This policy procedure sets out how vulnerable consumers are recognised, logged and supported, and points to the registers, forms and code of conduct that hold the detail.

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The following document labelling is included in the footer:

• Policy number and title
• Information-classification
• Version
• Page number / total pages

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Further Reading

Further guidance on consumer vulnerability:

• Consumer Vulnerability
• Consumer Vulnerability Risk Management
• ISO 22458 Clause 8 - Responding to Consumer Vulnerability
• ISO 22458 knowledge base

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Consumer Vulnerability Policy Procedure Template

The Consumer Vulnerability Policy Procedure is a Word template that sets out how a business identifies and responds to consumer vulnerability. It covers logging interactions with vulnerability flags, inclusive service design, roles and responsibilities, third party representatives, recognising and understanding vulnerability risks, service interruption, staff training, monitoring and continual improvement, and reporting concerns.

It is written to meet ISO 22458 and is classified Business Use as an internal procedure for staff, with a publicly shareable code of conduct carrying the outward facing policies. It has Title, File Location, Issue No, Issue Date, Controlled By and Approved By fields and an Amendment Record.

What the Policy Covers

• Summary, applicability and requirements - the purpose and Business Use classification, who the procedure applies to, and its aim of meeting ISO 22458, with guidance on what vulnerability means
• Logging interactions and inclusive design - records of interactions with vulnerable consumers using flag codes, and an impact assessment when designing or reviewing a service
• Roles and responsibilities - the Vulnerable Consumers Representative, an action team set up as needed, a focus committee for reviews and the duties of frontline staff
• Third parties and recognising risks - checking the identity and mandate of third party representatives, and vulnerability risk registers covering risk factors, research, case studies and support providers
• Understanding risks and service interruption - tables of individual needs and response options for frontline staff, and steps for supporting vulnerable consumers when services are interrupted
• Policies, training and awareness - the related policies and code of conduct, the resources given to frontline staff, training and periodic staff questionnaires
• Monitoring and continual improvement - monitoring of service provision, website accessibility reviews and testing, staff and consumer feedback, problem reporting and internal audits
• Reporting concerns and investigations - an open reporting culture, concerns raised with the representative on a report form, suspected data breaches and an appendix of external references

Built for ISO 22458 Inclusive Service

• Flag codes for suspected, confirmed and customer advised vulnerable consumers, used when logging interactions
• A named Vulnerable Consumers Representative with overall responsibility, supported by an action team when required
• Identity and mandate checks before personal information is discussed with a third party representative
• Response options for difficulties such as memory and recall, understanding information, communication and making payments
• Periodic website accessibility reviews, with a further review whenever a site is redesigned

Who Needs a Consumer Vulnerability Policy Procedure?

Businesses that deal with consumers who are, or could be, vulnerable, including those working towards ISO 22458. It is used by the person appointed as Vulnerable Consumers Representative and by the frontline staff who deal with consumers.

Included in the ISO 22458 Toolkit

This policy is part of the ISO 22458 Toolkit.

How the Policy Fits Together

Risks are summarised on F-IMS58 Vulnerability Risks Register and ER24 Consumer Vulnerability Register, new or reviewed services are checked with F-Q100 Inclusive Design Impact Assessment, and concerns are raised on F-Q102 Vulnerable Consumer Report. Staff awareness is checked with F-Q101 Consumer Vulnerability Staff Questionnaire, service provision is inspected on F-Q103 Consumer Vulnerability Monitoring Form and websites are reviewed on F-Q104 Website Accessibility Review. Investigations and review meetings can be recorded on F-CV1 Focus CV Committee.

Using the Policy

Edit the procedure to match your services, such as the flag codes your systems use, who is appointed Vulnerable Consumers Representative and how monitoring is scheduled. Name the person in the Controlled By field, give it top level approval and brief all frontline staff.

Related Documents

The public facing approach and policies sit in CC-CV1 Code of Conduct - Vulnerable Consumers, with GG-1-17 Consumer Vulnerability Guidance and TT-1-17 Consumer Vulnerability Training Talk supporting the frontline staff training the procedure requires.