This page sets out our principles and minimum expectations for the services that water companies deliver to support residential customers in vulnerable circumstances. This is part of our Paying Fair Guidelines.
2. Make sure customers who are eligible for help receive it when it is needed
Companies should establish and implement clear and effective policies, procedures and systems and a helpful culture to identify customers in vulnerable circumstances, such as customers at risk of falling into debt and other life events such as financial abuse or a bereavement, and take proactive action to offer them support.
Use all reasonable efforts to predict and support customers at risk of falling into debt
2.1 Make efforts to predict where customers might be at risk of falling into debt, and proactively contact these customers with a support offer to help prevent this where possible. For example using data on redundancies in particular areas or a customer indicating they are rationing their water use to keep cost down. A support offer could include (for example only):
- checking account and billing information are correct;
- checking consumption for signs of leaks and (if relevant) offering a free supply pipe repair and signpost to the leakage allowance (as required by condition H of each water company’s licence);
- checking for eligibility for discounts for surface water drainage;
- targeted social tariffs;
- tailored water efficiency home visits;
- helping customers to do checks for financial and non-financial support provided by Government or others;
- emergency social tariffs (supported by, for example, application for certain benefits); and
- allowing customers to opt to receive reminder texts, e-mails or letters if they occasionally pay late).
2.2 Use targeted action and support that anticipates the needs of customers in vulnerable circumstances to help prevent them falling into debt. This should be based on:
- customer contacts and feedback; and
- customer insights from working with other external organisations – such as charities, local authorities, health and social care or other third party customer advice and authorised debt advice organisations.
Identify and support customers in vulnerable circumstances
2.3 Have specific policies, procedures and systems for proactively identifying and offering support packages for customers in vulnerable circumstances. These should:
- recognise the complexities of a customer’s vulnerability in providing them support: that it can be temporary or lasting, mild to severe, and can have a significant impact on daily life or a minimal one;
- be inclusive by design (see expectation 1.29); and
- make support easy to access.
2.4 Make sure their policies, procedures and systems reflect the latest definitions, best practice and guidance from relevant charities and other expert bodies in supporting customers in vulnerable circumstances. For example, water companies should consider:
- helping their staff understand and support customers with both mental health and debt problems – including incorporating it into their training and their processes for handling problem debt;
- offering specialised vulnerability training and/or have specialised teams to deal with customers with vulnerabilities; and
- designing proactive interventions that minimise psychological distress for customers with debt problems.
2.5 Make sure their policies, procedures and systems are compliant with all relevant legislation. This includes the Equality Act 2010 and the ‘The Debt Respite Scheme (Breathing Space Moratorium and Mental Health Crisis Moratorium) (England and Wales) Regulations 2020’.
Use data sharing arrangements to identify customers in vulnerable circumstances
2.6 Put in place and use data sharing arrangements with other bodies – for example, credit reference agencies, energy companies, charities or local authorities – to help identify people in vulnerable circumstances, including those at risk of falling into debt.
2.7 Make sure any data sharing arrangements meet high standards of ethical behaviour, rulings and code of practice guidance from the Information Commissioner’s Office (or equivalent document) and any legal requirements which apply at the relevant time.
Communicate effectively and sensitively with customers in vulnerable circumstances
2.8 Communication methods and timing should take account of any additional support requirements for those customers who are registered for priority services and for those who may need temporary support and should comply with the provisions of the Equality Act 2010.
2.9 Make communications available to customers in accessible formats which they are able to use. Companies should offer customers with sight impairments large print or Braille bills where appropriate so that they are able to read their bills and notices. This is in line with our guidance to companies on services to customers with disabilities.
2.10 Have systems in place so that customers who use British Sign Language, or do not speak English or Welsh, can communicate with the company.
2.11 Design specific communications and approaches for customers with communication difficulties
2.12 Design communications for people who struggle with literacy and numeracy.
2.13 Have options for supporting customers who are not able to access or use digital services.
Offer customers the option for their account to be managed by authorised third party individuals
2.14 Have an approach that protects customers from fraud while allowing properly authorised people or organisations – such as free, independent debt advisers – access to help operate accounts for people who need help managing their affairs. Companies should make customers aware of options for third party bill management. For customers who do not make their own decisions, companies can use our joint guidance with the Office of the Public Guardian and the UK Regulators Network on ‘Supporting customers who do not make their own decisions’ (or subsequent updates or an equivalent document). This is also relevant where companies are dealing with relatives or other parties that may need to manage a customer’s account in event of their sudden incapacitation or death.
Use approaches to debt management for customers in vulnerable circumstances that are appropriate to their circumstances
2.15 Tailor your debt management actions to be sensitive to the circumstances that make customers vulnerable.
2.16 Offer customers access to holistic debt advice to help them maximise their incomes, and make them aware of other forms of support they may be eligible for through Government or other service providers – particularly at the first indication that a customer is struggling to pay. This service can be provided by another organisation or third party that is authorised to give debt advice – and is provided that the customer gives their consent to be passed to this organisation or third party.
Make it easy for relatives to close or amend the accounts of a loved one who dies
2.17 Have a written plan that outlines how your company will treat bereaved customers with empathy and respect. For example, a written plan might include the following.
- Clear and simple advice on company websites on how to report a death.
- An agreed timeframe for companies to respond to bereavement enquiries and settle outstanding customer balances.
- A bereavement customer care team for each company, to directly handle such cases and avoid customers waiting on calls.
- A direct telephone, email address or other channel for bereaved customers to contact companies more directly.
- Standardising paperwork needed to close an account with other companies, with a view to accepting digital documents whenever possible.
- Guidance or other support for customers who may be dealing with managing a household for the first time.
2.18 Train people who come into contact with bereaved people to know how to respond efficiently and with understanding.
2.19 Streamline your processes and procedures to be simple, pragmatic and risk-based. Avoid unnecessary steps and repetition. We would expect a water company to take a more risk-tolerant approach to requiring evidence of a bereavement than, for example, a life insurance company.
2.20 Ensure any forms are easy to follow and only ask for information that is needed. Pass on details of where people can get practical and emotional support.
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