Common harms across essential services
Even though individual sectors have their own way of talking and thinking about harm, the experience of the person at the receiving end is often pretty consistent. Unexpected high bills or charges are rarely welcome. A refusal to communicate in the way a customer needs is poor service by any firm in any market. But a trick of history means that individual policies and practices within sectors mean that rules vary depending on the kind of essential service. In energy we even see rules on support for people varying depending on the size of the firm! This poses an issue in two ways. First, it means that individual sectors work in silos despite there being important good practice to share. Second, and to me even more importantly, it takes us into detailed rulebooks and their nuances and away from the lived experience of people who need essential services.
Talking about common harms is already prominent in debates at regulators, particularly the recent Financial Conduct Authorities work on treating customers fairly. But these focus on the circumstances of consumers — particularly those in vulnerable circumstances — themselves rather than the harms that could result. As Dr Fitch from Money Advice Trust would say — what are people vulnerable to? This is a crucial distinction because rules on action and inaction of firms care about the harm that is caused by their action. Of course, the action taken to identify and respond appropriately to someone’s circumstances is an important step. However, without an understanding of what consumers are vulnerable to, understanding harm will be, at best, partial. Importantly, failing to consider common harms can move discussions away from the support that could help or even help prevent harm.
So what are these common harms? And what kind of support might ameliorate them? I’m suggesting that there are four core common harms:
- Lack of access.
I’m talking about physical access here, infrastructure that is missing or has been removed. That might be the wires that ensure reliable access to the internet. Equally it might be a network of free to use cash machines. If the physical infrastructure of accessible essential services is missing, you will see harm.
2. Poor Communications.
Communications are core to how people interact with essential services firms. Communications which are misleading, confusing or simply incorrect will create barriers to interaction and cause a large array of problems. While clear communication is important for all, there also needs to be variation to reflect people’s needs. That might be bills in braille, telephone lines for people for whom english is a second language or webchat for people with anxiety thats exacerbated by interacting with firms.
3. Process persistence.
People’s lives change. People’s needs change. Processes that fail to incorporate an expectation that someone’s circumstances can change will lock in the prospect of harm. At the point of buying or applying for a product or service someone might be a digitally engaged single person. But will that product be ready for that person to have a baby? Move house to somewhere with wobbly broadband? Lose their job? People’s lives have a habit of including change — process persistence that rejects the reality of transient circumstances risk causing harm.
4. Unaffordable products.
Everyone needs essential services. The clue is in the name! But a growing number of people simply cannot afford the level of service they need for their health and wellbeing. In fact, people on lower incomes often pay more for an identical service. As you can probably imagine, many discussions with firms and regulators include a commentary of the role of government in ensuring incomes reflect costs. The fact remains however that unaffordable products can cause immeasurable harm, as can barriers for those who cannot access the lowest price products. Importantly, there ARE things that essential service firms can do to support their customers who struggle to pay for what they need — ensuring they have access to all the income support they are entitled to or ensuring they have the support of a charity that can help.
Although the table above picks some specific examples to call out, the overarching need for proactive identification of people’s diverse needs is consistent across all four areas to prevent harm. We know that the best way to reduce the risk of products, services and processes of causing harm is inclusive design of all of these so that cross-cuts too!
I’m sharing my thinking in the hope to hear yours — so what do you think?
I’m reading
Inclusive design in Essential Services
https://fairbydesign.com/inclusive-design/
I’m listening to
Vulnerability matters https://www.moneyadvicetrust.org/training-and-consultancy/vulnerability-resources/?
