Vulnerable Customers Policy

Lifetime Training is committed to identifying, assessing and managing vulnerable customers in accordance with our defined objectives and procedures, as well as any regulations and guidelines set out by our regulators. We aim to treat all customers, who we define as being vulnerable, in a fair, clear and respectful manner.

We have implemented a number of identification and assessment tools and a vulnerable customer's policy to ensure that staff are aware of and knowledgeable about vulnerable customer's policy to ensure that staff are aware of and knowledgeable about vulnerable customers, including how to handle certain situations. We have also included external guidance in our procedures and information as provided by the Money Advice Liaison Group (MALG).


The purpose of this policy is to identify and support vulnerable customers and to promote transparency and openness in all business practices and processes that Lifetime Training and its staff, create and engage in.

Our staff are provided with training on what makes a customer vulnerable and how to identify, assess and deal with any vulnerability. We are committed to ensuring that any customer  who has a relationship with our company, is treated in a fair, reasonable and supportive manner.


The policy relates to all staff (meaning permanent, fixed term, and temporary staff, any third party representatives or sub-contractors, agency workers, volunteers, interns and agents engaged with Lifetime Training in the UK) within Lifetime and has been created to ensure that staff deal with the area that this policy relates to in accordance with legal, regulatory, contractual and business expectations and requirements. 


The 2 main definitions of a vulnerable customers as used by Lifetime Training are:

a. Customers who are unable, for whatever reason, to make an informed decision at the time of dealing with them – customers falling into this category include those with language barriers, hearing difficulties, those with mental health issues, suffering from bereavement, learning difficulties or the elderly. These customers may struggle to make a decision on whether the service or product Lifetime is providing is in their best interests.

b. Customers whose welfare (financial, mental or physical) could be put at risk through choosing the service or product Lifetime offers – these customers include anyone who is going to be put at detriment from taking up our offer. This could be financially if taking out a loan or setting up a payment plan causes them added financial stress.



The new starter induction includes a training module designed specifically to introduce and explain the meaning and reasons for a Vulnerable Customers ethos within the industry and Lifetime Training.

There is a 12-weekly, rolling training programme which is provided to all existing staff which reminds and updates them on the requirements, guidelines and company ethos of Vulnerable Customers.

Lifetime Training is committed to ongoing professional development. Communication with customers will be monitored for compliance with the Vulnerable Customer policy. Employees will receive 1:1 feedback and coaching, and workshops around the ethos of Vulnerable Customers.

Audits and Monitoring

Lifetime Training carries out regular internal audits and gap analysis monitoring in all business practices and procedures to ensure that the Vulnerable Customers policy and ethos is still at its core. Regular reviews of the audit results are held with senior management and an ongoing record of gaps, actions and improvements is maintained.

Identification & Interaction

Lifetime Training aims to identify vulnerable customers at an early stage to ensure that we provide the correct level of assistance during all interactions and provided services. Staff in a position to interact with customers, whether face to face, verbally, electronically or via written communication; will have received full vulnerable customers training and support aids in addition to being monitored and tested for competence on a rolling basis.

All customers are asked to provide details of any particular needs or problems to enable us to tailor our service to meet those needs. We have a Safeguarding Officer who will provide support and advice to both in-house staff and to vulnerable and disadvantaged customers based on their detailed knowledge of mental health issues and vulnerable customer requirements.

Our  interaction and sales based methods may be altered and usual deadlines extended where a customer has been deemed to be vulnerable, but where our service is still being provided. Such alterations may include (but are not limited to): -

  • Sending all verbal correspondence out in duplicate via post (Large Print or Braille)
  • Dealing with an authorised 3rd party (Language or Hearing Issues)

Debt and Mental Health

Mental health is one of the most common issues that can result in a customer being vulnerable. Lifetime Lifetime Training provides thorough staff training and support to identify and deal with customers who have declared or meet the criteria for having mental health problems.

This policy follows the guidance set out by the Royal College of Psychiatrists and Money Advice Liaisons Group (MALG) on debt and mental health. In cases where more information is required regarding how a customer’s mental health condition affects their ability to manage debt, Lifetime Training uses the Debt and Mental Health Evidence Form (DMHEF) containing the 7 standard questions below. The form is to be completed by a health or social-care professional and at the consent of the customer.

1. Does the person have a mental health problem?

2. Does the person have a mental health problem that currently affects their ability to deal with money?
a. Does this mental health problem have a name?
b. How does this mental health problem affect the person’s ability to deal with money?

3. What was the approximate date of the: -
a. First onset of this mental health problem
b. First treatment given for this
c. Most recent episode of this mental health problem
d. Is this episode currently ongoing?

4. If the person is receiving treatment or support for this mental health problem, is there any aspect of this that affects their ability to manage money?

5. Are there any other relevant impacts/effects that the person may experience in their everyday life due to their mental health problem? 
a. What other relevant effects are there?

6. Does the person have any difficulties with communication due to their mental health problem?

7. Can the information provided in this form be shared with the person it is about?

Lifetime Training follows the Codes of Practice relating to the collection of medical evidence about mental health conditions and always aims to: -

  • Take steps to establish whether the mental health problem affects the customers’ ability to manage money or their debt.
  • Work with the customer in a patient, clear and helpful manner to resolve the debt problems and use workable solutions
  • Provide reasonable periods of time for the customer to provide evidence of any mental health condition and place accounts on hold during this period.
  • Prevent any interest and/or charges from being added to the account during the consultation period.
  • Work with authorised 3rd parties to help the customer resolve their debt issues.]


Lifetime Training will ensure that all staff are provided with the time, resources and support to learn, understand and implement the Vulnerable Customers policy into their business practices. Senior Management are responsible for a top down approach and in ensuring that all staff are included. 

The Safeguarding Champion and Senior Management/Directors are responsible for Vulnerable Customer audits and gap analysis monitoring and their subsequent reviews and action follow ups. There is a continuous audit trail of all Vulnerable Customer audits and feedback to ensure continuity through each process and task.