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Looking after vulnerable customers


March 2017 Insurance Age was concerned about how the insurance industry is looking after vulnerable customers and launched its Insurance Cares campaign. Endorsed by the CII, this campaign has been designed as a platform for brokers and insurers to share knowledge and practical experiences about how they have helped customers that need extra assistance. It aims to find ways of identifying vulnerable customers and how we should be looking after vulnerable customers.

In January 2017 the CII’s New Generation Group issued a report called “Consumer Vulnerability – How well is insurance responding?” The researchers on this report found that insurance companies deal with vulnerability inconsistently across the industry, and even across their own internal functions. They found problems that were often a result of poor customer service where the negative impact was made worse by the individual’s vulnerability. The report identified problems across several stages of the insurance process, including claims handling. In claims handling it identified numerous cases of poor communication, unexpected interpretation of wordings at claim stage and rigid processes that negatively impact vulnerable customers.

Regulators are increasingly focusing on the how the industry is looking after vulnerable customers and the FOS considers vulnerability in its evaluations of situations. So it is clearly in the interests of everyone that the insurance industry – insurers, loss adjusters, surveyors, third party providers and outsourced claims handlers – gets better at dealing with vulnerable customers.

This paper looks at how the property claims industry is looking after vulnerable customers, what the MA Group is doing to help and where we think improvements can be made.


According to the FCA, a vulnerable customer 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. Vulnerability takes many forms*:

So these numbers suggest that at least half the population is vulnerable in some way, that’s over 30 million people and increasing! So the insurance industry urgently needs to find consistent ways of identifying and looking after vulnerable customers.

We are all aware of cases where a vulnerable customer has been let down during the property claims process. There has been recent coverage in the press of some shocking cases where ill or old home owners have been let down by poor claims handling, rigid processes or a failure to find suitable, efficient solutions to a difficult claim.

At MA Group we believe that anyone can be vulnerable when making a property claim, even though they may not feel vulnerable. A property claim is often a stressful process that involves a lot of inconvenience and uncertainty. The long and complicated supply chains can make it unnecessarily stressful and inconvenient and we find that many home owners simply do not understand the process and the roles of all the parties involved. So we approach every claim with the assumption that the customer is vulnerable.

At each stage of a claim, everyone involved has the opportunity to assess whether a customer is vulnerable and to take action to support and protect them if necessary.

Repudiation and cash settlement

The CII’s report found cases of policy cancellations and claim repudiations due to insurers not asking clear and unambiguous questions when setting up a policy or taking the customer through FNOL. A vulnerable customer often cannot understand the wording of policy documents or the information required by an insurer when buying insurance or making a claim. In such instances the vulnerable customer becomes even more vulnerable and is unable to follow the normal route of complaint. We agree with the report that claims handlers and loss adjusters should be trained to ask questions and spot signs of vulnerability at the point of claim so that special provisions can be made to ensure they are looking after vulnerable customers.

But even when a policy is valid and a claim progresses past FNOL, the validation of a claim on site is the next touch point where a vulnerable customer can be at a disadvantage. The surveyor or loss adjuster in the customer’s home is in the perfect place to assess the vulnerability of a customer, and it is incredibly important that a vulnerable customer is flagged at this point and the information passed on to other parties involved in a claim. The surveyor or loss adjuster on site should be able to get information on close family or friends who can help the customer and bring them into the process wherever possible.

Repudiation whilst still looking after a vulnerable customer is a difficult issue. When damage to a property is not covered by insurance the insurer is right to repudiate. But the insurer’s duty of care does not end at the repudiation – the home owner should at least be sign-posted towards organisations or services that can help them fix their problems.

Cash settlement is another area where we should all be looking after vulnerable customers. Not only should the insurer make sure the cash is sufficient to get the work done, but should ensure that cash settlement is the right solution for the customer.  For most vulnerable customers, a cash settlement is probably not the right solution – they may not be able to organise quotes and repairs and oversee builders in their home. If the surveyor or loss adjuster believes a customer is vulnerable, they must ensure that the options are explained clearly and unambiguously to the customer, taking account of their circumstances. If the benefits of property reinstatement clearly outweigh the benefits of a cash settlement for the customer, this should be made clear to the customer.


For any claim, the insurer and the supply chain should make the claims progress as easy and as quick as possible to minimise the stress and inconvenience, and this becomes particularly important for a vulnerable customer. By the time a claim gets to the reinstatement phase, a vulnerabe customer should have been identified but that isn’t always the case, or the customer’s circumstances change during the claim and they suddenly become vulnerable.

At this stage information sharing between parties is critical when managing a claim for a vulnerable person. Everyone involved should demonstrate compassion and empathy for a customer dealing with difficult personal circumstances. Rigid processes cannot deal with a vulnerable customer, so flexibility in the claims handling process is key. A good example is alternative accommodation – an insurer should make every effort to ensure that alternative accommodation provided is suitable for the customer, whether they are old, disabled or simply have a large family.

There are often several parties involved in a property insurance claim – surveyor, loss adjuster, drying company, builders, contents provider etc – and often there is no-one in overall control of the claim so hand-offs, inefficiencies and poor communication often occur. We strongly believe that customers, and insurers, have much to gain from there being one claims manager overseeing the whole claim and all the parties involved. This is particularly important when there is a vulnerable customer as the claims manager can co-ordinate parties and ensure information is shared. This would also mean that the customer would have just one point of contact which would significantly reduce their stress and confusion.

Where property reinstatement is concerned it is vital that the right experts are appointed, and generally only someone with a sound technical building knowledge will have those skills. We were recently involved in a claim where the drying company had spent many months unsuccessfully trying to dry out a property. Once we were appointed we quickly identified that standard drying techniques would never work as the property did not have a damp proof course. If we had been brought in at the start the customer would not have suffered many months of delay and stress.

Existing guidelines

There are no consistent industry wide guidelines to address the needs of vulnerable people. As the number of vulnerable people continues to grow insurers need to recognise that vulnerable customers are a significant and growing proportion of their existing and future customer base. Insurers need a better understanding of vulnerable customer’s needs so they can respond accordingly and be looking after vulnerable customers.

There are some guidelines in place, but they are not extensive. The ABI and BIBA Code of Good Practice is intended to support potentially vulnerable customers at renewal. It states that employees recognise potentially vulnerable customers at renewal, listen to their needs and be equipped with flexible options to address those needs. This information should be shared systematically so that anyone who interacts with the customer is aware of the issues and can help. The FCA’s Occasional Paper includes a Practitioners Pack to support firms’ understanding of how they can generate better outcomes and develop more inclusive services for vulnerable customers. Insurers such as Zurich and RSA have developed services and protocols for specific issues such as dementia or mobility schemes. But there is a real need for comprehensive guidelines on how everyone in the insurance industry should cater for vulnerable customers.


MA Group’s core values have always included values that apply to vulnerable people, such as Keep it simple, Compassion, Flexibility and Excellent communication. Back in 2015 we introduced our SUPPORTING Pledge, aimed at ensuring that we help and support older and more vulnerable customers. This is still in place today:

Since then we have further developed and extended the whole group’s proposition for supporting and helping vulnerable customers.

To find out more about our Supporting Pledge in action, please watch the following video.