Asking consumers about their characteristics of vulnerability may be new to you, just as it may be a new thing for the consumer to provide them. However, this is not as onerous as it may seem and, once positioned well, most people are happy to provide this information.
Most people are happy to disclose characteristics of vulnerability
MorganAsh has been assessing vulnerable people for over twenty years and, while some people may not want to disclose such information, this is, in fact, quite rare. Indeed, most people are happier talking about their personal circumstances than they are (for example) their finances, which is something they are often required to disclose.
Talking about consumer vulnerability will become more common
It’s relatively a new thing for people to be assessed for vulnerability characteristics. So, this may need to be explained to them. Legislation such as Consumer Duty requires firms to do this: and it is for the protection of the consumer. Likewise, there are consumer vulnerability protections in, for example, the utilities sector.
Firms need to comply with legislation such as Consumer Duty and, since there is no other reliable method, the best way to get the information is to ask the consumer. At first glance, many firms perceive that asking personal questions may be too invasive therefore shy away from doing this. However, these fears are generally unfounded – usually born from the unfamiliarity of doing this. MorganAsh has been talking to consumers about their vulnerabilities for over twenty years – so it’s something we do with confidence.
Assessment response rates
Firms using MARS, the MorganAsh Resilience System, routinely report good response rates. How a firm positions the assessment and uses MARS is up to the firm – MARS is very flexible. Some firms have mandated that consumers complete vulnerability assessments and send these along with their terms and conditions when doing business – and have 100% response rates, with no customer rejections. Others ask all of their customers to undertake an assessment but don’t make doing so a prerequisite for doing business – but they still have great success. One of our customers, a financial adviser, reported: “I got a fast response from about 80% of people, which tells me that the system is quick, reliable and easy to use. In the end, around 90% of the assessments were completed online and the rest I went through personally, with the client, using the MARS questionnaire.” The final tally was close to 100%. A loan company sends out MARS assessments to all those applying online and gets 70% response rates straight away, without talking to the consumers. Overall, the notion of low response rates or reluctance to complete an assessment is far more fear than reality.
Indeed, there is a level at which using an independent assessment tool helps. Not only is it more efficient and objective, it takes out of the equation the person with whom the consumer may have a relationship. It’s neutral.
Tailor assessments to your firm’s needs
Within MARS, we provide the options to embed the secure link to the assessment within one’s own emails, send an email automatically, or for the agent/adviser to complete the assessment themselves – either over the phone or face to face. These options allow users to adopt the method which best suits both the firm and the individual. As mentioned, we don’t dictate how MARS is used – firms know best, but we can advise.
We also provide a range of options to specify the depth of questions being asked. This helps firms align assessments with different products – for example, more detailed assessments for higher risk products and less detailed assessments for lower risk products.
Reporting on protected characteristics, as defined by the Equality Act
The Financial Conduct Authority (FCA) also requires firms to report on protected characteristics – as defined by the Equality Act. These protected characteristics include more sensitive topics, such as religion or belief, gender reassignment, race, and sexual orientation – which some consider too personal. We therefore offer the option for consumers to skip these questions by choosing ‘prefer not to say’ and, within MARS, we also offer the option to include or exclude these questions. Companies can configure whether to ask these questions on a company basis or if it is decided for each individual consumer.
If companies don’t collect this information as part of their vulnerability assessments, they will still need to assess protected characteristics using another method. The FCA does not require the information on every person, but firms do need to report on compliance with the Equalities Act. Giving the ‘prefer not to say’ option enables each consumer or firm to decide, rather than using a generalised or mandated approach.
Privacy and protected characteristics
To address privacy concerns, MARS does not report on protected characteristics for each consumer – they are only reported on at a firm level, using anonymised data. The FCA does not want firms to pressure consumers to provide information on protected characteristics – requesting it to be given voluntarily meets this requirement, while enabling firms to report on these cohorts of consumers.
Control or flexibility
With a primary aim to meet regulations and provide evidence of doing so, there is a need to ensure appropriate processes are undertaken. On the other hand, there is also a need to be flexible – to cater for differing consumers and circumstances, and to amend assessments when circumstances change. To meet these two demands, MARS allows great flexibility and keeps a record of every change. This audit trail not only provides a record of a consumer’s changing vulnerabilities but is also always available for inspection should inappropriate changes be made. Therefore, it meets both needs previously outlined.
Improving engagement
Like any consumer engagement, success depends on the consumer’s understanding. The more the consumer understands, the more likely they are to complete the assessment. MARS includes configuration settings to help achieve this.
MorganAsh can add company logos and configure settings within MARS to tailor communications for each firm, so they are more familiar to consumers.
Other ways to help
How you communicate the need for the assessment will have a great deal of bearing on consumers’ perception of it. Since there is nothing onerous about the assessment, and we know that the majority of consumers are fine with the questions, it’s something to be positive about. “The more we know about you, the more relevant our products and services can be, and, in some cases, we may change the way we work – to better suit your needs. It will also help make sure that we don’t provide anything which exposes you to harm. Helping us will help us to help you.”
Most companies position MorganAsh as a trusted independent partner – and this works well. We’re an independent third party and we have been assessing consumers for over twenty years – and indeed, has won awards for our work. We use secure data systems, which are regularly and rigorously tested, with ISO 27001 and Cyber Essentials Plus certification – as well as FCA authorisation to undertake this work. We work with many of the UK’s leading insurance and finance companies.