VULNERABLE CUSTOMER POLICY – HOME ASSIST 365 LTD
Last Updated: January 2026
OUR COMMITMENT
At Home Assist 365 Ltd, we are committed to treating all our customers fairly and with respect. We recognise that some customers may be in vulnerable circumstances and may need additional support when using our services.
This policy outlines how we identify and support vulnerable customers to ensure they receive the care and assistance they need when dealing with us.
WHO IS A VULNERABLE CUSTOMER?
A vulnerable customer is someone who, due to their personal circumstances, is especially susceptible to harm or disadvantage. Vulnerability can be temporary or permanent and can affect anyone at any time.
Vulnerability may arise from:
- Mental health conditions (such as depression, anxiety, dementia, or cognitive impairment) • Physical disabilities or illness • Learning difficulties • Hearing or visual impairments • Language barriers • Age-related issues (very young or elderly customers) • Recent bereavement or loss • Financial difficulties or debt • Domestic abuse or controlling relationships • Addiction or substance abuse • Literacy or numeracy difficulties • Social isolation or loneliness
UNDERSTANDING MENTAL CAPACITY
A person may be unable to make a specific decision if they cannot:
- Understand information about the decision to be made • Retain that information in their mind • Use or weigh that information as part of the decision-making process • Communicate their decision
We recognise that customers with mental health problems who are in debt are particularly vulnerable due to:
- Lack of money management skills • Reliance on benefit income • Fluctuations in income or inability to work • Unmet housing, care or treatment needs • Poor communication skills • Relationship breakdown
IDENTIFYING VULNERABLE CUSTOMERS
We train all our staff to recognise potential signs of vulnerability during every customer interaction. This assessment begins from the very first contact and continues throughout our relationship with the customer.
THREE KEY QUESTIONS WE ASK
When we believe a customer may be vulnerable, we sensitively ask:
- Does your health or personal circumstances affect your financial situation?
- Does it affect your ability to deal with or communicate with us?
- Does anyone help you to manage your finances, such as a family member or carer?
SIGNS OF VULNERABILITY WE LOOK FOR
During phone calls, meetings, or written communications, our staff are trained to identify the following indicators:
Communication Difficulties: • Does the customer ask us to speak up or speak more slowly? • Do they understand what we are saying, or do they miss important information? • Do they appear confused about what is being offered or discussed? • Do they have a language barrier? • Do they say they don’t understand their bank statements, previous phone conversations, or recent written correspondence?
Cognitive or Memory Issues: • Do they ask unrelated questions? • Do they keep wandering off the point in the discussion and talk about irrelevant things or things that don’t make sense? • Do they keep repeating themselves? • Do they take a long time to answer questions? • Do they say that someone else deals with these things for them?
Understanding and Decision-Making: • Do they struggle to understand the service we are offering? • Do they have difficulty explaining what they need? • Do they seem uncertain or confused about making decisions? • Do they show signs of being overly trusting without asking appropriate questions?
HOW WE SUPPORT VULNERABLE CUSTOMERS
When we identify or suspect that a customer may be vulnerable, we take the following steps:
Clear Communication: • We speak slowly, clearly, and explain everything fully • We use plain language and avoid technical jargon • We are patient and empathise where appropriate • We do not rush the customer, as it may take time for them to gather relevant information such as account details or understand what we are explaining • We keep focused on the subject under discussion • We clarify understanding at every point and always ask if there is anything else they would like us to explain • We ask the customer to explain back to us what they understand the agreement or arrangement to be
Flexible Communication Methods: • We offer alternative types of communication – phone, post, email, or in person • We do not make assumptions that the person we are dealing with can read, as they may have visual impairments or literacy difficulties • We do not assume the customer can hear everything we say, as they may have a hearing impairment • We adjust our communication style to meet their individual needs
Respectful Approach: • We do not make assumptions about a customer’s needs or capabilities • We give the customer time to explain their circumstances fully and don’t interrupt or appear impatient • We listen carefully for what is NOT being said, such as lack of questions about price, lack of commitment, timing of responses, or extended silences • We understand that some customers may be lonely and welcome the opportunity to talk to someone • We remember that some customers may be forgetful or overly trusting and believe that a sales representative is always acting in their best interest
Timing and Support: • We always ask if there is a better time to discuss matters, as some customers may perform better at different times of the day • We ask if there is anyone else the customer may need to talk to before making a decision (such as a family member, carer, or advisor) • We encourage them to seek independent advice if appropriate • We offer to re-contact them at a more suitable time
BEFORE FORMING A CONTRACT OR AGREEMENT
Before we proceed with any service or financial agreement, we ensure that:
- The customer demonstrates that they have an understanding of the decision they need to make • They understand why they need to make the decision • They understand the consequences of making, or not making, that decision • We ask if they need to discuss the matter with anyone else • We ask if they would like us to explain anything else or if there is anything more we can do to help • We are prepared to repeat anything to clarify understanding • We do not assume that the customer fully understands all the implications of the agreement • We explicitly and clearly confirm all the key features of the service, including costs, timeframes, and what work will be carried out • We suggest that they talk it through with someone else and offer to re-contact them • If appropriate, we suggest that a third person (such as a family member or carer) could be present during discussions
If at any point we are not confident that the customer fully understands the decision they are making, we will not proceed until we are satisfied they have the support they need.
AFTER THE CONTRACT IS AGREED
Once we have agreed to provide a service:
Recording Communication Needs: • If we identify particular communication needs, we store that information (with the customer’s permission) so that future contacts are handled appropriately • We record that we are satisfied the customer completely understood everything that was discussed • We allow customers to make a personal declaration about their capabilities or communication needs and store this information securely with their permission
Data Protection: • Any records that are held are with the full knowledge and consent of the customer • All data is stored securely in accordance with UK GDPR • Records are deleted when the relationship no longer exists or when the customer requests removal, in accordance with data protection regulations
Ongoing Support: • We continue to monitor for signs of vulnerability during all future interactions • We adapt our service and communication as needed • We check in with the customer to ensure they are satisfied and understand any ongoing obligations (such as payment plans or service agreements)
REFERRING TO SPECIALIST ORGANISATIONS
If we identify a customer who may be in need of specialist advice or support which we are unable to offer, we will refer them to, or seek guidance from, appropriate organisations such as:
For Debt and Financial Advice: • StepChange Debt Charity: 0800 138 1111 or www.stepchange.org • Money Advice Trust / National Debtline: 0808 808 4000 or www.moneyadvicetrust.org • Citizens Advice Bureau: 0808 223 1133 or www.citizensadvice.org.uk
For Mental Health Support: • Samaritans: 116 123 (24/7) or www.samaritans.org • Mind: 0300 123 3393 or www.mind.org.uk
For Elderly or Dementia Support: • Age UK: 0800 678 1602 or www.ageuk.org.uk • Alzheimer’s Society: 0333 150 3456 or www.alzheimers.org.uk
For General Advice: • Citizens Advice: 0808 223 1133 or www.citizensadvice.org.uk • Consumer helpline: 0808 223 1133
We will always respect the customer’s wishes and will not refer them without their consent unless we believe there is a safeguarding concern.
SAFEGUARDING CONCERNS
If we identify a serious safeguarding concern (such as suspected abuse, neglect, or exploitation), we will:
- Take the matter seriously and act promptly • Report our concerns to the appropriate local authority safeguarding team • Follow guidance from the Care Act 2014 and local safeguarding procedures • Keep a record of the concern and actions taken
STAFF TRAINING
All Home Assist 365 Ltd staff receive training on:
- Identifying signs of vulnerability • Communicating effectively with vulnerable customers • Understanding mental capacity and decision-making • Data protection and confidentiality • When and how to refer customers to specialist organisations • Treating all customers with dignity and respect
Training is refreshed annually and is part of our ongoing commitment to treating customers fairly.
LEGAL AND REGULATORY GUIDANCE
This policy is based on guidance from:
- Equality Act 2010 • Mental Capacity Act 2005 • Care Act 2014 • UK General Data Protection Regulation (UK GDPR) • Consumer Credit Sourcebook (CONC) 2.10 – Contact with customers • Financial Conduct Authority (FCA) guidance on treating vulnerable customers fairly • Mental Capacity Guidance • Money Advice Liaison Group (MALG) – Consumers with mental health problems and debt • MALG – 12 steps to treating vulnerable consumers fairly
FINANCIAL SERVICES AND VULNERABLE CUSTOMERS
Home Assist 365 Ltd (FRN: 971539) are an appointed representative of Koze Group Ltd, a credit broker not a lender. Koze Group Ltd are authorised and regulated by the Financial Conduct Authority (FRN 811281).
When offering finance options, we take extra care to ensure vulnerable customers:
- Fully understand the financial commitment they are making • Are not being pressured into agreements they cannot afford • Have access to independent financial advice if needed • Are aware of alternative payment options
We will not proceed with a finance agreement if we believe the customer does not have the mental capacity to understand the commitment or if we believe it would cause them harm.
MONITORING AND REVIEW
We regularly review our approach to vulnerable customers by:
- Monitoring customer feedback and complaints • Reviewing records of vulnerable customer interactions • Identifying areas for improvement • Updating our training and procedures • Ensuring compliance with current regulations and best practice
This policy is reviewed annually to ensure it remains effective and compliant.
CONTACT US
If you believe you may need additional support, or if you are concerned about a vulnerable person using our services, please contact us:
Home Assist 365 Ltd Henleaze Business Centre Harbury Road Bristol BS9 4PN
Phone: 0117 9474040 Email: helpdesk@homeassist365.co.uk
All information will be treated confidentially and with respect.
POLICY REVIEW
Last reviewed: January 2026 Next review due: January 2027
We are committed to supporting all our customers and ensuring everyone is treated fairly and with dignity.
Thank you for choosing Home Assist 365 Ltd.