Consistency is needed to benefit vulnerable consumers

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Guest blog

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Industry sector

Supply and Retail Market
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Following extensive engagement, we’ve outlined a new Consumer Vulnerability Strategy to improve help and support to vulnerable energy customers.

With our consultation on the draft strategy ending today, we close our vulnerability guest blog series with Amanda Manning, director of strategy at Ombudsman Services, on the inclusive, customer-first practices needed to improve help for vulnerable consumers.

Amanda Manning

Recent years have seen some encouraging progress across the energy industry in terms of identifying vulnerable consumers and working collaboratively to address the issue of vulnerability. 

There is, however, clearly more that can be done. Consistency in customer-first, inclusive practices is key to building trust and engagement in the energy sector and all industry partners have a role to play in this.

As Ofgem reports in its draft Consumer Vulnerability Strategy 2025, not only are vulnerable consumers more likely to suffer detriment, the nature of that detriment is likely to be substantial. 

Language and vulnerability

Analysis of complaints brought to the Energy Ombudsman shows that, from August 2017 to July 2018, 40% of complainants used words associated with vulnerability (such as “stressed”, “debt” or “mental health”) in their contact with us. 

This suggests that a large proportion of energy consumers who seek independent redress after experiencing problems are in vulnerable circumstances. 

Of the 40% of energy complainants who showed signs of vulnerability, the most common reason for this was financial hardship, followed by mental health.

These are two categories defined in Ofgem’s draft Vulnerability Strategy as factors that can lead to additional challenges for consumers.

Barriers to complaint and redress

In our latest annual Consumer Action Monitor (CAM), 64% of those identifying as vulnerable reported feeling filled with dread at the thought of complaining, while 63% said they find the process highly stressful.

The result is that, too often, complaints go unheard. Indeed, we found that vulnerable consumers are much more likely than the rest of the population to suffer in silence and not take a complaint forward. 

For an energy market that works for everyone, it’s important we take steps to identify and forge new strategic partnerships that enable us to collaborate on consumer vulnerability and ensure voices are heard.

Below are three ways in which we're working to help tackle the barriers vulnerable consumers face, and embed inclusive and consistent practices:

1) Digital inclusion

We’re involved in roundtable discussions, led by technology thinktank Doteveryone, that examine the potential impact of digital exclusion on vulnerable consumers. We are also partnering with charities and support groups that support vulnerable consumers and focus on promoting digital inclusion. 

2) Accessibility

At Ombudsman Services we’ve recently rebranded and adjusted our tone of voice to afford greater accessibility and ensure that interactions are simple, clear and inclusive with no jargon. We undertook significant immersion research and consulted with all customer groups to understand what motivates and drives the people who come to us with an unresolved complaint. A new website is live and our webform has been enhanced following work with Samaritans, to include sensitive questioning techniques to capture additional information and help us assist vulnerable consumers. 

Our new case management system is designed to encourage a more direct and transparent relationship between parties and promotes early resolution of complaints through Facilitated Case Resolution (FCR). As the system is developed, there will be fields aligned with the Priority Services Register. 

3) Facilitating discussion and collaboration 

At our recent annual conference, we held a panel discussion on the topic of consumer vulnerability with panellists from Cadent Gas, Money Advice Trust, Skint Dad and Dementia UK.

Meanwhile, we are holding a series of vulnerability workshops for communications providers (the other sector in which Ombudsman Services operates) and are keen to facilitate similar sessions in energy. 

Working together to improve experience 

Using the experience, insight and relationships we have in the communications sector as well as energy, we are committed to playing a valuable role in bringing together key stakeholders, sharing cross-sector insights and driving better outcomes for consumers. 

We wholeheartedly support the aims and objectives of Ofgem’s draft Consumer Vulnerability Strategy and look forward to working with the regulator and others to tackle the challenges faced by consumers in vulnerable circumstances.

Your views

Our consultation on our Consumer Vulnerability Strategy closes today, 8 August 2019. Responses to the strategy can be made here. 


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Our series of guest blogs represent the views of the authors writing with a view to encouraging debate about important energy topics. They do not represent the views of Ofgem, nor should they be construed as an endorsement or commitment by Ofgem to take any particular course of action.