Vulnerable Customer Policy

Identifying Vulnerable Consumers

For Leisure Promotions Newbury Ltd to address the needs of Vulnerable Customers, we first need to be able to identify them. There are many risk factors involved, including bereavement, illiteracy, illness, disability, or other impairments which increase consumer vulnerability.

We are alert to the signs that the person we are talking to may need help to make an informed decision regarding the implications of the purchase agreement we are making with them. This extends our existing listening skills and adjusts to fit their needs.

The Mental Capacity Act 2005 says that a person is unable to make a specific decision if they cannot understand information about the decision to be made, cannot retain that information in their mind, cannot use or weigh that information as part of the decision-making process or cannot communicate their decision.

Here at Leisure Promotions Newbury Ltd, as part of our customer experience, we always look out for vulnerable consumers and aim to help and support them through the following: –

  • Understand the customer's needs demonstrating compassion.
  • Be patient and take time to listen and facilitate a conversation with the customer so that they fully understand.
  • Provide a primary person for a familiar point of contact for the customer, ensuring consistency and trust.
  • Observe and involve other members of staff that can provide help and support.
  • Reward, recognise and praise good practices concerning vulnerable customers.
  • Make sure all frontline staff can deal with vulnerable customers appropriately.
  • Make all language clear and simple to understand, and do not use industry jargon when it is not necessary to do so.

What do we look for?

  • Do they ask us to speak more slowly?
  • Do they understand what we are saying?
  • Can they hear the whole conversation without missing bits?
  • Are they aware of what is being discussed?
  • Do they keep repeating themselves?
  • Are they asking unrelated questions?
  • Do they say YES to a question that they have not understood?
  • Do they suggest another family member deals with things for them?
  • When they say, they have yet to understand previous correspondence or communication.

Communicating with Vulnerable Customers

  • Speak clearly to the customer.
  • Set the expectations for the call.
  • Be patient.
  • Keep the call on the relevant topic.
  • Do not assume we know the customers’ needs.
  • Offer the customer a different method of communication.
  • Double-check that the customer has heard what you have said.
  • The customer may not be sighted.
  • Ask the customer if they need to speak to anyone before they make a decision.

What do we do when Vulnerable Customers are identified?

  • Refer the matter to a senior colleague.
  • The senior colleague must satisfy themselves that they have identified the customer’s needs and that the relevant communications have been noted to ensure future needs are met.
  • The Data Protection Act requires that any information stored should be recorded with the full knowledge and consent of the customer and how further communication should be made.
  • A customer’s situation can change anytime, so we need to escalate this to a senior colleague if this is identified.
  • Customers may be unable to make an informed decision on their own. It is important to try and find a Carer, family member or someone with authority and appropriate ID to act on their behalf.
  • Ensure that the authorised person knows exactly what is expected of them.

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