10th August 2026

When vulnerability policies go wrong.

I just want to speak to somebody who can help me?

When vulnerability policies go wrong.

I have never considered myself to fit such definition but since passing 75 I am beginning to wonder if lip service is being paid by regulated firms or they have just made it more difficult for their customers? 

Very lengthy calls this last week with a bank, an ISA provider and a major healthcare brand have highlighted major problems with them all that I can navigate, but suspect many senior citizens may find quite difficult.

It seems the perceived solution in all cases was that for those who may have vulnerable characteristics the advent of an app that you can download to your phone or even a desktop is the panacea.

The first problem with this is that not all seniors are ‘tech savvy’ or tech literate or have a device available to them.

For many in their mid 70’s and beyond this may be second nature, but for many others I suspect that it is definitely not the case.  Accessing an app is not always easy and that is assuming you know where to find it in the first place. This is compounded (when you have got the app) if you do not know where to find it on your device and if you did find it, have you registered and retained a password, pin or account number, enabled face or fingerprint recognition?  Add that to shortsightedness outcomes and fingers that are not as nimble as they used to be resulting in getting anywhere with speed impossible.

Working from home (WFH) and call centres do not ease the journey, even those who are adept with digital prompts and good vision will find the frustration build to unbearable levels by just not being to speak with someone before regulation decided to help by blocking that as an easy to navigate option. 

App based customer support, foreign call centres and financial services are not comfortable bedfellows. Treating Customers Fairly (TCF) endeavours and regulatory requirements regarding vulnerable consumers simply fail at the first encounter with very many seniors. 

Apps create unreasonable barriers, many older customers should be able to easily switch products, change providers, submit claims, or make a complaint without encountering unfair obstacles.  

My experiences this month have seen a 100% fail rate with banking, healthcare and ISA switches. The solution used to be a simple telephone call, even that option now sits within an app……..for security and ID purposes no doubt!

Why? 

The Four Key Drivers of Vulnerability were clearly defined by the FCA to determine what can increase a customer's susceptibility to harm or detriment in financial services. The FCA notes that “product manufacturers should consider how the design of products could cause foreseeable harm to customers in vulnerable circumstances. Whereas distributors that deal directly with consumers will need to ensure their communications and support processes respond to the needs of customers with characteristics of vulnerability”. 

For seniors these listed below could be an issue in all or part:  

• Health: Physical or mental health conditions, illnesses, or disabilities.
• Life Events: Significant changes such as bereavement, sudden caring responsibilities, divorce, or redundancy.
• Resilience: A low ability to cope with financial or emotional shocks, low savings, or high debt.
• Capability: Low financial knowledge, poor literacy or numeracy, or lacking digital skills.  

There should be a few more: 

Technology engagement- do customers have internet access and the appropriate equipment to engage? 

Menu driven call answering, my experience last week saw one brand offering 6 options, for many customers by the time option 6 has played out the first few will have been forgotten, imagine how that seems for the more ‘mature’ customer and that is before any prompts to input passwords, pins or account numbers.

Call centre practices regarding WFH (Working from home) Wait times can be enormous and it is not unusual to hear children crying in the background when you do actually get to speak with someone, something any consumer with hearing issues will not find too helpful.

Abuse warning. After a call is actually answered it is not unusual to be followed by such a warning played out, sadly that is also across state organisations such as HMRC, NHS and has crept into the world of financial services. This is issued rather than addressing the reasons why such a reaction has been generated to what the customer perceives as service failure.

 Since Covid firms have taken advantage of the unintended benefit of cost reductions by way of reduction of office space, WFH, hot desking, no operator to take a call. Add AI to the mix and I suspect that so many will have given up making any progress toward dealing with the issue they originally called about.

Steve Jobs viewed failure not as a permanent defeat, but as essential education, a fresh beginning, and the lighter state of being a beginner again.

One of the greatest discoveries in psychology is the fact that you can often correct or change behaviours, thoughts, or feelings for the better by trying to make them worse. 

FCA take note, this mindset originates from 12 Endeavour Square and is being made worse. My experiences are that these protocols are not for the senior consumer at all but just to tick a perceived regulatory box with no thought at all about the consumers it is there to supposedly make life a little easier.

Now make it better!

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