This document assists Adyen partners in identifying and assisting the marketplace\u2019s users who may be in vulnerable circumstances.<\/p>\n
Adyen recognizes that, due to personal circumstances, certain users may have or acquire traits of vulnerability throughout their lifetime. As a result, such users may require additional assistance to fully engage with the offered financial services and to ensure their needs are being met.<\/p>\n
In some countries where Adyen offers its financial services, Adyen is obliged by regulation to identify and assist vulnerable customers. To ensure these regulatory requirements are fulfilled, Adyen requires Platforms to adhere to certain processes concerning vulnerable customers, which are outlined in Adyen\u2019s compliance guidelines.<\/p>\n
This instruction document is an important component of Adyen\u2019s compliance guidelines. It provides practical, step-by-step guidance on how Platform staff should identify vulnerable customers and the procedures they should follow to ensure vulnerable customers receive the necessary assistance.<\/p>\n
Platforms are required to provide the following instructions to all members of staff who interact directly with users.<\/p>\n
This includes:<\/p>\n
Platforms must ensure all in-scope staff members read and fully understand these instructions. Staff should be encouraged to raise any queries. If there is any unclarity, Platforms should seek clarification from Adyen<\/strong>.<\/p>\n Agents should be encouraged to properly support the customer and be given all the additional time needed. Your organisation should also flag any support available for agents when they have been dealing with users who are in distress, as these situations can be stressful.<\/p>\n<\/div>\n Adyen applies the following definition for vulnerable users:<\/p>\n \u201cUsers who, due to their personal circumstances, are especially susceptible to harm, particularly when a firm is not acting with appropriate levels of care.\u201d<\/em><\/p>\n While all users are at risk of becoming vulnerable, the risk is increased by characteristics related to four key drivers<\/strong>:<\/p>\n Vulnerability is less likely in the B2B context than in retail financial services, but it can manifest for certain segments of Adyen's indirect customer base, particularly sole proprietors.<\/p>\n Indicative examples of merchants who may be prone to vulnerability include:<\/p>\n Vulnerability can be temporary. Merchants that do not exhibit signs of vulnerability one day may in fact experience it in the future, and vice versa. It is therefore important to routinely be on the lookout for signs of vulnerability.<\/p>\n<\/div>\n Greeting and Introduction: Begin every customer interaction with a warm and empathetic greeting. Introduce yourself and let the customer know you are here to help.<\/p>\n Indicators of Vulnerability: Pay close attention to the customer's tone, language, and emotional cues. Be alert for any of the following:<\/p>\n For identifying customers with potential mental capacity limitations, the BRUCE<\/strong> method can help identify difficulties with decision-making or limited ability to understand, remember, or \"weigh up\" information.<\/p>\n Use the TEXAS<\/strong> method to respond to a customer who has provided information indicating they need additional support.<\/p>\n Use the IDEA<\/strong> method when more information is needed about a customer\u2019s situation to take effective action.<\/p>\n If necessary, politely ask the customer for clarification about a condition or illness they mention. For example, \u201cI\u2019m really sorry, but I don\u2019t know very much about (name of condition), could you tell me a little more about it?\u201d<\/p>\n A general principle is that customers should only be required to share information about their vulnerability once. The details must be recorded so other staff members who interact with the customer can also meet their needs. The specific vulnerability indicator(s) identified or shared should be recorded using the tags below. A record must be attached to the customer\u2019s file.<\/p>\n Take detailed notes about the customer\u2019s situation, the support provided, and any follow-up actions. Make sure that you only record the facts shared with you by the user and do not include any proposed diagnoses or names of any specific conditions unless the customer has explicitly told you that they have that condition. Please also ensure that the notes are recorded in such a way that you would be comfortable with the customer or a third party reading that about themselves.<\/p>\n The following are examples of best practices for user interactions with staff.<\/p>\n The following are examples of unacceptable documentation for user interactions.<\/p>\nIdentifying vulnerable users<\/h2>\n
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\n \nDriver<\/th>\n Description<\/th>\n<\/tr>\n<\/thead>\n \n Health<\/td>\n Physical or mental health conditions that impact a customer's ability to manage their affairs.<\/td>\n<\/tr>\n \n Life Events<\/td>\n Significant life changes such as bereavement, job loss, or relationship breakdown that can affect resilience and decision-making.<\/td>\n<\/tr>\n \n Resilience<\/td>\n Low ability to withstand financial or emotional shocks (for example., tight margins, limited financial reserves).<\/td>\n<\/tr>\n \n Capability<\/td>\n Low levels of financial literacy, confidence in managing money, or other relevant skills such as digital literacy.<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n Vulnerability in a B2B Context<\/h3>\n
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Instructions for staff<\/h2>\n
Step 1: Initial Interaction<\/h3>\n
Step 2: Identifying Vulnerability<\/h3>\n
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\n \nAcronym<\/th>\n Focus Area<\/th>\n Question to Consider<\/th>\n<\/tr>\n<\/thead>\n \n B<\/td>\n Behaviour and talk<\/td>\n Is there a limitation in the customer\u2019s behaviour and speech?<\/td>\n<\/tr>\n \n R<\/td>\n Remembering<\/td>\n Is the customer experiencing problems with their memory or recall?<\/td>\n<\/tr>\n \n U<\/td>\n Understanding<\/td>\n Does the customer understand the information they are being given?<\/td>\n<\/tr>\n \n C<\/td>\n Confusion<\/td>\n Is the customer confused about the situation or options?<\/td>\n<\/tr>\n \n E<\/td>\n Evaluating<\/td>\n Can the customer \u201cweigh up\u201d the different options open to them?<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n Step 3: Providing Support<\/h3>\n
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\n \nAcronym<\/th>\n Action<\/th>\n Example Script<\/th>\n<\/tr>\n<\/thead>\n \n T<\/td>\n Thank<\/td>\n \u201cThanks for telling me about your situation, as it will help us take this into account.\u201d<\/td>\n<\/tr>\n \n E<\/td>\n Explain<\/td>\n \u201cLet me explain how we\u2019d like to use that information, just so you know.\u201d<\/td>\n<\/tr>\n \n X<\/td>\n Explicit Consent<\/td>\n \u201cAre you happy to give me permission to note down and save the information you\u2019ve shared with me today?\u201d<\/td>\n<\/tr>\n \n A<\/td>\n Ask<\/td>\n \u201cHow does your situation make it difficult to manage your finances?\u201d \"How does it affect your ability to communicate with us?\"<\/td>\n<\/tr>\n \n S<\/td>\n Signpost or Refer<\/td>\n Internally refer to a specialist team, or signpost to external help.<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n \n\n
\n \nAcronym<\/th>\n Action<\/th>\n Example Script<\/th>\n<\/tr>\n<\/thead>\n \n I<\/td>\n Impact<\/td>\n Ask about the impact of the circumstances on the customer\u2019s financial situation (what does it stop them doing or make more difficult?). For example, \u201cWhat has the impact been on your personal and financial situation?\u201d<\/td>\n<\/tr>\n \n D<\/td>\n Duration<\/td>\n Ask about the duration of the circumstances to help determine the time needed to consider options. For example, \u201cSo when did this first start to happen?\u201d<\/td>\n<\/tr>\n \n E<\/td>\n Experience<\/td>\n Understand the customer\u2019s experience of the vulnerability (one-off or recurring?). Take fluctuating situations (including medication effects) into account. For example, \u201cTo help me understand your situation better, can you tell me whether this has happened before?\u201d<\/td>\n<\/tr>\n \n A<\/td>\n Assistance<\/td>\n Establish what, if any, assistance the customer has received. This helps determine if you need to refer them for additional support from an external agency.<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n Tailor your support<\/h4>\n
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Offer Additional Assistance\/Signposting<\/h4>\n
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Step 4: Documenting the Interaction<\/h3>\n
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\n \nTag<\/th>\n Examples of conditions or experiences<\/th>\n<\/tr>\n<\/thead>\n \n Health\/Ability<\/td>\n Physical or mental health conditions that impact a customer's ability to manage their affairs. These may include: significant illness, health issues, or disability.<\/td>\n<\/tr>\n \n Life events<\/td>\n Significant life changes such as: bereavement, job loss, or relationship breakdown.<\/td>\n<\/tr>\n \n Resilience<\/td>\n Low ability to withstand financial or emotional shocks such as being in debt or living paycheck to paycheck.<\/td>\n<\/tr>\n \n Capability<\/td>\n Low levels of financial literacy, confidence in managing money, or other relevant skills, such as digital literacy.<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n \n\n
\n \nExample<\/th>\n Vulnerable circumstances tag<\/th>\n Follow-up\/support<\/th>\n<\/tr>\n<\/thead>\n \n Customer explained that they struggled to understand complex financial information and needed additional support in working through the terms and conditions.<\/td>\n Capability<\/td>\n Agent offered to spend time explaining terms and conditions (or any other aspect unclear to customer) in further detail. Agent added a note to the customer\u2019s file that additional care may be needed to ensure the customer understands all relevant financial information.<\/td>\n<\/tr>\n \n Customer appeared to have difficulty in understanding\/retaining relevant financial information.<\/td>\n Capability<\/td>\n Agent offered to spend time explaining terms and conditions (or any other aspect unclear to customer) in further detail. Agent added a note to the customer\u2019s file that additional care may be needed to ensure the customer understands all relevant financial information.<\/td>\n<\/tr>\n \n Customer shared that they suffer from hearing loss and requested that we only communicate with them via email and do not call them.<\/td>\n Health\/Ability<\/td>\n Agent added a note to the customer\u2019s file that all communications are to occur in writing and not via call.<\/td>\n<\/tr>\n \n Customer stated that they had recently suffered from a broken down boiler and they needed extra time to pay their fees.<\/td>\n Life events \/ Resilience<\/td>\n Agent offered to speak with the finance team and check if additional time to pay can be given.<\/td>\n<\/tr>\n \n Customer shared that their finances are tight following a relationship ending and they needed extra time to pay.<\/td>\n Life events \/ Resilience<\/td>\n Agent offered to speak with the finance team and check if additional time to pay can be given.<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n