I never thought I’d see myself typing the following, but I was thrilled to read Appendix A of the Ofgem Consumer Vulnerability Strategy 2025.
- The definition of vulnerable has expanded; I can see many characteristics in there now that I felt were missing in the 2013 version.
- It’s encouraging to see that Ofgem are working towards creating a sector that consistently takes fair debt management and accessibility seriously.
I’d really like to see the flag-waving of partnership working become a reality that leads to there being one Priority Services Register across all utilities and perhaps the basis for a sector-wide approach to fit-for-purpose inclusive customer service. I know it’s a competitive market but working together on this just makes sense.
Engage in a way that suits the customers, not you
With a background in social care and plenty of my own lived experience, it’s easy for me to scrutinise how an activity or service approach will impact someone without the advantages many professionals take for granted, such as a regular sleeping pattern, days filled with non-intrusive thoughts and the ability to enter any building with ease. Understandably the utilities sector as a whole does not carry this depth of knowledge, certainly not consistently (yet). So, the more engagement that is done, and done well, with these groups the better.
People in vulnerable circumstances are less likely to make a complaint or provide feedback than the average customer for a range of reasons. For many, getting through the day is hard enough without finding the resource to deal with a customer complaint process. So, if you want to find out what these customers need, you’re going to have to speak to them in a way that suits them, not you.
Accessibility is about where and how you promote, not just what you say
Despite my overarching sense of relief and warm fuzzy feelings, I was disheartened to read there had been a consultation on this strategy that closed only a couple of weeks ago that I can’t take part in because I hadn’t heard about it. I make it my business to do that sort of thing, so if I hadn’t heard about it then most of the people I care for, who are struggling through life, almost certainly haven’t.
If your budget’s low or you’re in a rush – that’s ok, talk to trusted organisations who know these customers
The sector is doing great work and partnering with people like Citizens Advice (who recently wrote a relevant call to action here) along with a range of third-sector organisations will surely reap better understanding, policies and practice. Plenty of people have done plenty of work already on the matters at hand, so just ask. There are some free resources included at the end of this blog, just to get you thinking.
Minimising disruption is a sector-based issue but in the context of reducing the impact on customers who will be most affected by interruption appropriate communication, support and plenty of warning can go a long way.
Try to focus on practicalities, rather than labels and assumptions
Vulnerable situations are complex and individual. Research I recently delivered on behalf of Cadent suggests that taking a needs-based approach around provisions and communication avoids labelling and unnecessary assumptions. This, I feel, is paramount given that so much of the difficulty of day-to-day life is massively exaggerated by stigma and prejudice (well-intended or otherwise). We apply the label of ‘vulnerable customers’, but vulnerable compared to who? Who is this mystical being with perfect vision, hearing, mental and physical health and cognitive ability of the appropriate age, cultural background and economic standing? Who is this ‘able’ and ‘correct’ person that the world is built for that we’re measuring ourselves against?
So, instead of having a database of characteristics, names and addresses – a database with answers to specific questions such as ‘do you want someone else present if an engineer is entering your home’ and ‘how much notice do you need to arrange this?’ negates the reasons for knowing why, omits some opportunity to make assumptions and simply deals with the needs of the customer.
Instead of focusing on all the ways in which a person can be vulnerable, or ‘less than’ in some way, perhaps we could talk about inclusive practice instead. That way, we can focus our efforts on understanding and dealing with the complexity of individual needs, rather than trying to segregate and ‘tick off’ accommodating the needs of groups that don’t exist in a tidy, segregated, manner.
You’re doing great, keep it up!
I applaud the efforts made by the sector to date and hope to pitch in more to make more inclusive services and, ultimately, a more inclusive world. I’m pleased to say we’re getting our heads together at Traverse to think twice on how we do inclusive practice to create some fresh, simple resources for everyone here to refer to. We’ll be sharing this more widely and asking for others to weigh in once we’ve done some work internally so watch this space – sharing makes the world go around!
Obligatory plug: Traverse are holding a breakfast roundtable event on Thursday 24th October for organisations working on inclusive engagement to learn and share knowledge about the challenges and opportunities. If you would like to attend, please email Hattie.firstname.lastname@example.org
For now, have some free resources I stumbled on through our recent work:
A framework for developing policies for engagement with vulnerable customers: https://dma.org.uk/article/framework-develop-vulnerable-customer-policies-for-internal-and-external-use
Some training materials for recognising and responding to vulnerable customers: https://dma.org.uk/article/free-training-materials-recognising-vulnerability-and-making-reasonable-adjustments
Some practical resources on communication with specific people: https://www.parkinsons.org.uk/information-and-support/speech-and-communication-problems-parkinsons
Some shared learnings around safeguarding practices: https://www.scie.org.uk/safeguarding/charities/roundtable-2019-04