Introduction

 

Square1 Communications recognises that some consumers may be vulnerable in the context of how they interact with services provisioned by our clients. As a provider of premium rate numbers, we have put in place an appropriate support mechanism to take account of these needs and to ensure that our client’s take action to reduce the risk to the vunerable.

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This policy aims to provide guidance on how our clients can define and identify potentially vulnerable consumers, outline the processes we have in place to help support vulnerable customers, and detail how we will oversee compliance in this area. 

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Defining and Identifying Vulnerability

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Consumer vulnerability is a complex issue. The definition of vulnerability is non-binary and encompasses a multitude of interacting factors. Therefore, Square1 defines vulnerable consumers in line with the PSA parameters as a consumer who is less likely to make fully informed, or rational decisions due to a specific characteristic, circumstance or need, and may be likely to suffer detriment as a result.

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Square1 requires all of its clients to have their own Vulnerability Policy in place which does not conflict with the measures set out in this document and ensures consumers are provided with appropriate levels of care, service, and that no unnecessary risk is posed to the consumer.

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Square1 works on the general principle that we will take appropriate steps to consider individuals who are particularly vulnerable or susceptible to detriment and therefore needs:

 

● Adjustments to the way in which we communicate and support them 

● Square1 recognises that there is a sliding scale of vulnerability, and that people are different, meaning that some customers will become vulnerable in circumstances where others may not.

● Square1 works on the basis that every individual is different, has different circumstances, and therefore may need consideration. This means that as far as possible, we will treat individuals in a way that is appropriate to their needs, where possible tailoring our approach. 

● In some cases, we may where appropriate need to adopt an approach for dealing with certain categories of vulnerable customers or vulnerable customers who despite having different circumstances may be appropriate to follow a similar treatment path. 

● We have a number of processes and tools in place to facilitate this and each of these are covered in more detail below. 

● Square 1 takes any complaint about treatment of vulnerable customers very seriously and any such complaint will be investigated fully. If appropriate, Telecom2 will liaise with relevant law enforcement agencies. 

 

Reasonable Foresight

 

Phone-paid Services Authority Guidance on Vulnerability requires service providers to exercise reasonable foresight, with the aim being to reduce the risk of services taking unfair advantage or vulnerable consumers. The Guidance states that all providers are expected to undertake steps to actively identify and monitor risk, together with take the appropriate action should risk to a vulnerable consumer be identified. The PSA acknowledges the difficulties in identifying a vulnerable consumer at the point of use, however they have proposed measures which Telecom2 considers when engaging with it’s clients and their consumers.
 

All prospective clients are required to complete Square1’s due diligence and risk assessment documents. Answers to these provide the basis for the decision to proceed or reject clients wanting to use Revenue Share Numbers or SMS from Square1. All responses are considered carefully, and clients failing to meet expectations and actions in support of safeguarding consumer vulnerability will not be accepted.

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As part of this process, clients are required to produce their own Vulnerability Policy which identifies risks to vulnerable consumers as well as detailed risk control measures. 

Consideration of risk identification includes:

 

- Identifying the target market of the service and considering if the service is likely to appeal to vulnerable consumers or a particular type of vulnerable consumer (including children) 

 

- Consider if the ways in which the service is advertised and marketed might attract vulnerable consumers. This should include whether the style, content, and composition of the promotional material might make it particularly attractive to children. 

 

- Thought about the characteristics and circumstances that can lead to consumers becoming vulnerable and to test their system to ensure they adequately anticipate and can respond to any reasonably foreseeable vulnerable consumer needs. 

 

- Storage and use of existing customer data and on-going monitoring information to identify any additional risks, especially around customer care. 

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Consideration of risk control and safeguarding includes:

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- If the service is likely to be attractive to children, parental controls may need to be in place. 

- If the service is restricted to people over 16 or 18 years of age, appropriate controls, including parental controls should be in place. 

- If an advertising channel is suspected of driving vulnerable consumers to the service, this may need to be addressed with any marketing partners. 

- Ensure that appropriate mechanisms are in place to identify excessive use of phone-paid services. 

- Ensure customer care staff have appropriate resources and reference materials at their disposal so they can engage with vulnerable customers appropriately and provide a level of service that meets their needs.

- Training staff to enable them to recognise and respond appropriately to the explicit and implicit signs of potential consumer vulnerability, or consider training a small number of staff who could act as “specialists” for prompt and convenient communication with the consumer.

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Monitoring Risk

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To ensure risk is controlled, upon signing Square1’s Service Agreement, all clients agree to participate in regular monitoring of their service, provide SQ1 with regular updates on advertising and inform SQ1 of any complaints from a suspected vulnerable group. Square1 must be alerted by email to info@sq1.co.uk in all instances and receive a full breakdown of the mitigating actions the client will be undertaking. Failure to address issues promptly may result in a suspension of service to prevent consumer harm. 

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Square1 itself uses statistical monitoring to flag any patterns in call data which may indicate to us the presence of anomalies. Anomalies can include indications of Bill Shock or changes in the call duration. Whilst an excessively high phone bill from a phone-paid service cannot be directly attributed to vulnerability, it may serve to contribute to wider financial issues for the consumer and associated difficulties which may follow. As a result of any SQ1 monitoring the client maybe contacted for further investigation of suspected issues.
 

Our clients must provide a policy relating to refunds and corrective actions in the event that a complaint is received from a consumer. We also expect clients to respond to issues in line with their own vulnerability policy considerations. Failure to address issues may result in service termination.