PSA published a public consultation on vulnerability guidance in March 2016.
The proposed Guidance is intended to:
- Assist providers to interpret the Code and remain compliant with it
- Assist providers to proactively ensure they mitigate any risks of taking unfair advantage of vulnerable consumers
- Contribute to building trust in the market
- Define who is likely to be considered as vulnerable consumers by detailing some of the characteristics and circumstances that may lead to a situation of vulnerability
aimm Members worked extensively with Phone-paid Services Authority prior to the guidance being written to ensure that the Guidance was fair, pragmatic and provided information to providers to help manage risks. The risks identified were when vulnerable people used premium rate services and when marketing was targeted at a vulnerability (e.g. debt management) or a vulnerable group (e.g. children).
As a result of the pre-consultation work, very few comments were made by aimm in our consultation response.
