Vulnerable Customer Policy
Play Music Today (PMT) is committed to ensuring that all customers are treated fairly and have equal access to the products and services we have to offer.
PMT’s approach to the treatment of vulnerable customers evolve in line with consumer and Regulatory demands. Treatment of vulnerable customers is supported through industry and regulatory guidance and covered within FCA principles. Further information can be found through the FCA site.
PMT must operate appropriate processes that consider the circumstances of our customers and to be able to recognise whether they are vulnerable (either permanently or temporarily) and tailor the way in which we communicate and deal with them to take account of the vulnerability.
Nobody is immune to being vulnerable. It can happen to anyone, at any stage of life and under a variety of circumstances. PMT understands that this can lead to situations where our customers may need a little extra help from us than our standard service, The main objective of our Vulnerable Customer policy is to outline PMT’s approach when dealing with vulnerable customers and how we ensure that any individual needs are considered.
Definition of vulnerable customer
Being vulnerable can mean different things to different people. It is often a result of personal circumstances that can lead an individual being less capable of making the best decision for themselves or less likely to get the best service.
Vulnerabilities aren’t always permanent. They can be short term, long term or even reappear. This could mean that support may be needed at some times, but not at others.
The Financial Conduct Authority’ (FCA) defines vulnerable customers as “Someone who, due to their personal circumstances, is especially susceptible to detriment, particularly when a firm is not acting with appropriate levels of care.”
The FCA consider that the following act as key drivers to actual or potential vulnerability:
- Health – any condition or illness that affects the ability to carry out daily tasks
- Life events – these events include bereavement, job loss or retirement
- Resilience – reduced ability to withstand financial or emotional shock
- Capability – low confidence and confidence in managing money or financial matters. This driver includes low capability in areas such as literacy and numeracy.
PMT’s approach to vulnerable customers
PMT has different approaches to ensuring that vulnerable customers are identified and handled appropriately, and this section details the processes and controls that are in place to protect customers.
Expectation of PMT Employees
To act in accordance with the requirements of this Policy, PMT employees are expected to:
- Be alert and ensure to understand what the customer advising, recognise triggers or clues to vulnerability
- Take time to understand the reasons behind any difficulties the customer may be facing, such as job loss, illness, divorce, or learning difficulties as this will help colleagues to understand what the best option or outcome for the customer is
- Set expectations clearly – it is useful to set expectations at the earliest possible stage
- Apply discretion or adapt the existing process where appropriate
- Speak clearly and if required slow down and be patient and empathetic
- Clarify understanding at trigger points by asking questions such as ‘is there anything else you would like me to repeat or explain?’
- Ensure there are no barriers to the appropriate and fair treatment of a customer.
- Where vulnerability is identified, this will be recorded accurately, sensitively and regularly reviewed for relevance.
This Policy acts in accordance with the Equality Act 2010, which provides it is illegal to discriminate and strengthens protection for specific protected characteristics. This means when a customer who has a disability is identified through PMT’s operational processes or service, reasonable steps must be taken to ensure they are treated equally, fairly and with respect.
PMT also acts in accordance with the requirements of General Data Protection Regulation (GDPR). In practice, this means that PMT employees are required to obtain explicit consent from the customer regarding the recording of information, including both medical data (the vulnerability) and the duration of any vulnerability, for example, whether the vulnerability is thought to be temporary or permanent. Employees are expected to ensure the recording of a vulnerability is accurate and reflective of the customers most recent circumstances.
PMT employees can record the interventions or adjustments requested by a customer rather than the vulnerability itself, in these instances, PMT employees are still required to obtain the customer’s consent before making a record.
We aim to continuously treat all customers as individuals. All PMT employees receive training to help identify vulnerable customers and to provide the additional level of support that may be required to meet their needs and achieve a great outcome. PMT provides annual mandatory e-learning training for colleagues one of which is a module on vulnerable customers which all colleagues must complete and pass each year.
To notify us of any particular needs please see our contact information on page 7. If we are informed of something that may make a customer vulnerable, we may securely record the information for future reference, if that is the right thing to do.
We will carefully plan how to deal with a vulnerable customer to ensure that everyone continues to receive the same fair treatment, and no one is disadvantaged. Each situation is different and will be treated carefully.
Any records that we do keep on vulnerability will be temporarily and will never been shared outside of PMT.
Third Party Relationships
Play Music Today work alongside V12 Retail Finance Limited to be able to offer competitive finance options to our customers both online and in our retail stores. We may need to alert third parties if we believe a customer may have, or is experiencing, a particular vulnerability which may affect their ability to enter into a credit agreement.
Please note, any finance agreements made between the following third parties and our customers are not associated with PMT.
To register as a vulnerable customer, to let us know about a personal circumstance which you think we should know about or to contact us with any questions, please reach out to us in one of the following ways:
Phone : 0151 448 2089 (Lines are open Monday – Saturday 9.30 am – 6.00 pm, Sunday 11:00 – 17:00)
Email : [email protected]
Online : Through our Customer Care Portal
In Writing : Customer Service, Play Music Today (PMT), 70-72 Evans Road, Speke, Merseyside L24 9PB