If financial vulnerability is to become a fundamental part of a business, and if a board is going to be able to make informed decisions on customer vulnerability, then all three of these parties need to work more closely together.
Not only this, but they will also need to embed cultural change from both the bottom up and indeed the top down around this important topic, so that everyone understands its significance.
And central to this will be data. All these groups need better reporting, greater visibility, and more robust processes around customer vulnerability.
Cutting-edge technology can help with this and will need to combine both digital and clinical insight to produce accessible and easy-to-use data points for businesses to better understand vulnerability, mitigate their business risks and better protect their clients.
And not only will better data ensure a more streamlined and robust process across these three key groups, it will also allow for a clear and consistent audit trail to assist a business in its regulatory requirements should the regulator come knocking.
On the topic of data and intelligence, it is important to consider what questions non-executive board members might ask – namely, how can you be sure you are identifying everyone in vulnerable circumstances; do you understand your client well enough to know what is required if they are found to be vulnerable; and where is the board report that will demonstrate this all?
In order for boards to establish good governance, these three powerful questions are fundamental.
Now is the time to switch the board onto the topic of customer vulnerability before it becomes too late. There is no scope to simply delegate this issue to another group, but rather a combined systematic process is required by all parties. This process should be wholly reliant on data and should be ingrained into the very culture of a company too.
Jonathan Barrett is chief executive and co-founder at Comentis