Phil Deacon , Head of Claims , Guardian

Are all protection claimants vulnerable ? We think a reasonable interpretation of both Consumer Duty and related vulnerability requirements is that they are . Indeed , the regulations highlight what we ’ ve always known – that customers can be at their most vulnerable when they come to claim . The Duty now gives the sector an excellent opportunity to review and assess our approach .

We know every claimant is very likely to be exhibiting at least one and perhaps two of the characteristics of vulnerability , at least temporarily . For example , what constitutes someone being vulnerable – or potentially vulnerable – include health conditions or illnesses that affect the ability to carry out dayto-day tasks , and major life events such as bereavement or relationship breakdowns . A claim will certainly involve one of these and it could obviously involve both .

It ’ s worth saying that other characteristics of vulnerability , such as a lack of resilience to financial or emotional shocks , or lower capability such as low knowledge of financial matters and low confidence could also apply at claim , although perhaps more to surviving family members than most protection clients .

The Financial Conduct Authority ( FCA ) has placed the onus on firms to decide how they will implement the Duty across their business to reflect the principle , four outcomes and three cross-cutting rules . We believe – when thinking about claims – the consumer support outcome , with its emphasis on support for customers with characteristics of vulnerability , is the most relevant . This applies whether it is the policyholder themselves or their partner or other family members .

Delivering on our side of the bargain

So what measures are we taking to support our partners to be Duty compliant when looking at claims and the customer support outcome ? Looking at Guardian ’ s claims support specifically , our whole approach to HALO – which is our bespoke claims support service – is based on our belief that a claim is about much more than just a payout . It ’ s about helping individuals with whatever they need when they ’ re going through incredibly difficult times and are possibly at their most vulnerable .

This perspective applies with or without the regulation , but we believe this approach helps us meet the Consumer Duty requirements . HALO was designed to challenge the market norm because it is bespoke and personal , and our team are not confined to a set list of partners ; they can listen to the claimant and provide what they need . In other words , we designed the service to provide suitably enhanced support when people are vulnerable .

WHEN IT COMES TO HOW OUR TEAM DEALS WITH CLAIMS , OUR INTERNAL APPROACH INVOLVES LISTENING

When it comes to how our team deals with claims , our internal approach involves listening , using empathy , practising curiosity and avoiding judgement without sufficient knowledge , all of which are practices suited to supporting vulnerable customers .

Designed-in certainty and focus on outcomes

It is interesting that a poor claims process for terminal illness is one of the few specific mentions of protection in the Consumer Duty guidance . However , we believe our work around clarity helps avoid this kind of poor practice . That includes clear definitions , which provide certainty at claim .

20 | PROTECTION ADVISER | AUTUMN 2023 |