Vulnerable Customer Policy

The purpose of this policy is to ensure that the operations of RSG Motor Group do not have any negative impact upon vulnerable customers.

For the purposes of this policy, vulnerable customers are customers and prospective customers whose ability or circumstances require us to take extra precautions in the way that we conduct business and provide our services to ensure that they are not disadvantaged in any way.

What is a vulnerable customer?

The Financial Conduct Authority (FCA) defines a vulnerable customer 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."

The FCA expects firms like ourselves to treat customers fairly when we are dealing with people with vulnerable circumstances.

Identifying a vulnerable customer

Our staff are trained to identify vulnerable customers so we can take extra steps to assist outside of our standard procedures. However, it is not always possible to recognise these characteristics. Therefore, if you believe you may fit the criteria for a vulnerable customer, please read this policy and notify us immediately of your particular needs.

Signs we look out for:

  • Do they ask us to speak up or speak more slowly?
  • Do they understand what we are saying, or do they miss important bits?
  • Do they appear confused about what is being offered?
  • Do they ask any unrelated questions?
  • Do they keep wandering off the point or talking about irrelevant things?
  • Do they keep repeating themselves?
  • Do they take a long time to answer questions or say that someone else deals with these things for them?
  • Do they have a language barrier?
  • Do they say they do not understand previous correspondence or discussions?

Vulnerability groups may include, but are not limited to:

  • Customers with communication difficulties (learning difficulties, dyslexia, English not being their first language).
  • Customers with reduced physical or mental capacity.
  • Customers with health issues - physical or mental illness, severe or long-term.
  • Customers dealing with a sudden diagnosis of serious illness (self or family).
  • Customers facing personal circumstances such as financial difficulty, bereavement, caring responsibilities, or redundancy.
  • Customers who may be inexperienced (younger people) or less technologically able (older people).

Steps we take if we believe a customer may be vulnerable:

  • We speak slowly, clearly, and explain fully.
  • We are patient and empathise where appropriate.
  • We do not rush and allow time to gather information.
  • We stay focused on the subject under discussion.
  • We do not make assumptions about a customer's needs.
  • We clarify understanding at every point.
  • We ask the customer to explain their understanding of the agreement.
  • We offer alternative communication methods (phone, post, email, in person).
  • We consider that some customers may have sight or hearing impairments.
  • We allow time for explanations and do not interrupt or show impatience.
  • We always ask if there is anyone else they may need to consult before making a decision.

Prior to forming a contract:

  • We ensure that 'yes' is a genuine agreement, not just compliance.
  • We confirm that the customer understands their decision and consequences.
  • We ask if they need to discuss the matter with anyone else.
  • We repeat and clarify points to confirm understanding.
  • We ensure the customer is not agitated or emotional when making decisions.
  • We offer to defer discussions to allow time for reflection or third-party advice.

Post Contract:

  • We record communication needs to ensure future interactions are handled appropriately.
  • We document that we are satisfied the customer understood all discussions.
  • We store information about customer needs with full consent.
  • We delete personal data when the relationship ends, in line with the Data Protection Act 2018.

If we identify a person who may need specialist advice beyond our expertise:

We will signpost them to appropriate organisations such as:

  • Samaritans
  • Citizens Advice Bureau
  • Age UK
  • Alzheimer's Society
  • Mind
  • StepChange Debt Charity
  • Macmillan Cancer Support

Sources of guidance we refer to:

  • Equality Act 2010
  • Mental Capacity Act 2005
  • FCA CONC 7.9 - Contact with Customers
  • MALG 12 Steps to Treating Vulnerable Consumers Fairly
  • Irresponsible Lending and Debt Management Guidance

Contact Us

To discuss this policy in more detail or to register yourself as a vulnerable customer, please contact us:

Email - [email protected]
Phone - 0208 115 0325
In Writing - RSG Motor Group, Kings Road, Ascot, SL5 7BT
Website - www.rsgmotors.co.uk