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Looking after vulnerable customers

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Monday 10th April 2017 | By ma-admin

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*:

  • Age – 11 million people, 18% of the population, is aged 65 or over and this is increasing.
  • Disability – there are 13 million disabled people in the UK, 20% of the population.
  • Computer literacy and access – 7 million people in the UK have not been on the internet, another 11% of the population.
  • Low literacy and numeracy skills – 8 million people (13% of the population) have “below-functional” numeracy skills and another 5 million people (8%) have “below-functional” literacy skills.
  • Mental health – this can be a long term or temporary condition, affecting 1 in 4 people.
  • Bereavement and carers – with 600,000 deaths every year and about 6 million people acting as unpaid carers there are many temporarily vulnerable people.

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:

  • SHARE information about the customer’s situation with the appropriate people using our flexible systems effectively.
  • UNDERSTAND the customer’s needs and concerns, demonstrating compassion.
  • be PATIENT and take time to listen and to facilitate a proper conversation so the customer’s situation and concerns are fully understood and appropriate actions are taken.
  • PRIMARY CONTACT must be appointed for that customer’s case, ensuring consistency and familiarity for the customer.
  • OBSERVE the risk factors and triggers that create a need for help and advice and involve other staff or organisations that can provide help.
  • REWARD good practice in relation to older customers and recognise and praise it.
  • TRAIN all frontline staff to identify an older, vulnerable customer and to deal with the situation appropriately.
  • INVOLVE and communicate with all parties to the claim and ensure that they are aware of the issues and needs of the customer and are kept up to date.
  • use NO JARGON, just clear and simple information and language, avoiding industry terminology.
  • GIVE time and effort with regular and appropriate updates to the customer and relevant parties.

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

MA Group’s initiatives

From our first surveying or validation visit to the closing of the claim, MA Group companies are geared up for looking after vulnerable customers.

The Virtus independent surveying and validation model has been designed around the customer. The business has invested in IT and surveyor training to ensure that Consumer Rights are protected and that information is gathered on site to help the smooth progression of the claim. IT innovations and generous time allowances mean that surveyors have more time to spend with the customer understanding their needs and explaining the process and options to them.  Specific innovations include:

  • Scoper – our in-house mobile surveying and validation app that allows the surveyor to comprehensively scope and investigate a claim. Its data capture abilities include a lifestyle questionnaire where the customer can declare any issues that are important to them, such as disabilities or illnesses, or even booked holidays and family events that the claim managers needs to take account of when planning the reinstatement. This information is passed onto the suppliers assigned to do the reinstatement works as well as the insurer.
  • CARE meetings – Virtus can ensure a smooth handover to the contractor through a CARE meeting at the risk address where the surveyor introduces the customer to the contractor and the surveyor and contractor agree the scope on site. This is a great way to support a vulnerable customer, making sure that the contractor is aware of all the issues and has time to plan the project accordingly in advance.
  • Sign-posting and support – At the end of a repudiation or cash settlement, the Virus surveyor provides support for the customer by giving them an unpriced schedule of works that they can use to get quotes and arrange their own repairs. They also sign-post the customer to TrustMark, the only Government-endorsed scheme for trades in and around the house. TrustMark awards registered firms with its accreditation after thorough vetting and on-site inspections to ensure the firm is raising industry standards.
  • Aftercare – Virtus can give customers retail discounts with major high street brands and, to help them save money if they have to carry out their own repairs.

MA Assist’s flexible approach and systems enable it to cater for vulnerable customers. Our claims system enables us to flag a vulnerable customer and so assign a claim owner who will oversee the claim and look after the vulnerable customer as needed. Our staff are trained to identify a vulnerable customer and have been known to contact emergency services if they haven’t been able to get hold of a vulnerable customer, or send round a supplier to check on the well-being of a customer.

Our suppliers are also trained and equipped to deal with vulnerable customers, and are often the people on the ground looking after frail, elderly and vulnerable customers.

It is not unusual for us to receive compliments for our staff and suppliers from vulnerable customers such as:

“Gareth has shown great kindness and sensitivity to my stress. He moved things along and liaised on my behalf over difficult situations…”

“I have been asked by the insured’s representatives to pass on their gratitude for the works completed by one of your contractors, SDM Group. The couple who live at the property are elderly and are immobile in many ways…. There were also some other complex issues which the contractors took in their stride and dealt with to the highest level of professionalism that Mr X (who used to be a loss adjuster) had ever seen…”

“I can’t believe how wonderful everyone has been. This has been such an ordeal for me and I am so pleased to be back in my home. It’s beautiful.”

There are several case studies demonstrating our suppliers amazing ability to support vulnerable customers. Cipher UK’s professional team worked with one of our suppliers, Phoenix, to rebuild Mrs Eaves’ home following a gas explosion. Mrs Eaves was 80 at the time and was full of praise for everyone involved in her claim.

Cipher UK and Spain Building & Maintenance project managed a flood claim in the North West of England involving an elderly couple who were delighted with the service that Cipher UK and Spain Building provided.

Primary Authority advice

In 2015 MA Group set up a Primary Authority partnership with Northamptonshire County Council to consider the implications for the insurance industry in relation to the new consumer rights regulations. This advice sets the framework for Trading Standards Authorities all over the UK for consumer complaints in relation to property insurance claims.

One element of this advice is relevant to vulnerable customers. It is not sufficient to assume that a consumer is aware of all of the facts and information that has been provided to them, e.g., the details of a policy document, particularly in relation to vulnerable groups. A misleading omission can occur if a consumer is not “average” and is unable to make an informed transactional decision with the information provided to them at the time. An omission of information or misleading statements given to consumers can be a criminal offence if they cause the consumer to take a transactional decision he would not otherwise have taken.

We have designed all of our processes and trained all of our staff across the whole group to ensure that we operate in line with the Primary Authority ruling in place.


We believe that the property insurance industry can improve its service to vulnerable customers during the claims process by following some simple recommendations:

  • Ask the right questions at FNOL. In addition to the routine FNOL questions, staff should simply ask a couple of open questions such as “Is there anything you are worried about or don’t understand?”
  • Customer vulnerability should be flagged at FNOL stage and the information passed on to the supply chain.
  • Sharing of information ensures that the customer doesn’t have to answer the same questions repeatedly and ensures a better customer experience
  • The first person on site, such as the surveyor or loss adjuster, should be trained to recognise vulnerability and be provided with a mechanism to make others involved in the claim aware of the situation. An extra few notes for recording any issues or concerns on the schedule of works or survey report would be a start.
  • A sole claims manager should be appointed to oversee the whole claim, from survey and restoration right through to reinstatement and contents. Not only does this give the vulnerable customer one point of contact and one clear source of help and advice, but it would also ensure effective project management and fewer delays and less stress.

Support and information in the case of a cash settlement or repudiation should be provided to all customers, vulnerable or not. Not only does this help to ensure that the repairs actually take place (so the risk of future claims is reduced) but it also makes sure that help and advice is provided to those that need it most.


The regulators are increasingly focusing on the treatment of vulnerable customers and so insurers need to respond to their needs. The reputational damage caused by getting it wrong can be enormous, never mind the financial cost. But an insurer that gets it right has a real business opportunity; by providing great customer service to a growing majority of the population who need help, an insurer can grow their own business through strong customer retention and winning new business.

We can deliver a complete claims management solution that ensures good customer care, clear communication and strong project management throughout. We have demonstrated many times that when acting as the overall claims manager we can ensure an efficient claims process, higher NPS scores and less stress for the customer.

Our clients have often chosen MA Group to manage claims for vulnerable customers from start to finish, even when their normal business models usually involve several parties. It is encouraging to see that insurers can be flexible when faced with a challenging claim or vulnerable customer, but it is inconsistent and we would like to see earlier and more consistent identification of these claims so we can help sooner.

MA Group and its suppliers consistently achieve NPS scores of 70% or more. We can deliver a great service not matter which stage of the claim we are involved in, and have many years of experience in dealing with vulnerable customers. If you would like to know more about how we can help please get in touch.

* Consumer Vulnerability – How well is insurance responding, CII New Generation Report

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