In last week’s article, we looked at diversity and inclusion in customer services under the Consumer Duty. In this article, we will be looking specifically at disability, one of the nine protected characteristics, and how it can affect a customer’s experience.
It is important to note that protected characteristics are not the same as characteristics of vulnerability. The FCA defines a vulnerable customer as someone who, due to their personal circumstances, is more at risk of harm. Being disabled does not automatically make someone vulnerable, but sometimes a disability can make someone become vulnerable. All of us have a chance of having a disability, whether it be temporary or long-term.
There are some ways in which disability and vulnerability can be linked, such as financial exclusion or difficulty in accessing services. Disabled customers tend to have lower levels of savings, which can make insurance unaffordable or result in not being able to keep up with payments. Certain communication channels can make access to services more challenging for disabled customers, such as emails being difficult to use for those who have visual impairments. It is also important to remember that not all disabilities are visible. Someone may have difficulty communicating their needs due to a mental illness or neurodiversity, for example, 23% of people with mental health problems avoid switching because they find it overwhelming.
Someone should not be discriminated against or disadvantaged because of their disability. There are ways that firms can help support disabled customers to pursue their financial objectives:
Products and services
Under the Equality Act 2010, firms should accommodate the needs of disabled customers. Reasonable adjustments should be made for those with certain needs so that they can more easily access products and services.
Price and value
Firms must examine whether the price of the product or service is fair value while also considering that disabled customers may be disadvantaged. Evidence of fair value must be provided, such as basing risk assessments on reliable sources and statistics.
Firms should anticipate the needs of disabled customers. For example, if a customer is visually impaired, information can be provided in an accessible format, such as through audio or braille, rather than by email or written letter. If a consumer has difficulty understanding due to a mental disability, processes should be in place to allow for more time or more in-depth explanations to ensure they are able to make fully informed decisions.
Firms must ensure that the channels of support they offer meet the needs of their disabled customers. They are expected to be able to provide support through a variety of different channels and respond flexibly.
The way you speak with disabled customers also requires consideration. You should address the customer in the same way as you would talk to everyone else and speak directly to them, even if they have an interpreter or companion with them.
If you are a Development Zone user, you can find a range of courses on diversity and inclusion in the course catalogue. For those not currently using the system, you can find out more and request a free 14-day trial here: https://mydevelopment.zone/#getStarted.