Identifying vulnerability

May is Mental Health Awareness Month, and during these unprecedented times we have all had to adjust to how we live, work and socialise.

The likelihood that more people will be vulnerable due to these changes needs to be taken into consideration along with the financial impact of furlough, job losses and the overall economic downturn resulting from the Covid-19 pandemic.

The Financial Conduct Authority defines a ‘vulnerable consumer’ 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”.

Vulnerability is both transient and can sometimes be difficult to pinpoint or identify, which means that any company who might interact with vulnerable debtors needs to have appropriate training to help identify and communicate effectively and empathetically with anyone who is vulnerable.

Vulnerability can include:

  • A recent bereavement
  • Mental health problems
  • Long-term or terminal illness
  • Dementia or brain injury
  • Difficulty in communicating, for example reading or speaking on the phone
  • Not having English as a first language
  • Hearing or sight problems
  • A learning disability
  • Relationship breakdown
  • Addiction

This list is by no means exhaustive and vulnerability should be looked at on an individual and case-by-case basis.

National Standards and vulnerability

The National Standards that enforcement agents work to state that:

Enforcement agents must withdraw from domestic premises if the only person present is, or appears to be, under the age of 16 or is deemed to be vulnerable by the enforcement agent.

Enforcement agents must withdraw without making enquiries if the only persons present are children who appear to be under the age of 12.

A debtor may be considered vulnerable if, for reasons of age, health or disability they are unable to safeguard their personal welfare or the personal welfare of other members of the household.

The enforcement agent must be sure that the debtor or the person to whom they are entering into a controlled goods agreement understands the agreement and the consequences if the agreement is not complied with.

Training to identify vulnerability

Any employees working with debtors will need to be fully trained, and we believe that this must include those working within call centres.

“Secret shopper” style activities can ensure that all policies and procedures are being adhered to and that there is a consistent approach to how vulnerable debtors are communicated with. These types of activities can also help identify training needs for teams and individuals.

Soft skills such as listening and problem solving as well as being able to communicate clearly and effectively with different age groups and demographics are incredibly important.

The qualifications and workshops delivered by Excel cover all aspects of vulnerability identification and how to signpost, respond and communicate with vulnerable debtors. Our teams have all undergone this valuable training.

Listening skills

Everyone will need to have training on their listening skills; is a debtor frightened, scared or anxious? Is a debtor angry or are they expressing views or thoughts that are worrying or concerning? Do they react disproportionately to the situation they are in?

Both front line and back office operatives should be aware of the triggers and signs of vulnerability, both audible and physical.

People skills

Enforcement agents who are facing debtors daily will need to understand how to deal with situations that are challenging. These challenges include dealing with vulnerable debtors, dealing with threatening or violent behaviour and managing confrontation.

Useful Links

Vulnerability eBook

Vulnerability webinar

Training prospectus

Coronavirus information for debtors

Please visit this page for more information about what to do if you have received a notice of enforcement or are currently in a payment arrangement.


Excel Quick Pay - the new debtor app

The app is free to download and free to use. It has been designed to give debtors a quick, easy and user-friendly way to manage their debt.