Vulnerable Customers

With as many as nearly one in two people in the UK showing characteristics of vulnerability¹, it’s vital you know how to identify vulnerable customers to ensure they’re not disadvantaged in any way. Vulnerability can arise for any number of reasons and vulnerable customers are often at greater risk of poor outcomes when it comes to dealing with their finances. To help you spot customers who are potentially at risk, we’ve put together this section to show you some of the signs to look out for and how we can support them.

The Financial Conduct Authority (FCA) defines a vulnerable customer² as:

“As someone who, due to their personal circumstances, is especially susceptible to harm, particularly when a firm is not acting with appropriate levels of care”

The FCA has issued guidance about how regulated firms can support vulnerable customers which says: "All customers are at risk of becoming vulnerable, but this risk is increased by having characteristics of vulnerability. These could be poor health, such as cognitive impairment; life events, such as new caring responsibilities; low resilience to cope with financial or emotional shocks; and low capability, such as poor literacy or numeracy skills."

There are lots of circumstances and situations that could mean a customer is identified as being vulnerable. While a vulnerability may not affect a customer’s ability to manage their finances, it could impact their understanding of the implications of carrying out certain transactions.

The FCA’s four key drivers of vulnerability include:

As an FCA regulated lender, we’re committed to ensuring vulnerable customers receive consistently fair treatment so they experience outcomes as good as those received by other customers.

Here are just some of ways we can support your vulnerable customers:

• We treat every customer as an individual and will do everything we can to understand and support their needs.

• We promise to remain open and approachable, and to listen and respond to our customers with sensitivity and respect.

• Our colleagues have received specialist training to ensure customers are treated with sensitivity, respect and compassion.

• Our systems and internal processes are flexible to ensure customers’ individual needs are considered in an appropriate and sensitive manner.

• Our policies, products and services are regularly reviewed and updated, to help improve the overall customer experience.

• Our communications will remain clear, accessible and easy to understand.

If you believe a customer may be vulnerable, it’s important you let us know as soon as possible. Don’t be afraid to tell us. Just because a customer has a vulnerability doesn’t mean we’ll automatically turn them down and it certainly won’t have any bearing on our final decision.

Whatever their support needs, our defined and robust approach ensures they’ll be treated fairly, but we can only start putting the necessary measures in place to deliver a satisfactory outcome for everyone involved – your customer, you and us – if you tell us about their specific needs.

You will need to ensure you have either obtained the customer’s consent to share their vulnerability information with us or that you have an alternative lawful basis under data protection law for doing so. When sharing vulnerability information with us, please ensure you have told the customer you will share the information with us and confirm to us the lawful basis you are relying on.

If you’re dealing with a vulnerable customer, or are concerned they may have vulnerabilities, you can contact us in the following ways:

Our customer hub contains key information about what additional support we can offer, as well as links to relevant external organisations, such as charities and advice services. Click here to visit

Please only use email for general enquiries or to request a call back. As email isn't a secure channel, please don't include any sensitive or financial information in any messages you send. The details you provide to us will be used sensitively to help us support you and the customer with managing their account and in line with our Privacy Notices. Our customer privacy notice can be viewed here. Our privacy notice setting out how we use your information can be viewed here. We’ll be happy to answer any questions about how we process personal information when you contact us.

1 - Financial Lives 2022 survey: insights on vulnerability and financial resilience relevant to the rising cost of living

2 - Finalised guidance: FG21/1 Guidance for firms on the fair treatment of vulnerable customers - Online PDF file