Vulnerable customer policy

The four drivers of vulnerability

The FCA groups the drivers of vulnerability under four headings. They overlap - a customer may be affected by more than one driver at the same time.

Health

Physical disabilities, severe or long-term illnesses, hearing or visual impairments, mental-health conditions such as depression or anxiety, addiction and cognitive impairments such as memory loss or learning disabilities. Recent injury - including injuries sustained in the accident the customer is contacting us about - is a relevant health factor.

Life events

Bereavement, relationship breakdown, loss of housing, becoming a carer, the arrival of a child, redundancy, retirement, leaving the armed forces or serving a prison sentence. The accident itself can be a life event, especially where it has caused injury, property loss or financial pressure.

Resilience (financial)

Low ability to withstand a financial shock. Examples include people on a low or volatile income, those carrying unmanageable debt, those without savings, or those facing unexpected costs (such as taxi fares while a damaged vehicle is off the road) that they cannot easily absorb.

Capability

Low knowledge or confidence in dealing with financial services, low literacy or numeracy, low digital skills, English as a second language, and a lack of experience of how insurance or legal processes work. Capability is situational - a senior engineer can still be a "capability-vulnerable" customer in a claims-management context where the vocabulary is entirely new.

Why accident-support customers may be vulnerable

People come to a UK accident claim management because they have just been involved in a road traffic accident. The context is therefore inherently more stressful than most consumer services. We see four recurring patterns:

• Recent trauma. The accident itself can be a traumatic event, especially where injury, the death of a passenger or a near-miss is involved. Customers may be calling us within hours of the incident.
• Possible injury. Where the customer was hurt, fatigue, medication and pain can affect concentration. We adjust the pace and length of calls and offer to follow up in writing.
• Financial pressure. Loss of transport can mean lost earnings, taxi costs and missed appointments. Even where credit hire is available, the period between accident and hire can be tight.
• Unfamiliar vocabulary. Insurance and legal language is unusual, even for technically capable customers. Terms such as "credit hire", "subrogation" or "Part 36 offer" need translating and we treat pointing this out as a sign that the explanation is wrong, not the customer.

How we identify vulnerability

We identify vulnerability through a combination of staff training, listening cues, the accident-evidence form, and customer self-disclosure. None of these routes is "ranked above" the others - what the customer tells us is the most reliable signal, but we do not require disclosure before we offer support.

• Staff training. Every front-line handler completes a training module covering the four drivers, the cues that suggest a customer may be in vulnerable circumstances, and the adjustments available. Training is refreshed annually.
• Call-handler indicators. Signs we listen for include the customer asking for things to be repeated, sounding distressed, mentioning medication, expressing financial worry, or struggling with the chronology of events. These are signals to slow the call, not to take over.
• Form prompt. Our accident-evidence form includes an optional free-text field where you can tell us about any support you need. Answering it is voluntary.
• Customer self-disclosure. You can tell us at any time, by any channel, that you would prefer a different communication style, a trusted contact, or a slower pace. We will record it on your file and apply it from that point.

Adjustments we offer

Adjustments are intended to reduce or remove the disadvantage someone might face when using our service. The list below is not exhaustive - if something else would help, please ask.

• Extended time. Longer call slots, longer windows to read documents, longer cooling-off conversations before any commitment is made.
• Alternative channels. Email, letter or text instead of phone where the phone is difficult. We can also use large-print or plain-language summaries.
• Simplified language. Plain-English explanations of insurance and legal terms, written summaries after calls, and step-by-step lists of what happens next.
• Trusted-contact authority. A nominated friend, family member or advocate can deal with us on your behalf with your written consent. A registered Lasting Power of Attorney is accepted without needing separate consent.
• Slower process pacing. Holding off on the next step until you are ready, with no pressure on time-sensitive choices unless an external deadline (such as a limitation date) genuinely requires it. Where there is an external deadline we explain why.
• Pausing communications. If you need a break - for example while you are in hospital - we can pause routine updates and resume on a date you tell us.
• Quiet contact times. If certain times of day are difficult, we will call only within the windows you give us.

Consent and data

Information about vulnerability - particularly anything that touches on your health or mental health - is "special category data" under Article 9 of the UK GDPR. We process it only on a lawful basis, which is normally your explicit consent (Article 9(2)(a)) and, in some cases, for the establishment, exercise or defence of legal claims (Article 9(2)(f)) where the vulnerability bears directly on the claim.

We record only what is needed to provide the support you have asked for. Access is restricted to the colleagues who need it. Vulnerability records are retained for as long as the file is open and for any subsequent retention period required for regulatory or legal reasons, then deleted. You can ask us to update, restrict or delete the record at any time - see your data rights in our privacy policy.

Telling us

You can tell us in whichever way is easiest:

• By phone: 0330 043 3409.
• By email: support@citygripclaims.co.uk.
• Through the accident-evidence form: the free-text field at the end of the form is the right place to mention anything you would like us to know.
• By post: 124 City Road, London, EC1V 2NX.

After you tell us, we will: confirm what you have asked for, record it on your file with appropriate access controls, apply the adjustments straight away, and check in periodically to see whether your needs have changed.

Independent help

The organisations below offer free, independent support. We are not affiliated with them and we do not see what you discuss with them.

• Citizens Advice - general practical advice on consumer, housing, employment and benefits issues: citizensadvice.org.uk.
• Mind - information and support for people experiencing a mental-health problem: mind.org.uk.
• StepChange - free, impartial debt advice: stepchange.org.
• Samaritans - emotional support, including if you are in crisis. Call 116 123 (free, 24/7) or visit samaritans.org.

Complaints

If you feel our service has fallen short - including the way an adjustment was handled or refused - please tell us. The full process is in our complaints policy. Raising a complaint will not prejudice your claim, and the complaints team is trained to apply the same vulnerability adjustments to the complaints process itself.