Vulnerable Customer Policy

  1. Introduction

At OpenDoor, we are committed to ensuring that all members of staff are able to understand how to pick up signs of a vulnerable client, and how best to handle such situations with care and respect.

All staff will have had telephone conversations with people who find it difficult to make an informed decision about the choices offered to them. There may be those who have a diagnosed condition like dementia; those who have an undiagnosed or temporary mental health condition such as severe anxiety; those with learning difficulties or literacy issues; or those who have problems understanding the language.

Contacting our clients by phone to seek instructions, updating them on the progress of a case, or, or to offer new services and promotions, or simply to keep the client informed and aware of how we are dealing with the everyday situations arising on his/her case, is important for both parties. It is therefore important that vulnerable clients are able to fully understand your conversation with them.

At OpenDoor it is imperative that we strictly follow this code in order to ensure absolute fairness and equality of service to all our clients. These guidelines have been provided as a practical framework to help everyone in our organisation to communicate with our vulnerable clients with the utmost care and respect.


  1. Practical issues for our staff

 2.1 Identifying vulnerable clients

In order to address the needs of vulnerable clients correctly it is important to be able to identify them. Our staff are trained to look for risk factors, which can include bereavement, illiteracy, illness, disability or other impairment. In many cases more than one risk factor is present which increases the client’s vulnerability.

Our staff are alert to the signs that the person they are talking to may not have the capacity, at that moment in time, to make an informed decision about the implications of the agreements that they are being asked to make, or advice they are being provided with. This is not a diagnosis of a condition, it is just an extension of our staffs’ existing skill of listening, identifying needs, and adjusting their approach accordingly.

The Mental Capacity Act 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.

Frontline staff should be alert for signs such as:

  • They ask you to speak up or speak more slowly

> can they hear the complete conversation or are they missing important bits?

> do they understand what you are saying?

  • They appear confused
  • do they know what is being discussed?
  • do they ask unrelated questions?
  • do they keep wandering off the point in the discussion and talking about irrelevancies or things that don’t make sense?
  • do they keep repeating themselves?
  • do they say ‘Yes’ in answer to a question when it is clear they haven’t listened or understood?
  • They take a long time to get to the phone and sound flustered or out of breath, indicating they may have a lack of mobility due to age or illness
  • They take a long time to answer questions. They say “my son/daughter/wife/husband deals with these things for me”
  • Where there is a language barrier they are vulnerable as they may not fully understand what is being said to them
  • They say that they don’t understand figures put to them, a previous phone conversation or recent correspondence.


2.2 Practical tips provided to our staff when talking to vulnerable clients

Speak clearly and enunciate

  • Set expectations for the call – outline all the information that will be required – account numbers, personal details, etc – and how long the call is likely to last.
  • Be patient / empathise
  • Don’t rush them – if they need to put the phone down to find account details it could take them some time.
  • Guide the call to keep it ‘on topic’ – staff need to be coached on how to do this.
  • Don’t assume that you know what the client needs – it’s easy to rush through if the consumer is slow or not able to explain what they need.
  • Clarify understanding at every point posing the question “is there anything you’d like me to explain?”
  • Ask the client to explain to you what they understand the agreement or offer/promotion to be.
  • Offer alternatives to dealing with things by phone – maybe they would prefer to transact the business by post or email.
  • Don’t assume that the person you are talking to is sighted – they may be unable to read serial numbers or statement details.
  • Don’t assume that the person you are talking to can hear everything you are saying – they may have a hearing impairment.
  • Remember that a vulnerable client can sometimes be forgetful or overly trusting.
  • Give the client time to explain fully – don’t interrupt or show impatience.
  • Listen for what isn’t being said, not just what is – e.g. absence of understanding, commitment, timing type questions on the part of the person receiving the call should ring alarm bells.
  • Ask if there is a better time to call – e.g. some people will function better in afternoons than mornings.
  • Ask whether there is anyone else they need to talk to before making the decision.


  1. Best Practice

3.1 What our staff do when a vulnerable client is identified

  • Once a vulnerable client has been identified, or the staff member reasonably believes that he/she is dealing with a vulnerable client, they should immediately refer the matter to their Team Manager who must then review the service provided, regardless of whether the customer has been with the company a long time.
  • The Team Manager must satisfy him or herself that the client has particular needs, to ensure future communications are tailored to those needs. All staff are then under a duty to identify those client’s needs and vulnerabilities each time they are spoken with to ensure consistency of service.
  • DPA 1998 requires that any information stored must be recorded with the full knowledge and consent of the client, and must be kept accurate and up to date. If the communication needs of an individual are due to a disability eg needs to be contacted by telephone only as they are blind, care must be taken about the recording of any medical data, as it is classed as sensitive and personal, and has to be checked for accuracy. It should be relevant but not excessive. The data will be deleted when the relationship no longer exists between Harrington Brooks and the client.
  • A client’s circumstances can change so be aware of the fact that a client might be telling you that they now have recent health issues which would warrant handling them as a vulnerable client, and again the case should be escalated to the Team Manager.
  • If a client does not want to be called again as a direct result of their incapacity or health issues, then the matter is referred to the Team Manager to respond with suggestions of alternative means of communication, to the client’s satisfaction.
  • When a problem occurs as a result of the client’s incapacity, and perhaps lack of understanding, the Team Manager will have systems in place to track back and listen to calls to find out where the misunderstanding took place and identify what procedural changes or additional training is required to prevent it happening again.
  • In some cases vulnerable clients will not have the capacity to make the decisions that are required to set up or administer their account. The staff member will try to identify a carer or someone who is authorised to act on behalf of that client with respect to financial affairs. The staff member will also ask if there is a valid Power of Attorney in place. Evidence must be provided of that authority to act, along with appropriate ID, before any further private or confidential information is passed to that person.
  • Ensure that Attorneys or authorised persons know exactly what is expected of them.


3.2 What to do when the client alleges their incapacity is life threatening eg suicidal

  • Under no circumstances should the member of staff continue with the conversation if the client suggests they may be thinking of committing or have committed any kind of self harm. The case will be immediately passed to the Team Manager who will contact the Police. The business will fully co-operate with any further Police enquiries and offer help to the staff member, if he/she has become distressed by the call.

Remember all our clients are important to us, and those suffering any incapacity or vulnerability must be particularly looked after, and treated with the care and respect they deserve.

All members of staff, regardless of grade or level who have any client contact must read this policy regularly and ensure they understand it fully.