This document contains the Andrews & Arnold Ltd policy relating to dealing with vulnerable people. The document has been created in response to Ofcom’s “Treating vulnerable customers fairly” guidance published 23rd July 2020. It should be noted that Ofcom’s notes are not law, but a set of suggestions for how best to apply the law, and enact best practice.
General Condition C5.2 is part of the law, and requires A&A to “establish, publish and comply with clear and effective policies and procedures for the fair and appropriate treatment of Consumers whose circumstances may make them vulnerable.”
Most of this document is based on what Andrews & Arnold Ltd already offers especially in connection with the wider section C5 of the General Conditions of Entitlement.
Andrews & Arnold Ltd wishes to treat everyone fairly, all the time, and regards existing processes, attitude, and general mode of operation as achieving this in the vast majority of cases.
Therefore, this is mostly a policy to ensure that vulnerable customers obtain the same level of service, in practice, as that which is offered everyone else (but which they may be not making full use of, or are unaware of) rather than a policy to detail specific practices only for vulnerable people.
A&A will ensure that all staff are made aware of this policy.
2. Identifying Vulnerable Customers
The first step towards ensuring that vulnerable customers are able to access and make use of our services is identifying who is vulnerable.
A&A’s aim is to make it as easy and convenient as possible for customers to notify us that they are vulnerable, but without unnecessarily disturbing all customers in an intrusive and unwanted way.
Andrews & Arnold has a policy of not hassling customers and does not engage in any email marketing, or any telephone marketing, or any kind of direct marketing at all.
A&A does send out invoices to customers. From time to time, a news letter is added to this emailed invoice. This really is the only kind of mail shot customers would ever receive - and many customers choose A&A, in part, because they dislike being sold to.
It would be out of character for A&A to email its customers explicitly asking them to let us know if they are vulnerable, and indeed, might be assumed by many to be a scam, or similar. The negative effects of doing this would probably outweigh any benefit.
Therefore, it would seem proportionate to invite customers to notify A&A only by the following ‘non intrusive’ means :
A&A will endeavour to issue such a communication on an annual basis.
A&A will notify all “customer-facing” staff — in particular, in the sales, accounts, and support teams — to be mindful of cues that a customer may be vulnerable in their dealings with a customer (for example, by email, phone, or IRC).
There is no definitive list as to what constitutes a “vulnerable” customer, nor is a customer necessarily “vulnerable” or not: they may be vulnerable for a particular period of time, whether short or extended. Indicators of vulnerability include:
3. Routine facilities and services offered with utility/relevance to vulnerable customers
Many of the services A&A offer already to all customers have applicability to people who are vulnerable.
4. Special facility: An email address for vulnerable customers
Although A&A would regard all methods of communicating (as per the ‘contact us’ page on the website) as acceptable and accessible, a separate email address :
is made available.
This email address redirects to the Director, General Managers and Team Leaders of Technical, Sales and Accounts departments.
Given the size of A&A and the approach it takes to customer service, it is neither necessary nor proportionate to implement a specialist or specific customer service team or staff member for the purpose of dealing with vulnerable customers.
5. Empathetic customer service
A&A will remind staff in customer-facing roles of the need to be patient and empathetic, and — in keeping with A&A’s compliance with the GDPR — to ask for only the minimum information necessary to provide the service requested by the customer.
In particular, where a customer finds themselves in a distressing situation, staff shall focus only on the core information that they need (for example, avoiding unnecessary questions about a crime).
Where a third party makes contact with A&A on behalf of a customer, A&A’s identification and verification procedures will be clearly explained and appropriate to the circumstances to avoid unnecessary repeat contacts with the customer. The level of verification required will be dictated by the action which the third party is looking to undertake, or the information which they are looking to access, and the customer’s own choice of security settings.
If a customer indicates that they are facing problem debt, A&A will — as with all customers — treat them fairly. In particular, A&A will treat disconnection as a serious step to be used only as a last resort, but with the recognition that disconnection may be the consequence of a failure to pay for the service which A&A is providing. If A&A agrees to a repayment plan, the plan will be one which A&A considers is reasonable in the circumstances.
6. Record keeping
A&A will record any information relating to a customer’s needs relating to being vulnerable in the accounts system’s notes section. These will only be visible to staff.
Paragraph 4.17 of the Ofcom guidance: "We also encourage providers to do what they can to avoid vulnerable customers having to explain their personal circumstances each time they contact them, which could be frustrating and/or distressing.”
If A&A records information about a customer's vulnerability, the member of staff doing so will notify the customer that this is what they are doing. This is consistent with both the GDPR and Ofcom's guidance.
A&A's privacy notice is available at https://www.aa.net.uk/privacy/
7. Plain English communications
A&A prides itself of communicating in plain English, providing clear and simple guidance and documentation.
A&A’s terms of service are written in plain English, and A&A has included comments to explain provisions which, while expressed in plain English, may require a little further context for customers not used to the detail of communications services.
8. Monitoring the effectiveness of this policy
A&A will review the impact and effectiveness of this policy on an annual basis.
A&A encourages any customer who has comments or feedback on this policy, or their experiences of dealing with A&A as a vulnerable customer, to get in touch by a method of their preference.
9. Consultation with the Consumer Panel
As is required by GC C5.14, A&A would consult the Consumer Panel on request to ensure that the requirements and interests of End-Users with disabilities and Consumers whose circumstances may make them vulnerable are fully taken into account in the development and provision of their services.
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