Financial services firms are at risk of alienating consumers by obtaining vulnerability data without their knowledge and not engaging directly with the client, according to MorganAsh.
Under the regulator’s consumer duty, firms are required to identify and assess vulnerable customers.
Some companies, particularly those in credit space, are trying to obtain vulnerability data by using external sources such as credit scores and socioeconomic data.
However, Andrew Gething, managing director of support services provider MorganAsh, argued this approach could mean judgments are made about consumers’ vulnerabilities behind their backs.
Since this runs the risk of alienating clients, Gething said firms should instead engage directly with the consumer.
He explained that it is similar for those firms in the distribution chain which are reporting few – or even zero – vulnerable customers.
“Many companies are trying to distil vulnerability data from credit scores or socioeconomic analyses,” he said.
“For example, some indicators of a consumer using gambling websites may be obtained through open banking data.
“While this may be useful information, it runs the risk of alienating consumers – because the data is obtained through the back door, without their awareness.”
Gething said when considering how to obtain data, the priority should be on its use to reduce harm, not the simplest way to obtain it.
“Since engaging with consumers is an important part of managing vulnerability, making a decision based on inferred or indirectly sourced data has the potential to scare consumers – because these judgments are made behind their back,” he said.
“Just as worrying is the number of firms across the distribution chain still claiming they don’t have any vulnerable customers – this simply isn’t possible, and speaks more to both a lack of engagement and a lack of good-quality assessment data.
“Not only do firms run the same risk of alienating clients, they could also fall foul with the regulator when it enforces consumer duty.”
The firm said in its 20 years experience of assessing vulnerable people, it has always found that it is best to go to the consumer and engage directly with them on their issues.
“This early disclosure is more likely to lead to remediation – or, at the very least, to an adapted engagement process which is better suited to their needs,” Gething added.
MorganAsh said it follows concerns raised by the FCA that many firms were just “repackaging existing data”, as well as its recent survey, which found that many firms were still implausibly reporting few or even zero vulnerable customers.
This is in contradiction to the FCA’s own financial lives survey, which revealed that around half of all UK adults are vulnerable in some way.
Gething explained that for any organisation managing vulnerability, there is a need to have a consistent way to assess, monitor, communicate and evaluate who is vulnerable.
“In addition, firms need to be able to assess both the level and severity of the vulnerability to ensure the appropriate actions can be implemented consistently,” he said.
