SFE Insight | Reflections from SFE's Vulnerable Customer Summit 2023, by Luke McKinney and Katherine Snow
SFE Vulnerable Customer Summit 2023 : Challenges, Collaboration, Commitments
Vulnerability can affect anyone at any time. In May 2023, The first Scottish Financial Enterprise Vulnerable Customer Summit brought together industry experts to discuss what it really means to support vulnerability, sector-wide.
The atmosphere at the summit was one of care and decisive action with a mutual understanding that the FCA’s Consumer Duty regulations are a great start, but there is more work to do. Work that will only be effective in collaboration. We were privileged to take part, hear best practices, share stories and reflect.
On the day, Nile facilitated an activity that codified the day's conversations into practical opportunities for change. Groups focused on one of four areas identified through the presentations, activities and panel discussions from the day. In each group, key challenges were identified to help inform a collective starting point. These were used to ideate better ways to serve vulnerable customers through industry collaboration. The groups then identified commitments we believed should be adopted at an industry level.
Ownership and responsibility
How might we establish clear accountability within our organisations and collectively as an industry?
Ownership and responsibility within organisations and cross-industry collaboration are logical starting points. The Consumer Duty regulations pose a new approach that may not neatly fit within existing org structures or ways of working. Teams are now challenged to think and respond to a changing landscape rather than simply implementing the 'rules' associated with new regulations.
Key challenge
The regulations are the bare minimum, and often treated as another box to tick, making it under-resourced or left to one team to implement. As an industry, we risk falling short of the outcomes vulnerable customers need as a result.
Opportunities for collaboration
● Define what ‘good’ looks like at a strategic level for Vulnerable Customers, in and beyond Consumer Duty.
● Establish an industry-wide charter that identifies and articulates key areas of action for organisations and the FCA.
● Refine services and strengthen the industry by mapping financial and financial support organisations in Scotland to understand gaps, link and improve handovers between financial services and specialist support providers.
Culture and capability
How might we ensure we have the organisational mindsets and skills in place to understand and deliver on the needs of vulnerable customers? In order to engage teams across traditional organisations and industry silos, we must establish a culture-driven approach. To unlock the knowledge of how individual roles contribute to supporting these, new skills, tools, training, and ways of working are needed.
Key challenge
Defining what ‘good’ looks like for different teams and roles is challenging. This in turn makes building awareness, understanding and confidence in the topic difficult at scale. To be consistently customer-led, vulnerability awareness must be embedded across entire organisations.
Opportunities for collaboration
● Build understanding and awareness of top-to-bottom industry resources.
● Create an academy for training, exploring both internal and shared variations
● Shift from designing for vulnerability to designing for a customer personalisation culture.
Measuring and monitoring
How might we measure success for the vulnerable customers engaging in our products and services?
To build a cross-organisational and cross-industry approach to vulnerability, goals, aims, and impacts must be consistent. Key to this is measuring how Consumer Duty changes practices, and defining its impact. In addition, it is making sure that no customers are excluded in the pursuit of metrics. Industry-wide collaboration to create collective KPIs will be necessary to do this at scale.
Key challenge
In our sector, every organisation measures success with different data points which makes impact measurement and funding challenging.
Opportunities for collaboration
● To develop best practices across the sector, agree on a shared set of data points or KPIs.
● Develop key metrics to enable signposting and clarity, and links to funding.
● Close the loop on inter-organisation hand-offs
Technology & data
How might we apply technology and the data we collect to deliver better and more consistent experiences?
In the UK, financial services are increasingly using digital channels to interact with their customers. This presents a number of challenges but also many opportunities. As a key enabler of Consumer Duty at scale, data and hyper-personalization can play a key role in delivering tailored, more consistent experiences to vulnerable customers than those reliant on human agents.
Key challenge
At this time, there is no clear value exchange for customers sharing data on their vulnerability. In many cases, customers ask, "Why do they need to know this information about me? Will it be used against me?”
Opportunities for collaboration
● Build trust by developing consistent customer messaging, across all providers, on the value exchange when sharing data on personal vulnerabilities and needs.
● Establish warm handoffs between banks, credit unions, pension providers, and third- and public-sector providers
● Consider implementing a trusted central directory/registry so customers can define and share their needs without duplicating the information across multiple providers.
Our commitments
Industry-level commitments were ranked and defined collectively by summit attendees. After the summit, these were consolidated into the following five areas:
1. Establish shared Key Performance Indicators (KPIs) to monitor and identify areas for improvement, share best practices, and enable industry-wide reporting.
2. Establish a sector-wide charter for vulnerable customers and expert-led best practices by mapping the ecosystem of multiple organisations (e.g. their services, links, boundaries, aims and hand-offs, etc.) and subject matter specialists (e.g. on inclusivity, scenarios, bereavement, etc.) to develop expert-led best practices.
3. Collaborate and share non-competitive information. At a macro-level, this could be sharing expectations and best practices; on a micro-level sharing individual personalisation preferences.
4. Measure and monitor industry-level handoffs to charities or specialist support channels - noting patterns, and providing funding to close the loop. This will build thinking, communication and collaboration beyond the financial services industry.
5. Have customers' needs embedded in every touchpoint and channel of their experiences so they only have to explain them once. Use technology to provide better and more consistent experiences at scale.
Next steps
Creating a sector-wide charter is the cornerstone of all these commitments. We recommend that a representative group of SFE member firms co-design the charter with individuals with lived experience of vulnerability. During co-design, a community works together to craft a solution collaboratively. This would involve three key steps:
Step 1: Get clear on the document's purpose and power
Establish the specific goals, purpose, role, and format of the charter. It will serve as a unifying document that sets out our language, our aims, our commitments, and the high-level metrics that will guide us.
Step 2: Establish a space for deep discussion to articulate consensus and best practices
For the charter to represent and set new intentions based on the summit's outcomes, it is essential to discuss its content deeply, gain insight, experiment, and iterate.
Nile is happy to host and facilitate these co-design workshops in our Edinburgh office. To be effective, any charter must be both tangible and future-oriented, enabling immediate action and long-term sustainability.
Step 3: Provide organisations with a variety of engagement options
Unlike strategies or guidelines, a charter requires organisations to engage by consensus on a chosen commitment. We need to ensure that our charter is accessible in a variety of ways so organisations can engage with it in a way that is inclusive and works for them. This will take time and socialisation