If you offer your UK customers subscriptions for goods or services then there are significant changes coming your way. As mentioned above, the Digital Markets, Competition and Consumers Bill is now making its way through parliament!

The Bill isn’t just concerned with subscriptions, there are 5 new requirements on firms that you really need to know about. These are planned to make subscriptions more transparent, understandable and to help address the ‘subscriptions trap’ which results in millions of consumers paying for things they no longer want or have forgotten.

Once passed into law, the changes aren’t likely to take effect until the second half of 2024. But that’s just a year away and you may well find that the contact centre, process, proposition, process and data changes required are significant.

And once you’re compliant with the new rules you can then assess their bottom-line impact on subscription acquisitions, retention and revenues. For some it’s likely to be massive.

Whats changing?

1. Full Transparency

When a subscription starts with a free or discounted period then the company needs to be transparent up front about the new or increased cost – and the date when it will start to be paid. If the subscription is purchased online (as almost all are), the consumer needs to acknowledge that they understand they need to pay; how much and when.

Free or reduced-price periods are one of the most common techniques used for marketing subscriptions. They still can be, of course, but the substantive rates and the point at which they become effective will need to be overtly highlighted in a way that they often aren’t today – and in a manner that allows the customer’s understanding of the terms to be captured

2. Sharing information, twice!

“Key information” is to be shared with consumers before they enter into a contract, with “full pre-contract information” (the small print stuff) to be provided as close to the start of the contract as possible – but both lots are to be provided separately, so consumers aren’t bombarded by lots of information at once.

So that’s two separate ‘sends’ of information. You will need to amend your processes, review all your information and terms and conditions – and decide which information needs to be sent to customers when.

3. Reminder and reminders

Reminders must be provided before the first payment and before renewal (at between 3 and 5 working days before renewal) – with two reminders for annual subscription contracts.

Yes, you’ll need to remind customers when they’re about to start paying, even after an introductory free period (and just to make things more challenging, unless the customer has opted into marketing communications, then to obey the Data Protection Act that reminder will need to be dull, factual and unpersuasive).

4. Easy cancellation

Consumers need to be able to cancel through a single communication, without undue barriers.

So, the days of requiring customers to speak to the ‘cancellation’ (i.e. retention) team are numbered! You won’t be able to demand that customers speak to an advisor in order to cancel.

5. Cooling off periods

Consumers buying digital products already benefit from a 14 day cooling off period, but the Bill proposes extending these periods for subscriptions:

Just from a data and customer management perspective these new cooling off requirements may prove onerous – never mind their revenue and retention impact.

What will be the impact?

The effect of these changes is likely to be substantial. The new duties will probably require extensive technology and data developments, but the commercial impacts will be considerable, too.

There is a lengthy list of exclusions from the scope of what the Bill considers to be subscriptions, including utilities contracts, insurance and financial services contracts, package holiday contracts, medical prescriptions and residential tenancy agreements. Though nearly all of those will have sector-specific requirements of their own, too.

As ever, contact centres will find themselves right in the midst of the collision of proposition, customers and compliance.

Looking for support to lessen the impact of this new bill? Get in touch, we’d love to chat with you.

Wednesday 5th July, 11:00 – 12:00 (BST)

Whilst we discuss why the PCI DSS applies to contact centre outsourcers, we will also shine a light on what the benefits are to you in delivering a secure payments capability, including enabling your clients to take more payments from more customers, more often, more easily and at less cost.

Points for discussion include:

• Why does PCI DSS apply to contact centre outsourcers?
• How does an outsourcer certify their PCI DSS compliance?
• What is the downside if the client does not ask about our compliance?
• How creating a competitive advantage for clients will win you more business.

The session will be based on pre-circulated content, shared on event registration, enabling you to get actively engaged in the conversation with our panelists

Meet the panel

Jeremy King

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VP, Regional Head for Europe,
PCI Security Standards Council

[/vc_column_text][divider line_type=”Full Width Line” line_thickness=”1″ divider_color=”default”][vc_column_text css=”.vc_custom_1639756841207{padding-right: 75px !important;}”]Jeremy leads the Council’s efforts in increasing adoption and awareness of the PCI security standards internationally. He works closely with the Council and representatives of its policy-setting executive committee from American Express, Discover, JCB International, MasterCard and Visa. Jeremy serves as a resource for Approved Scanning Vendors, Qualified Security Assessors, Internal Security Assessors, PCI Forensic Investigators, and related staff in supporting regional training, certification and testing programs.[/vc_column_text][/vc_column_inner][vc_column_inner column_padding=”padding-3-percent” column_padding_position=”right” background_color_opacity=”1″ background_hover_color_opacity=”1″ column_shadow=”none” column_border_radius=”none” column_link_target=”_self” width=”1/2″ tablet_width_inherit=”default” column_border_width=”none” column_border_style=”solid” bg_image_animation=”none”][image_with_animation image_url=”27797″ alignment=”” animation=”Fade In” border_radius=”none” box_shadow=”none” max_width=”50%”][vc_column_text]

Andrew Barratt

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VP Technology & Enterprise Accounts,
Coalfire

[/vc_column_text][divider line_type=”Full Width Line” line_thickness=”1″ divider_color=”default”][vc_column_text css=”.vc_custom_1687251077941{padding-right: 75px !important;}”]Andy Barratt has over 20 years of experience in IT and cybersecurity assurance. He leads delivery teams across a number of high-risk verticals including financial services, FinTech, and telecoms, advising on the complexities that are involved with the PCI DSS self assessment or audit processes. Andy is also a member of the Forbes Technology Council and a frequent media spokesperson both in the US and internationally.

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John Greenwood

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Director, Compliance3 and
Head of Technology & Payments,
Contact Centre Panel

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John is an innovative, award-winning contact centre specialist recognised for his ground-breaking work in securing telephone payments and his collaboration with the PCI Security Standards Council in drafting the PCI SSC Information Supplement Protecting telephone-based payment card data. He has supported over 50 PCI scope reduction projects, giving him a unique insight into the applicability of the PCI DSS in contact centres, the contact centre supply chain and the technology provider landscape. As Technology Lead and Payments SME at Contact Centre Panel, John will chair our event from a contact centre outsourcers and technology providers standpoint.

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Who should attend?

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The UK new anti-fraud strategy looks to ban (a) ban the cold calling of financial services products, (b) ban SIM farms, mass texting and number spoofing and (C) utilise Action Fraud services.

A few days ago, the UK Government announced its new strategy to help combat fraud. It’s not surprising that this provoked generated a lot of publicity, as current estimates are that fraud accounts for 40% of all crime and scams have already cost UK consumers over £4 billion since March this year.

So, what does the Strategy mean for business and those of us involved in the management of contact centres?

In truth the strategy is a mixed bag of things that were already in train, things that should have already happened and some promised new innovations.

1. Ban on the cold calling of financial services products

This is the proposed measure which created most media interest. Even in the age of mass digital adoption, unwanted or ‘nuisance’ calls continue to be an irritant to consumers – and the outbound channel continues to be attractive to fraudsters.

The government’s Strategy, which is currently a proposed set of measures under consultation rather than an agreed series of changes, is a little unclear on specifically what falls under the scope of this measure. At times the government has suggested any financial services product will be banned from cold calling and at others it has referred specifically to investment products – which would seem to be a very logical extension of the current ban on pensions cold calling.

However, even as the GDPR and the 2018 Data Protection Act still slowly percolates its way into the consciousness of some people who’d still prefer to forget all about them, hadn’t true ‘cold calling’ supposed to have stopped anyway? In any event, none of us should be calling consumers ‘cold’ to offer them financial services products, now, because the FCA bars the activity anyway. (see its Handbook and the imminent Consumer Duty).

Although if you call a customer or prospect that you deem to have a relationship with and who you think will anticipate hearing from you by phone and they don’t agree, then that’s a different matter! And if you use a business partner to provide you with sales leads – especially for financial services products – then some rigorous due diligence is called for.

2. Bans of SIM farms, mass texting and number spoofing

Sim Farms

Another key proposal contained in the strategy is a plan to ban both SIM farms and mass texting. It would be hard to work out what legitimate reason anybody would have to operate a SIM farm, which is a cheap device that allows mass calls and messages to be generated using numerous SIMs and mobile numbers. The USP of a SIM farm is that it allows the CLIs (outbound calling / texting numbers) to rapidly rotate, thus avoiding detection and the risk of being blocked by the networks.

Mass Texting 

Likewise mass texting is to be reviewed. As the government acknowledges there are obvious, beneficial use cases for the use of mass texting, but not many in the arena of sales and marketing.

Number Spoofing 

Fraudsters love the apparent ease with which legitimate calling numbers can be ‘spoofed’, so that the real origin of scammers’ calls are hidden. You might think that spoofing can best be addressed by the network operators, and you would be right. This proposed change is just a reflection of work Ofcom has finally started to focus on, getting the networks to deploy technical measures to stop spoofing. As well as applying more pressure on the networks and their re-sellers to undertake proper due diligence of contact centres and communication providers using numbers.

3. Action Fraud action (again)

Like Mark Twain, reports of the death of Action Fraud are greatly exaggerated. Action Fraud is a fraud reporting service run on behalf of the City of London police. It carries out a triage and assessment function, helping collate the volume and type of fraud, nationally, as well as providing data and insights. However, only a small minority of the c.1,000 cases reported to it each day by consumers go on to be actively investigated by the police.

Now the government has pledged to invest £30m over 3 years to replace Action Fraud with “a state-of-the-art reporting centre, including a simple to use reporting website and upgraded call centre with reduced waiting times”. In fairness, while that doesn’t sound especially ambitious it will a step-change improvement over the current service.

So, if you might benefit from a chat about how you handle your outbound calling, CLI treatments, how you assess marketing permissions for proactive communications including by SMS – or anything else the new Strategy touches on – then just let us know (unless you’re a fraudster, of course).

You’ll need to tailor that approach according to sector, profile and demographics, but speaking to people is where you start to bring all that hard work together.

How easy is it to sign up or subscribe to your company’s products or services? Pretty easy I should think (or hope). Now more than ever, organisations understand that in our hyper-competitive world, a friction-free way to make consumers aware of what you offer and to make it as easy as possible to become your customers, is vital.

However, deliberately creating friction and barriers for customers looking to leave is almost as common. We all know that it takes a lot of effort and expense to acquire customers, so surely making it a bit of an up-hill slog for customers to leave is just common sense?

Maybe, but possibly that’s all about to change. Be warned!
In the US, Ericsson-owned Vonage has been fined $100m by the US Federal Trade Commission for using a raft of measures which meant that domestic and small business customers found it almost impossible to cancel Vonage’s VoIP services.

Vonage’s services were easy to start using, with many customers offered ’free trial’ opportunities allied to less-than-transparent switches to default sign-up and auto-billing. But when it came to trying to cancel their membership, things were difficult and ‘friction’ was everywhere. The tactics Vonage used ranged across: the sophisticated use of ‘dark patterns’ on the web; making customers speak to ‘retention team’ advisors in order to cancel; hiding the ‘retention’ phone numbers; routing cancellation calls to barely-staffed phone lines with inconvenient opening times.

“Do as I say, not as I do”

The FTC gleefully highlighted Vonage’s own advice to its business customers which it totally failed to take itself – a classic case of “do as I say, not as I do”.

Vonage’s advice included:

They don’t mean us though, do they?

However, most of us aren’t in the US and not under the jurisdiction of the FTC, so does this really matter?

Well, first of all, a lot of us work directly or indirectly supporting US clients and their customer experience delivery, so it’s always helpful to know if you’re potentially part of delivering illegal customer journeys!

But equally, government regulation tends to – slowly – follow international trends. So, Vonage’s recent experience might be a $100m sign of things to come in other markets and jurisdictions. In the UK we know that government is still determined to tackle the consumer ‘loyalty penalty’ (the fact that many products and services are cheaper for new customers than for loyal, long-established users), which is closely related to a customer’s ability to exit expensive deals and relationships – and similar concerns are voiced in the EU and expressed through its Digital Services Act.

So, if part of your customer retention strategy is the creation of challenging journeys for people looking to cancel, then it may be time to do some redesign!

However, it might be that you provide services to a financial services firm at some point along its customers’ journeys, or that you are in a customer-facing part of a financial services firm that tends to be the last involved in these big programmes of work. In which case, what do you need to know?

If that is the case, it will almost certainly pay dividends to take some time to read through the FCA’s documents and guidance, which you can do here. You don’t need to be an expert in it all, but it’s good to be able to put the customer contact tasks in a wider perspective of what’s trying to be achieved, which is “delivering good outcomes for retail customers”.

The Consumer Duty is broad in its scope. It naturally has a major focus on how B2C financial services products and services are designed. As well as the changes at executive level that need to be made to recognise the Consumer Duty’s demands. But – I hope – you don’t need to worry about that, because your colleagues or clients should already have that in hand. Where they might benefit from your help is in how firms communicate with customers and support them. This is where the contact centre and customer engagement teams’ detailed understanding of customers and their needs can really help.

Customer Communications

Even if you have no direct role in the creation and distribution of automated communications (letters, texts, emails, in-app notifications, etc.) you will have ‘from the horse’s mouth’ an understanding of how they are received, understood and acted upon. Previously firms were obliged to be “clear, fair and not misleading” in their communications. Now they need to be “understandable” to a whole range of customers, in a variety of circumstances, including those considered to be vulnerable.

This is likely to require:

All of which you and your teams are perfectly placed to help with.

Training

Your teams are directly interacting with customers. To do this as well as the Consumer Duty will demand, your people will need the skills and tools to:

If you feel that this is not already the case, then you need to ensure that training, coaching tools and resources are made available to you. If all these elements are already in place, then now might be the time for you to start training the rest of your organisation on these vital skills and aptitudes!

If you’d like to discuss how you are facing up to the Consumer Duty’s customer management challenges, just drop us a line.

Even today, businesses find themselves with new compliance challenges; homeworking is a great example of this.

So, do you need to spend big (or spend anything at all) to become compliant? The answer is both yes and no, for the reason being that it depends on your company objectives. For example, if your business finds itself taking payments for a product or service, then you will need to become PCI DSS compliant to do so (due to the regulations that are in place to protect cardholder data). Not only will you have to complete the process to provide an attestation of compliance, but you will also need to employ the right resource to undertake this task. Ultimately this will take both time and money for it to be completed.

However, I’ve always been a firm believer that applying best practice shouldn’t have to cost you the earth. Here are my top 4 tips on what you can do today without spending big money:

1. Documentation

It’s usually the last thing on our minds, however documenting your processes and procedures is vital in not only demonstrating your standards, but also leaving a set of documented instructions for new employees or third parties. A simple flow diagram will suffice if you don’t possess any great writing skills within the business.

2. Assess Risk

After you have documented your processes and procedures, you should review these with key business stakeholders to identify any risks. If you do identify any risks, I would suggest logging these somewhere. There are plenty of risk templates online, a simple Google away. By logging risks, you’re halfway there in showing risk and compliance best practice. You then need to decide whether you address that risk or accept the risk.

3. Keep up-to-date

Make sure that you know your industry. There are updates all the time to regulations, laws and best practice, so make sure you follow and react to these changes. I would suggest subscribing to regular newsletters, be that the ICO for Data Protection Regulation changes or the FCA for all things financial. You will also find updates within this monthly Insights publication, along with the latest information from the world of contact centres.

4. Don’t be afraid to ask

Rather than cowering under your desk at the thought of any of the above, don’t be afraid to ask the question. Be that a colleague, a like-minded business or Contact Centre Panel! You will be surprised how receptive people are to a soul in need.

By adopting the 4 steps above as your mantra, you will put yourself and your business on the right road to your eventual destination.

Looking for support with your next compliance project? Drop us a message and let’s chat!

Everyone wants positive growth. Perhaps not our waistband, but certainly everything else. It’s how capitalism works. Positive growth is a simple concept. Increase the number of new customer transactions, increase the frequency of existing customer transactions or increase the average transaction value. Deliver any one of those and growth is linear. Deliver all three and growth is exponential.

In the contact centre tech’ space we see lots of solution providers targeting firms that want to increase growth, whilst at the same time reducing cost to serve. They offer us great case studies of how they have increased operational efficiency, seamlessly delivered new customer communication channels and/or augmented people assets through digital assistants or BOTs to drive automation. This conversation is not about that. This conversation is about something far more basic and far more fundamental to the transaction process. Payments.

In my experience, when business managers think of contact centre payments, two things come to mind. One is taking payment cards over the phone. The second is the complexity of the Payment Card Industry Data Security Standard. Generally, the conversation ends abruptly when it comes to the PCI DSS. Usually, the discussion is never really that interesting and is likely to cost money. Plus people believe the PCI DSS to be so complex when it comes to contact centres, that it feels easier to pay the monthly non-compliance fines and increased transaction charges.

Well folks, there is another way to think about it and here is why. Just like we think of aligning our contact centre tech to engage with the customer – less friction, less cost etc, so we should think about payments. We know our customer communication strategy should align with how our customers want to engage with us, so why not our ability to take payments?

The point is that contact centre payments are just like contact centre everything else, they need to support how customers want to interact with us. And what does that mean in the context of growth. Well, the answer to that is simple. Just think about how you can take more payments from more customers more easily, at less risk and at less cost. Have a payments strategy and align it with how customers generally want to pay and enable that within all the communication channels you use to engage with customers.

Oh, and the PCI DSS thing? Just come and ask and we’ll simplify that whole thing for you.

However, if you work in contact centres and you were around from 2017 to 2018 when the EU’s General Data Protection Regulation (GDPR) and the last Data Protection Act went live, you may be less excited about the prospect of more change!

Following the previous Bill, millions of working days were spent trying to figure out what it all meant in practical terms; changing processes and procedures; ditching databases; confusing consumers with millions of ‘would you still like to hear from us’? emails; and preparing for a tsunami of data rights request contacts which never really happened.

Well, the good news is that the recently proposed Bill looks a lot more like a sensible tidying up of the rules (and the slightly vague promise of less data protection bureaucracy and admin), rather than a radical overhaul. The fundamentals will remain the same. The post-Brexit UK version of the GDPR will remain in place, alongside the 2018 Data Protection Act. For a business this is doubly reassuring, not only does it suggest fewer revisions and re-work to existing policies and processes, but it also means that it’s less likely that the UK’s rules will deviate so far from the EU’s that we lose our prized ‘adequacy’ status, which allows UK firms to process and transfer personal data with the EU with little friction.

There are many areas covered by the proposed Bill, but for most of us the key elements are:

If you would like to discuss these forthcoming changes and review your current approach to ensuring data protection and privacy, please drop us a line.

Source information: Data Reform Bill

It’s a conversation I’ve had more than once over the past few months, so let’s explore further:

What is ISO certification?

In layman’s terms, this is the official approval to show that you comply with one of the many international ISO standards that are in place currently.

What does ISO cover?

There are many (and I mean many) different ISO standards available. Covering things from IT Security to Environmental Management.

Do I need to be ISO certified?

The simple answer is no, however, it does truly depend on your current circumstances and future objectives.

When should I be considering ISO certification?

Again, this really does depend on your current circumstances. Many organisations go for a specific ISO certification because their clients demand it or it is required for a particular tender. Some organisations use it as a barometer of how well they are doing, and whether there are certain improvements they need to make.

If you are considering embarking on the ISO certification journey, we would suggest considering three key areas before setting off:

1) Cost: Be prepared to make a commercial commitment as part of the certification process and beyond. Whilst there will be an initial cost for the audit and award of the certificate, most businesses forget to track the cost of the internal resource they will need to engage with for the preparation and delivery of the ISO accreditation.

2) Time: Ensure that you book plenty of time in ahead of the audit date. Use this time to conduct a gap analysis against the standard, ensuring you cover all of the points ahead of the audit. You don’t want to go through this process more than once – it will cost you precious time and money.

3) Internal buy–in: There’s nothing more important than to ensure you have all key business stakeholders on board before you set off. Some certifications, such as ISO9001 – Quality Management Systems, will touch upon all areas of the business. Delivering one, strong, united message across your business is pivotal.

Achieving certification may provide increased sales opportunities or identify risk/opportunities you were never aware of. All in all, the benefits that you gain will vary greatly depending on the ISO standard that you implement and the amount of effort you put into it.

Need a safe pair of hands as part of your ISO journey? Drop us a line.

The primary reason for these firms being fined was that they were calling prospects who they didn’t have a prior relationship with, whose numbers were registered with the Telephone Preference Service (TPS). This, as most of us should well know, is illegal. As covered in our previous articles – ICO flurry of fines and BTB sales and marketing ops compliance.

However, when the ICO levies a whole series of fines on firms in the same sector, with similar sales and marketing models, it’s evidence of other underlying concerns. Although the ICO’s Enforcement Notices only refer to 67 consumer complaints, these kinds of collective enforcement actions are invariably evidence of alarm bells ringing at the ICI’s Wilmslow offices about widespread misbehaviour. Here, the ICO has highlighted these firms’ targeting of vulnerable consumers, in this case the elderly.

Targeting the vulnerable elderly

Undoubtedly, judging by the evidence presented by the ICO, this is exactly what these businesses did. While it’s arguably unfair to judge a firm’s sales and marketing practises based on relatively little information, I think we can be confident that these firms were all at the malicious end of the ‘Ignorant vs Complicit’ spectrum of compliance awareness. They seem to have known exactly what they were doing, which is to deliberately target the vulnerable; selling on the basis of worry and fear, not value and consumer benefit, to those least well equipped to make informed decisions.

Scammers stick together

In an interesting example of geographical clustering, 4 out of 5 of the firms were located in East Sussex on the South coast, presumably showing connections to the biggest name in appliance warranty insurance, Domestic & General in Brighton (about which there is no evidence of the ICO having concerns, I hasten to add). So, even scammers like to stick together!

The vast majority of firms don’t set out to exploit or deceive, but

  1. Being a legitimate, respectable firm – even a blue-chip brand – is no guarantee you won’t be snared by the ICO, as the Royal Mail, American Express and Saga, which have all recently been hit by enforcement actions and fines, can attest
  2. Awareness of the prevalence and importance of vulnerabilities has grown. An understanding of vulnerability had increased before Covid 19, but the pandemic has accelerated it massively. Firms need to be able to both recognise and adapt to prospects and customers who are exhibiting signs of vulnerability

So, what can we learn from this raft of ICO fines? Does the rise of vulnerability awareness just mean that we can no longer sell to older people?

We sought the opinions of some members of the wider Contact Centre Panel network.

Are older consumers too ‘risky’ to market to?

Senior Response is a long-established outsourced contact centre “dedicated to communicating with the older consumer market”. So, what conclusions does Managing Director Michael King draw from the ICO’s slew of fines? Can firms still confidently market and sell to Mature consumers?

“We find that firms which utilise direct mail or online activity prior to commencing telemarketing activity not only have better results but give the customer and prospect the opportunity to know a little bit more about the business and ultimately be more receptive to being contacted.

We work very closely with our clients to ensure that we have a shared Vulnerable Customer policy, which outlines the process if we believe we have a vulnerable customer and what steps to take.

The other point I would stress is that firms should be aware that the adult children or grandchildren of many mature consumers are often part of the decision-making process and therefore your customer journey from marketing to sales, should incorporate this. We often arrange call-backs with our client’s customers to speak with the family member where permission is granted by the customer and requested by the family member. We all want to ensure our parents and elderly relatives are not being taken advantage of by the very things that the ICO have acted on.  It is our view that firms who are proactive in the examples I have mentioned, are more successful in marketing to this rapidly growing market.”

What really is vulnerability?

“Circumstances impact people in different ways – what makes one person vulnerable may affect another quite differently. Age, mental and physical health and financial pressures are all subjective. We believe it is important to communicate with people in the most tailored way possible according to their circumstances and use the tools available to determine what is appropriate.” Helen Lord, CEO, Vulnerability Registration Service

You can find out more about the Vulnerability Registration Service by clicking here

How can technology help?

Can the new technologies of machine learning and artificial intelligence play a part in helping firms identify vulnerable prospects and customers – and serve them better, too?

Keith Shanks of Vorth Technology Solutions helps make contact centres work more effectively through the application of AI (artificial intelligence) tools. Can they support centres involved in sales and marketing, especially when they are targeting groups which may contain vulnerable consumers?

“Advances in AI and Machine Learning (ML) now mean that all contact centres are able to highlight potentially vulnerable customers. As has already been highlighted, vulnerability comes in many different forms and it is the responsibility of companies to understand these and act appropriately.

The truth is there is insufficient attention given to vulnerability and if you consider the current economic climate, responsible companies should be paying more attention to the welfare of their customers and the right technology will have a huge impact on this.

We expect a mini-revolution in this field over the next few years as regulators also start using technologies to review and monitor call centre services.”

Financial services: What’s the FCA’s perspective?

Elanev provides dynamic scoring services to contact centres including propensity and best time for contact, propensity for purchase and propensity for financial resilience / vulnerability with no GDPR implication.  Elanev’s John Willoughby gives his practical guidance for the future of such financial product sales and marketing, in light of proposed regulatory changes:

“Financial product sales will be bound by the FCA’s proposed Consumer Duty requiring marketing firms to “deliver good outcomes for retail clients”. The FCA expects all reasonable steps to be taken to avoid causing foreseeable harm to customers. Harm being primarily financial, but may also include mental health effects.

The FCA is requiring firms to have a better understanding of their customers calling out the need to understand customer propensity for vulnerability and to harm. The FCA expects firms to predict behaviour and monitor outcomes recognising the need for data to support this. Common data sources include:

 To properly identify, quantify and assess vulnerability a combination of data sources may be needed. The specific combination depending on the depth of customer insight that the organisation has and the level of customer consent granted.”

So where does this leave us?

Helen Lord of the Vulnerability Registration Service makes clear that vulnerability isn’t simple or clear cut. The scammers recently fined by the ICO deliberately targeted older people, but not all older people are vulnerable. So, we all need to be more vulnerability aware and unavoidably some customer and prospect groups are likely to contain a higher proportion of people with vulnerabilities. Senior Response is dedicated to engaging and communicating with older people, but as Michael King explains, they do so in a sophisticated way. Senior Response and its clients make use of multiple contact channels and embrace more varied and flexible customer journeys. This might point the way for other sales organisations – and not just for those targeting the ‘grey market’.

A growing role for technology and the insights it can provide seems to be unavoidable and desirable. Vorth Technology Solutions’ Keith Shanks has explained how technologies like his can help identify the ‘growing’ number of vulnerable consumers. John Willoughby from Elanev shows that in the regulated financial services sector, especially, the smarter use of data across a combination of sources is now essential.

The ICO’s fines of exploitative scam marketers doesn’t mean that older consumers are now ‘off limits’ for responsible, ethical firms. But the fines do help highlight the growing importance of being able to recognise and respond to consumer vulnerabilities; not just as an ‘add on’ but in a way that is embedded into processes and customer journeys.

If you require guidance on any of the areas discussed in this article, please contact us.