Whether it is a permanent condition such as dementia or the short-term pain of a broken leg, at any one time a large percentage of a brand’s customers could be in a vulnerable state. If marketers fail to speak to these individuals in the most appropriate way, they could risk alienating consumers when they are in most need of help.
The Direct Marketing Association (DMA) responded to this issue in May with the launch of its Responsible Marketing Commission. It oversees the Vulnerable Consumer Taskforce, which aims to raise awareness across the vulnerability spectrum from debt and redundancy to mental illness.
The DMA’s head of preference services, compliance and legal John Mitchison advises brands, retailers and suppliers to take vulnerability seriously and begin recording details in a customer relationship management (CRM) database as soon as they sense someone could be vulnerable.
“You use this information to decide how to market to that person in the future. If a vulnerable consumer has phoned but is becoming confused, you can offer to send them information in written form, invite them into store or perhaps make a house visit. None of this is intended to label people or make decisions on their behalf,” adds Mitchison.
Vulnerability is firmly on the political radar. On 18 May, the Government announced that as part of its Digital Economy Bill companies will need to obtain consent for direct marketing in order to protect consumers from nuisance calls and spam email.
Nuisance calls are on the rise according to consumer group Which?. It analysed 4,000 calls made over three years to customers of call blocking provider trueCall. The data shows older, vulnerable customers received 38 nuisance calls a month, 46% more than other customers, with one in five receiving more than 60 monthly nuisance calls.
At BT, a dedicated vulnerable customer department works to create a better call experience. The telecoms giant has eradicated automated systems in favour of “natural language”, asking customers to simply input their number and explain the reason for the call. This information is fed into an intelligence report.
Hiring people with real empathy is critical, according to BT vulnerable customer and nuisance calls manager Gav Barang. Talking at a roundtable on vulnerable consumers hosted by the DMA last month, he said: “It’s important to have a transparent policy and publish it so it is easy to read, as well as being flexible enough to unwind the process so consumers aren’t tied into lengthy contracts they don’t fully understand.”
“Designing marketing that is more accessible to vulnerable consumers creates an uplift in engagement among the wider population“
Esther Jackson, Age UK
Conversation is key
Identifying vulnerability in the first place can be a challenge, which is why conversations are essential, says TSB director of regulatory risk and compliance Simon Fidler.
“We train our partners to understand that vulnerability can be permanent or temporary. Sometimes our customers are happy to disclose when they’re having difficulties, other times we spot signs of vulnerability.”
Assessment is done on a case-by-case basis, with partners looking out for signs of financial stress, from late payment to changes in payment dates.
TSB offers a variety of accessibility options from in-branch induction loop hearing aids to sign language videos and access to BT’s text service app, which relays what the operative is saying in real time. Digital experts in TSB branches also assist customers who lack confidence using technology.
Conversation is the key tool for O2. Rather than using behavioural data captured online to determine vulnerability, the company provides advisers with specialist training to help them identify vulnerable customers on the telephone, online chat, email or by letter.
Operators look out for signs a customer is struggling to understand or exhibiting confusion about personal information, explains Telefónica UK head of accessibility Donna Howden. Signs of vulnerability are noted on the customer’s account.
Focusing on vulnerable consumers is not bad for business, argues Age UK group marketing and fundraising director Esther Jackson, who sees the value in using design to connect with vulnerable and non-vulnerable customers alike. Age UK, for example, has simplified its website with clearer signposting and four easy-to-navigate tabs.
“Designing marketing that is more accessible to vulnerable consumers creates an uplift in engagement among the wider population, meaning a real business benefit,” she says.
Marketers should see vulnerability as an opportunity to create empathy across channels and step up their communication strategy, argues Jackson. “Vulnerability can affect anyone of any age or ability, so it’s about understanding and adapting the conversation, recognising everyone is an individual.”
Bookmaker William Hill has trained staff to recognise various vulnerability triggers that might suggest that customers are gambling excessively. The company also uses timed pop-ups to advise online customers to take a break and provides facilities for people to set limits on their spending.
Marketing materials are not sent to anyone who has chosen to self-exclude and William Hill does not advertise its gaming machines in its windows. Instead, 20% of window space and TV adverts are devoted to responsible gambling messages, as well as 10% of print ad space.
William Hill is also in the process of developing a gaming machine algorithm to identify players displaying ‘markers of harm’, the most common being a change in gambling patterns.
“Customers are encouraged to sign up to our linked card, which allows us to identify patterns of play and target them with responsible gambling messages when they are exhibiting possible markers of dangerous behaviour,” explains CMO Alex O’Shaughnessy.
“We can then use this data to message customers in order to get them to change their behaviour or to trigger a responsible gambling interaction [such as a disruptive pop-up.]”
Legislating for vulnerability is not the answer, argues Mitchison at the DMA, who believes legal guidelines cannot keep pace with changes in the way brands approach marketing. He believes self-regulation and guidance based on industry input will be more effective.
This opinion is shared by Jackson at Age UK, who claims legislation cannot apply to vulnerability because it is too extensive. “A far better approach is to concentrate on guidelines and up-skilling staff so they can confidently identify vulnerability and offer specialist safeguarding in real time.”
For self-regulation to work, marketers need to understand the widening scope of vulnerability and the variety of ways it affects a customer’s life in order to find the best ways to communicate.