This page details everything you need to know around helping clients with support needs and those who could be classified as vulnerable. This includes the definition of vulnerability, details of specific support needs, how you can help, and how we use your client’s information.
Vulnerable client guidance
What is vulnerability?
The FCA (Financial Conduct Authority) define a vulnerable client as someone who:
“Due to their personal circumstances is especially susceptible to detriment, particularly when a firm is not acting with appropriate levels of care”
It’s essential we consider vulnerable client needs to ensure they benefit from the services we offer, failure to do so could result in a poor experience for these clients.
Vulnerability can take many forms, but key drivers are set out below:
| Health | Life event |
|---|---|
|
Physical disability Severe or long term illness Hearing or visual impairment Mental health condition or disability Addiction Low mental capacity or |
Retirement Bereavement Income shock Relationship breakdown Domestic abuse Caring responsibilities Other circumstances that affect people’s |
| Resilience | Capability |
|
Inadequate or erratic income Over indebtedness Low savings Low emotional resilience Lack of support structure |
Low knowledge or confidence in managing Poor literacy or numeracy skills Poor English language skills Poor or non existent digital skills Learning impairments No or low access to help or support |
What is a support need?
We have built a range of tools to support clients who have specific needs. A support need is something that a client has asked us to do to make sure they can access our products and services without barriers. This includes adjustments to our communication style and approach to following a certain process, for example, an alternative mail format.
The full range of needs are detailed below.
Support needs and Interacting with us
Interacting with us
| Support need | What is it? |
|---|---|
| Speak slowly and clearly, pausing between sentences |
What is it? This support need provides instructions to colleagues that this client highlighted they may need to take the conversation at a slower pace, they may need adjustments to your tone of voice to support their understanding. When should this be offered? This support need could be offered to clients if you identify in your interactions that they would benefit from a more patient, leisurely paced appointment or call. It’s an appropriate support need to consider if the client has shown you that they struggle to retain information during previous interactions. |
| Help me with my understanding of numbers and information |
What is it? This support need tells colleagues that the client has highlighted they need some additional support understanding information and how this impacts the financial decisions they may make. When should this be offered? This support need should be offered to clients if you identify that the client would benefit from a more supported, leisurely paced appointment or call that breaks down complex information into accessible chunks. |
| I need longer appointments |
What is it? This support need tells colleagues that the client has highlighted they need adjustments to the usual timeframes that a task can be completed in. When should this be offered? This support need should be offered to clients if you identify that the client would benefit from a more patient, leisurely paced appointment or call. |
| Give me more time to respond or complete tasks | What is it? This support need tells colleagues that the client has highlighted they may need to take the conversation at a slower pace, they may need adjustments to the usual timeframes that a task can be completed in. When should this be offered? This support need should be offered to clients if you identify that the client would benefit from a more patient, leisurely paced appointment or call. The client has told us or we identify that we may need to make adjustments to timescales for completing tasks. |
| Keep calls and appointments to a minimum | What is it? This support need tells colleagues that the client has highlighted that they need interactions such as telephone calls and appointments to be limited and only utilised when essential. When should this be offered? This support need should be offered to clients if you identify that the client struggles with interacting with The Mortgage Works without feeling overwhelmed. |
| Please only contact me AM/PM | What is it? This support need provide instructions to colleagues that the client has highlighted a preference on when we contact them. When should this be offered? This support need should be offered to clients if you identify that the client has a specific time preference/need that The Mortgage Works should where possible honour. |
| Check purpose of transactions to support my decision making | What is it? This support need highlights to colleagues that this client needs some additional support in making informed decisions When should this be offered? This support should be offered to client if you identify that the client would benefit from a more patient, leisurely paced appointment/call that breaks down decisions into more accessible chunks-ensuring all options are reviewed. It will help consultants avoid making assumptions that the client is aware and can weigh up risks without discussing those during our interactions. |
| Ask me to summarise information to check my understanding | What is it? This support need highlights to colleagues that this client needs some additional support, steps and time taken to ensure that that they fully understand the content of your interactions When should this be offered? This support need should be offered to clients if you identify that the client would benefit from a more patient, leisurely paced appointment/call, that breaks down the conversation into more accessible chunks. Aiming to ensure all options are reviewed and that we reflect back to the client to check they understand. It will help consultants avoid making assumptions that the client has understood and tells them to make a conscious effort to confirm understanding. |
| Be aware I find social interactions difficult | What is it? This support need highlights to colleagues that the client has highlighted that they find social interactions such as talking to their financial provider challenging. When should this be offered? This support need should be offered to your clients if you identify that the client struggles with interacting with us and needs us to be aware and understanding. We may need to make reasonable adjustments as to how we interact with them. |
| Help me with my memory, I may forget information | What is it? This support need tells colleagues that the client has highlighted that they have issues with their memory that may impact the interactions they have with The Mortgage Works. When should this be offered? This support need should be offered to clients if you identify in your interactions that the client would benefit from a more supported, leisurely paced appointment or call that breaks down complex information into accessible chunks. |
| I may use an interpreter: BSL/Foreign language | What is it? This support need tells colleagues that the client colleagues that this client may bring with them a British Sign Language/Foreign Language Interpreter to support them in their interactions. When should this be offered? This support need should be offered to clients if you identify that the client uses BSL or a foreign language and may on occasion have a third party attend appointments with them to translate. |
| Someone may assist me to provide support | What is it? This support need provide instructions to colleagues that this client may bring with them a supporting party to help them in their interactions. This could be ranging from a friend/family member, support worker to an external advocate. When should this be offered? This support need should be offered to clients if you identify that the client struggles to interact with The Mortgage Works without someone there to help them. |
| When talking to me please speak louder | What is it? This support need provides instructions to colleagues that when they are talking to the client, they need to speak louder to enable the client to hear them properly. When should this be offered? This support need should be offered to clients if you identify or are told in your interactions that the client finds it hard to hear agents. This is making it difficult for the client to interact with us without frustration or potential detriment to the client. |
| My voice may sound different to what you expect | What is it? This support need provides context to colleagues that the client has told us that their voice may be different to what we would anticipate they sound like. It asks us to be sensitive to this and consider this in our interactions. When should this be offered? This support need should be offered to clients if you identify or are told in your interactions that the client has faced barriers when dealing with providers relating to their voice not aligning with agents' expectations. Clients who have differences in their voices can often find engaging in channels such as telephony challenging- having a support need on a client's profile allows agents to have some context behind why their voice may sound different to what is anticipated |
| My speech may be affected so give me time to answer |
What is it? This support need provides context to colleagues that the client has told us that their speech may cause them to have delays in answering our questions and they therefore need us to be patient and allow them additional time to articulate what they want to say. When should this be offered? This support need should be offered to clients if you identify or are told in your interactions that the client has challenges with their speech that often include struggling to get the words they want to say out. |
| Sometimes my behaviour or mood can change quickly | What is it? This support need provides context to colleague, that the client has disclosed that occasionally how they appear when they interact with us may change. When should this be offered? This support need should be offered to clients if you identify or are told in your interactions with the client that their behaviour can change quickly. Having this support need provides context to this behaviour and allows us to better prepare for when this happens. |
| I struggle with literacy | What is it? This support need provides context to colleague, that the client has disclosed that they struggle to read and write and therefore require us to make reasonable adjustments to support them. When should this be offered? This support need should be offered to clients if you identify or are told in your interactions with the client struggles with their ability to read and/or write and as a result of this would benefit from The Mortgage Works making reasonable adjustments to support them. |
How we need to communicate
| Support need | What is it? | When should this be offered? |
|---|---|---|
| Please follow up in writing | This support need tells colleagues that the client has told us they need a summary of information provided to them during interactions sent to them via letter or email in line with their preference. | This support need should be offered to clients if you identify that the client would benefit from a summarised version of your interaction in order to support their ongoing management of their finances. |
| I need to use Video Relay Service to communicate | Video Relay Service is a service that allows clients to communicate with The Mortgage Works via British Sign Language. The way it works is the client has a secure video link with the assistant from VRS- they then sign to the assistant who translates this into words over the phone to the The Mortgage Works consultant. | This support need should be offered to clients if you identify that they have a hearing impairment and rely on BSL as a method of communication. |
| I need to use Text Relay to communicate | Relay UK (formally Text Relay) is a service provided for clients who struggle to hear over the telephone. It is a mediated translation service that connects clients via a confidential service, to an assistant who the client ‘texts’. The assistant then ‘relays’ that information to us over the telephone. It essentially introduces a middle person to the conversation. This support need advises colleagues to use this process and not to be alarmed when a party that isn’t the client is providing the information to us. | This support need should be offered to clients if you identify that they use the Relay UK facility. Or if you are aware that they have a hearing impairment and believe they may benefit from the service then it is worth having a conversation with the client about this option. Please note- Relay UK is an external organisation-it is not run by The Mortgage Works. Visit the Relay UK website |
| I use text-to-speech software to communicate | This support need informs colleagues that the client uses assistive technology. This may range from screen readers, voice activation, keyboard commands and many more. Essentially it is acknowledging that the client needs an aid to use the standard channels available. | This support need should be offered to clients if you identify that they use a form of assistive technology that supports text to speech communication. |
| Branch is my only accessible channel | This support need highlights to colleagues that this client has told us that branch is the only way that they can engage with us. | This support need should be offered to clients if you identify that the client struggles engaging with The Mortgage Works over the telephone or via other channels such as online. We will accommodate this support need as much as possible. |
| Telephone is my only accessible channel | This support need highlights to colleagues that this client has told us that telephone is the only viable method for them to be able to interact with The Mortgage Works effectively. | This support need should be offered to clients if you identify that they cannot use other mediums such as branch or online channels to communicate. We will accommodate this support need as much as possible. |
| Online is my only accessible channel | This support need highlights to colleagues that this client has told us that online is the only viable method for them to be able to engage with The Mortgage Works. | This support need should be offered to clients if you identify that the struggles engaging with The Mortgage Works over the telephone or via other channels such as branch. |
| I cannot attend meetings in person | This support need highlights to colleagues that this client has told us that attending an in person, face to face meeting/interaction is not an accessible to them. | This support need should be offered to clients if you identify that they struggle engaging with The Mortgage Works in person. |
| I can’t use digital channels | This support need highlights to colleagues that this client has told us that digital channels such as internet banking, mobile app and the internet are not viable options for them to interact with The Mortgage Works and manage their account. | This support need should be offered to clients if you identify or are told in your interactions that they cannot use digital channels as a way of servicing their accounts.. It is important to remember that this is not intended for clients who can access digital channels but have a preference to not- its intended usage is for when a vulnerability prevents clients from being able to access digital channels. |
Writing to us
| Support need | What is it? | When should this be offered? |
|---|---|---|
| I can only communicate in writing | This support need provides instructions to colleagues that this client has told us that the way they can communicate with The Mortgage Works effectively is in writing. | This support need to be offered if you identify that they struggle engaging with The Mortgage Works verbally/in person and they would prefer to be contacted in writing. |
| Send me communications in Audio | This support need provides instructions to colleagues that if they are sending correspondence to the client, this needs to be done via audio not in writing. This preference means that the client will receive a CD for them to play that has been dictated. | This support need should be offered to clients if you identify that the client finds written format inaccessible and would benefit from an alternative approach. |
| Send me communications in Braille | This support need provides instructions to colleagues that if they are sending correspondence to the client, this needs to be sent via braille not standard print. Braille is a written language for blind people, it uses a series of raised dots that correspond to different letters and words. | This support need should be offered to clients if you identify that the client finds written format inaccessible and specifically uses Braille as a method of communication. |
| Send me communications in Large Print | This support need notifies colleagues that if they are sending correspondence to the client this needs to be sent in an accessible font size as directed. | This support need should be offered to clients if you identify that the client finds their current written format inaccessible and specifically needs a larger font to be able to access written content. |
| Send me communications in bold print | This support need notifies colleagues that if they are sending correspondence to the client, this needs to be sent in a bold font as directed. | This support should be offered to clients if you identify that the client finds their current written format inaccessible. By talking to the client and understanding if a Bold font would help them, we can make correspondence more accessible. |
Meeting us in person
| Support need | What is it? | When should this be offered? |
|---|---|---|
| Please arrange a BSL interpreter for appointments (A BSL interpreter and a manual deaf blind interpreter cannot be supplied at the same time) |
BSL stands for British Sign Language. It is a method of communication for people who are severely hearing impaired. The Mortgage Works can provide an in-person interpreter for clients who have this as a communication need. | This support need should be offered to clients if they have a hearing impairment and rely on BSL to communicate. If they would prefer to use their own, consider applying the ‘I may use an interpreter: BSL’ alert. |
| Please turn the radio off | This support need highlights to colleagues that this client needs a quieter calmer environment including turning off the branch radio and overall minimising background noise as much as possible. | This support need should be offered to clients if you identify that they struggle with loud environments or background noise. |
| I need to use a hearing loop | A hearing loop is a type of sound system specifically to support people with hearing aids. Its aim is to minimise background noise and allow a client to be supported in their interaction with a consultant. | This support need should be offered to clients if you identify that they struggle with loud environments or background noise and need to use a hearing loop. |
| Please arrange a manual Deaf Blind interpreter for appointments | Being Deaf Blind means that you have both a severe visual and auditory impairment. The Mortgage Works can provide an interpreter for clients who have this as a communication need. | This alert should be offered to clients if you identify that they are deaf-blind. If you notice they have brought a supporting party to interpret for them, consider asking if they are likely to provide their own interpreter often or if they want NBS to arrange an interpreter for them in their appointments. |
| I need to use the aids/tools held in branch | This support need highlights to colleagues that this client may need to utilise some of the accessibility equipment that is available the Helping Hand unit within branches. There could be a variety of reasons for this including but not limited to; a possible sight impairment, dexterity issues, age related preference. | This support need should be offered to clients if you identify that they struggle with things such as filling out documentation, seeing text clearly. |
| I lip read, face me when speaking | Lip reading is when someone interprets the movements of your mouth into words. The support need highlights to colleagues the importance of facial communication when supporting the client in their interaction. This is normally due to a hearing impairment. | This support need should be offered to clients if you identify that they have a hearing impairment and rely on lip reading as a method to make the interaction more accessible. |
| I prefer to meet in a quiet space if available | This support need provides instruction to front line that the client would benefit from a quieter and calmer environment to get the most out of the interaction. | This support need should be offered to clients if you identify that they are struggling to hear you or cope with a loud environment. Or perhaps are finding the background noise distracting or overwhelming. We may not always be able to offer an alternative location but consider the things that we can offer such as turning off the radio or perhaps choosing a counter off to the side to support where possible. |
| I prefer to meet in a public space if available | This support need provides instruction to front line that the client would rather have their appointments in a public forum rather than an office or private space. | This support need should be offered to clients if you identify that they do not like enclosed appointments and find these interactions difficult or stressful. We may not always be able to offer an alternative location but consider the things that we can offer such keeping the door open in any appointments. Offering additional people to be present. |
| I use an assistance dog | This support need provides instructions to branch that the client has told us that they use an assistance dog to help them and therefore require the dog to be allowed in the branch to support them | This support need should be offered to clients if they tell us that they use an assistance dog and require The Mortgage Works to allow the dog in their premises to support them. |
| Please do not draw attention to my body movements | This support need provides instructions to colleagues that this client has told us that they may have involuntary body movements. They do not want us to reference these in our conversations (unless directly relevant) and would like us to proceed with our interactions making reasonable adjustments to support them. | This support need should be offered to clients if they tell us, or you identify in your interaction that’s they have involuntary body movements and would prefer not to have to discuss or re-explain this with Nationwide Group directly. |
| Arrange meetings in accessible areas due to mobility issues | This support need provides instructions to colleagues that when we are arranging in person interactions, we must consider that they have mobility needs and choose an appropriate location to meet those needs. | This support need should be offered to clients if they tell us, or you identify in your interaction that’s they have mobility challenges that mean The Mortgage Works need to make adaptations as to where and how we service their needs. |
How can you help?
Identifying a client who may need additional support is the first step towards providing the right help. Here are some useful tools to help identify if your client may have support needs and how to communicate with your clients about their additional needs.
Vulnerability Toolkits
How do I identify if recording support needs will help in the future?
Here are some things to consider when assessing whether or not recording your client’s support needs will be the best outcome for them:
- How do the client’s circumstances affect their ability to manage their money?
- Do you think the type of help and support they need is a one off request / short term or is it likely to last longer?
- Are there any barriers that we could remove to make it easier for the client now?
- Will a support needs alert ensure a better or more consistent experience for the client?
Telling us about your client’s support needs
You can tell us about a client’s support need by filling out the following form.
Before you notify us of a client support need, please ensure you have asked your client for permission and have their consent to record and share their support needs with us. You also need to ensure they understand how we will use their information.