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Safeguarding Vulnerable Person’s


Car Call UK understands that as a business we will from time to time take telephone conversations with people who may find it difficult to make a decision about the choices we offer them in relation to the services that we provide.

This may be from customers who have been diagnosed with a condition such as dementia; those who have an undiagnosed or temporary mental health condition such as anxiety; those with learning difficulties or literacy issues; or those who have problems with a language barrier. We know these are only a few examples, but we as a company would see these situations as a Vulnerable Person.

Car Call UK ensures that the protection of vulnerable customers is handled extremely seriously and are committed from Senior Management level for the Company to do all it can to protect vulnerable customers.

Our Principles

A set of commonly agreed principles supports this policy. Such principles flow from respect for the rights of vulnerable adults who are entitled to:

  • Privacy

  • Be treated with respect and dignity

  • Lead an independent life and be enabled to do so

  • Be able to choose how to lead their lives

  • The protection of the law

  • Have their rights upheld regardless of ethnic origin, gender, sexuality, impairment or disability, age and religious or cultural background

  • Have the opportunity to fulfil personal aspirations and realise potential in all aspects of daily life

Identifying A Vulnerable Person

For us to address the needs of vulnerable customers correctly it is very important to be able to identify them. Some Risk factors can include bereavement, illiteracy, illness, disability or other impairment. In many cases more than one risk factor is present which increases the customer’s vulnerability.

All our employees at our Customer Service level are given training as part of the induction process to the company to be alert to the signs that the person they are talking to may not have the capacity, at that moment in time, to make an informed decision about the implications of the agreements that they are being asked to make. This is not a diagnosis of a condition; it is just an extension of the employees at our Customer Service level’s existing skill of listening, identifying needs, and adjusting their approach accordingly.

Customer Service staff should be alert for signs such as:

  • The customer asks them to speak up or speak more slowly
    - Can they hear the complete conversation or are they missing important bits?
    - Do they understand what is being said?

  • The customer appears confused
    - Do they know what is being discussed?
    - Do they ask unrelated questions?
    - Do they keep wandering off the point in the discussion and talking about irrelevancies or things that don’t make sense?
    - Do they keep repeating themselves?
    - Do they say ‘Yes’ in answer to a question when it is clear they haven’t listened or understood?

  • The customer taking a long time to get to the phone and sound flustered or out of breath, indicating they may have a lack of mobility due to age or illness

  • The customer taking a long time to answer questions. They say “My son/daughter/wife/husband deals with these things for me”

  • Where there is a language barrier the customer is vulnerable as they may not fully understand what is being said to them

  • The customer says that they don’t understand a previous phone conversation or recent correspondence

Our Principles

  • If any employees at Car Call UK are alerted to any of the above signs they will:

  • Speak clearly and enunciate

  • Set expectations for the call – outline all the information that will be required – account numbers, Personal details, etc – and how long the call is likely to last

  • Be patient / empathise

  • Not rush them – if they need to put the phone down to find any details

  • Guide the call to keep it ‘on topic’

  • Not assume they know what the customer needs

  • Clarify understanding at every point posing the question “is there anything you’d like me to explain?”

  • Offer alternatives to dealing with things by phone – i.e. by post or email

  • Not assume that the person they are talking to is sighted

  • Not assume that the person they are talking to can hear everything they are

  • Remember that vulnerable customers can sometimes be forgetful or overly trusting

  • Give the customer time to explain fully

  • Listen for what isn’t being said, not just what is

  • Ask if there is a better time to call – e.g. some people will function better in afternoons than mornings

  • Ask whether there is anyone else they need to talk to before making the decision

  • Record on the internal CRM system that the customer is ‘vulnerable’ to ensure all future communication with the customer is supportive and within our guidelines and recommendations

  • Record on the internal CRM system any preferred methods

External References Supporting this Policy

This policy has been written in conjunction with the following:

DMA (Direct Marketing Association) White Paper Guidelines for Call Centres dealing with vulnerable customers

  • Data Protection Act (DPA) 1998

Policy Review

This policy will be reviewed and updated annually in October each year and any amendments to the policy will be communicated to all employees across Car Call UK as well as being updated on the document portal on the internal intranet.