Vulnerable Customers Policy

1. Who this applies to#

Anyone who self-discloses, or whom we identify in good faith as needing additional support. Self-disclosure is private and only used to deliver this policy.

2. What we adjust#

• Bill format (large print, audio, Braille on request, no time limits to read)
• Comms cadence and channel (e.g. SMS-only, or postal-only)
• Payment plan flexibility - including pause-and-resume
• Dedicated named contact, not a queue
• Zero outbound marketing
• Where appropriate, account-takeover protections (e.g. for domestic-abuse situations)

3. Our staff#

Care staff complete TSAT (Telecoms Sector Vulnerability) training annually, refreshed quarterly with case-study sessions. The Head of Customer Operations is the named owner.

4. Data handling#

Vulnerability data is special-category data under UK GDPR Art. 9 and is processed only on your explicit consent (Art. 9(2)(a)). It is held separately from marketing systems and never used for any other purpose.

5. Review & ownership#

Owner: Head of Customer Operations. Reviewed annually. Cross-references: Complaints, Billing, Accessibility.