UKGI Compliance Manual

It remains entirely a firm’s own discretion as to what channel of communication it uses to support its customers. These could include telephone, online, e-mail, in writing, SMS messaging, webchat, video calls and social media interaction. The rules do not require firms to adopt all methods but any channels of support they do offer must meet the needs of their customers, including facilitating customers dealing with non-standard issues.

The FCA does expect firms to respond flexibly to the needs of customers with characteristics of vulnerability and this will usually require adapting their standard approach to provide appropriate channels within reason of the firms’ capabilities.

Example of good practice

A firm which normally conducts all customer service support via telephone and in-branch considers the impact of its support channels on mental health issues, in particular those customers who may find it difficult to conduct verbal communication in person or over the telephone.

They offer an immediate alternative channel of support by enabling customers to send an enquiry e-mail via their website contact us page, which will be responded to within 1 business day. This enables customers to reach them quickly and be confident that they will get a prompt response.   The e-mail inbox is monitored frequently to ensure all queries are addressed within the timescales promised and any exceptions to response times are monitored via quality monitoring reviews and monthly management information reporting to ensure that remedial action is taken to address any response delays.

However, the firm also realises that the alternative method provided does not provide the same real time response as a telephone call would and therefore takes further action to improve the customer journey by developing the capability to provide real time web chat functionality.  

This does not require firms to always communicate and provide support via each individual’s preferred channel, but this does require firms to put themselves in the shoes of vulnerable customers and consider what adaptations can be reasonably made to existing channels of support and what developments may need to be considered taking into account particularly where characteristics of vulnerability exist within the defined target markets with which the firm deals.

Limited channels

The FCA recognises that a firm could design a product where support is provided through limited channels only, for example a product designed for a ‘tech-savvy’ target market may offer digital-only support. In such cases the FCA does not expect firms to offer additional non-digital support aimed at customers outside of this target market.

Where a firm does provide support through mainly or only through one channel it should consider the following:

Communicating the support availableProducts and services must be targeted appropriately, and the limited channels of support offered must be clearly communicated to customers before the product is purchased to allow the customer to assess whether the limited support channel offered meets their needs.
Ensuring support works effectivelyThe limited channel(s) of support offered must by effective and enable customers to realise the benefits of the product or service without unreasonable barriers. Unclear or confusing customer journey will not meet the standard.
Dealing with non-standard issuesException processes should be in place to deal effectively with non-standard issues that could arise during the lifecycle of the product or service. This could include security or fraud concerns or technical issues. It is likely that firms will need to provide a real-time human interface such as a telephone service.
Operational resilienceFirms should be able to continue to provide support to their customers in the event of a business continuity incident, e.g., an IT outage or cyber attack.
Customer with changing needsFirms should be mindful that anyone, including those classed as ‘tech-savvy’, can become vulnerable, either temporarily or permanently, and if this happens it could result in the limited channel of support no longer meeting their needs. This does not mean a firm will need to provide an additional full-service channel but it should have processes in place to meet changing needs (which may be similar for the options for dealing with non-standard issues).

Examples of good and poor practice

Poor practice  Good practice
A firm uses an automated telephone system as part of its consumer support. The system only provides options to progress with a few commonly raised issues. It does not provide a route for customers to seek support regarding other issues and refers them back to the firm’s website.   The customer is unable to obtain the support they need as the channel does not work effectively and is unable to deal with non-standard issues.       A firm changes its channel approach to sell a motor product via its digital app.   The firm adapts is sales journey and literature to work effectively when accessed on a mobile device using layering and digital tools.   It tests the effectiveness of the customer journey by using an internal focus group to carry out scenario testing before launching the service.   The firm also provides a telephone support line to deal with any non-standard enquiries or anyone having difficulty in using the app.   The firm is actively developing the customer experience adapting to the changing needs of customers and providing a route for any non-standard issues or for those with characteristics of vulnerability. In addition, it is ensuring that the channel works effectively via proportionate testing.