Vulnerable Customer Policy

Policy Statement

At EIRA Therapy Ltd, we are dedicated to identifying and supporting vulnerable customers in line with our company objectives and regulatory guidelines. We have developed procedures to ensure that our team can effectively recognise, assess, and assist vulnerable customers, ensuring they receive the appropriate level of care and service at all times.

1. Purpose

Our goal is to treat every customer fairly and meet their individual needs to the best of our ability. We understand that vulnerability may arise from physical or mental health conditions, age, literacy challenges, or language barriers. We strive to treat each customer according to their specific circumstances and provide staff training to enable them to identify and manage vulnerable customer situations sensitively and effectively.

2. Scope and Definition

A vulnerable customer, as defined by the FCA, is: “Someone who, due to their personal circumstances, is especially susceptible to detriment, particularly when a firm is not acting with appropriate levels of care.”

We recognise that vulnerability can take many forms, including but not limited to:

• Low literacy, numeracy, or financial capability
• Physical disabilities
• Long-term or severe illness
• Mental health issues
• Low income or debt
• Older age (e.g., 80+)
• Youth and inexperience
• Changes in personal circumstances (e.g., job loss, bereavement)
• Limited English proficiency
• Substance intoxication

Our communication, primarily face-to-face and over the phone, enables us to identify both short-term (e.g., illness, bereavement) and long-term vulnerabilities (e.g., disability, mental illness).

3. Processes and Procedures

When a member of our staff identifies a customer as potentially vulnerable, they will ask non-intrusive questions to better understand the customer’s circumstances and ensure appropriate support is provided. Any information shared will be processed in line with GDPR, and explicit consent will be sought before recording any personal data related to vulnerability.

Our processes include:

• Seeking explicit consent to store/process vulnerability-related data.
• Explaining why and how the information will be used.
• Sharing the information only with relevant staff or third parties where necessary.

We also tailor our communication and products to meet customers’ needs, and if necessary, involve authorised third parties such as family members to assist in decision-making.

4. Monitoring and Reviews

EIRA Therapy Ltd regularly audits business practices to ensure that vulnerable customers are treated fairly and with respect. Senior management reviews these audits to identify trends and make necessary adjustments to improve our support for vulnerable customers.

5. Responsibilities

It is the responsibility of senior management to ensure that all staff are trained to identify and support vulnerable customers. Training is provided at the start of employment and refreshed annually. We also offer support to staff who may be emotionally impacted by working with vulnerable customers, particularly if they have faced similar challenges personally.

By adhering to this policy, EIRA Therapy Ltd aims to ensure that all customers are treated with the care and respect they deserve, regardless of their personal circumstances.