Overview - Vulnerable Customers

Contents

1. Vulnerable Customers
2. Regulatory Requirements
3. Support Person / Authorised User/ Power of Attorney (POA)/ State Trustee
4. National Relay Service
5. Translating and Interpreting Services
6. External Support for Vulnerable Customers
7. Resolving disputes

1. Vulnerable Customers

1.1 About Vulnerable Customers
1.2 Definition of Vulnerability
1.3 Identifying Vulnerability
1.4 Assessing Vulnerability
1.5 Supporting Vulnerability

1.1 About Vulnerable Customers

Vulnerability is defined as someone who, due to their personal circumstances, is especially susceptible to detriment. Vulnerable customers are more likely to experience harm and if harm occurs, the impact is much greater than for other customers.

A helpful way to think about vulnerability is to look at how the customer’s circumstances affect their decision-making or ability to engage with or use Foxtel’s products and services. It’s about returning some of the fairness and balance back to these interactions so we don’t take advantage of someone’s challenging personal situation.

1.2 Definition of Vulnerability

Vulnerable customer groups can include:

Intellectual and Psychological Disability

• Intellectual Disability (e.g. Down’s Syndrome, Fragile X Syndrome, Fetal Alcohol Syndrome)
• Mental Illness (e.g. Bipolar Disorder, Schizophrenia, Depression)
• Neurological Disorders (e.g. Cerebral Palsy, Dementia, Traumatic Brain Injury)

Physical and Sensory Disability

• Chronic or life threatening illness (e.g. Cystic Fibrosis, Cancer, ALS)
• Blindness or partial vision loss
• Deafness or partial hearing loss
• Elderly

Limited Language Capacity

• Non-English speaking background
• Illiteracy (being unable to read or write)
• Innumeracy (difficulty with numbers and basic maths)
• Learning Disability (e.g. dyslexia, dyscalculia)
• First Nations Australians
• Aboriginal
• Torres Strait Islander
• Living in a remote location
• Different cultural background

Traumatic Life Events

• Domestic/family violence
• Relationship breakdown
• Death of a loved one
• Suffering an accident
• Natural disasters

Financial Difficulties

• Low income
• Homelessness
• Financial stress/job loss
• Precarious work or high variable income

1.3 Identifying Vulnerability 

You must not rely on a consumer self-identifying as vulnerable. It’s important to pick-up on signs of vulnerability during a customer interaction so you can adjust your approach and support the customer’s needs.

Note: Identification of vulnerability should only be used to provide the customer with individualised support and flexibility, not to label the customer in any detrimental way.  

Intellectual and Psychological Disability
Customers with an intellectual disability may process information more slowly, find communication challenging and may also have difficulty with abstract concepts such as money or contracts. Customers with a mental illness or neurological disability may experience issues with cognition, emotional regulation or behaviour which can impact decision-making. Signs of vulnerability can include:

• Repetitive behaviour, becoming easily confused or being unable to stay on topic
• Agreeing with everything said, even when they don’t agree
• Over purchasing products that they cannot afford or that are not suitable or needed
• Displaying confusion or agitative behaviour

Physical and Sensory Disability
Customers with a physical disability may have limitations in mobility, stamina or dexterity which can be acquired (injury), congenital (from birth), due to illness or older age. Customers with sensory impairment may be blind or deaf requiring assistive technology to navigate the world. Signs of vulnerability can include:

• Being unable to physically install or troubleshoot Foxtel equipment without additional support
• Relying on chat services if they are deaf or unable to communicate over the phone
• Using communication support like the National Relay Service
• Elderly customers who may find it difficult to understand new technology

Limited Language Capacity
Customers experiencing illiteracy, innumeracy or have English as a second language may have a limited language capacity. Illiteracy and innumeracy impacts a person’s ability to read, write or understand numbers. Customers who have English as a second language may also find it difficult to articulate their needs and understand complex information. Signs of vulnerability can include:

• Being unable to read, write or understand numbers
• Inability to follow, understand or becoming easily confused by complex discussions
• Relying on Translating & Interpreting Services to communicate
• Inability to structure sentences in a clear way without syntax errors

First Nations Australians
First Nations or Indigenous Australians are at risk of vulnerability due to differing social norms, systemic discrimination and inequality. First Nations Australians may not fully understand contracts and are particularly susceptible to pressured sales tactics, agreeing to contracts because they believe they have no other alternative. Signs of vulnerability can include:

• Agreeing out of politeness, even when the customer does not understand or agree
• Not having a complete understanding of the long-term impacts of contracts or agreements
• Having limited exposure to commercial transactions
• Difficulty weighing up the information given against alternative options

Traumatic Life Events
Customers who are experiencing a traumatic or significant life event may be more likely to experience vulnerability due to heightened levels of stress. This can include customers impacted by domestic violence, relationship breakdown, death of a loved one or a natural disaster. Signs of vulnerability can include:

• Residing in temporary accommodation, shelter or a halfway house
• Indicating they’re unsafe or have fled their home
• May have lost all their possessions or belongings
• May be distressed or in a heightened emotional state

Financial Hardship
Customers may experience financial hardship as a result of having a low income, loss of income or experiencing complete job loss. The impacts of financial hardship may extend into homelessness. Signs of vulnerability can include:

• Not having enough money to pay for food, rent or medicine
• Residing in temporary accommodation, living in their car or couch surfing
• Experiencing unexpected job loss as a result of redundancy or sudden illness/injury
• May not have any income or planned savings to pay for expenses during sudden financial change

Not every customer who is vulnerable needs additional support from Foxtel. Vulnerable customers requiring additional support will typically share their circumstances with you during an interaction.

1.4 Assessing Vulnerability 

When a customer shares intimate personal information with you, it’s important to make a connection with that customer and display empathy towards the situation they’re facing. Reassure the customer that you are there to support and find a solution that meets their needs.

Once we have identified a potential vulnerable customer, we need to assess how we can support that customer and recognise when we are at risk of contributing to further vulnerability. Don’t assume that you know what a vulnerable customer needs, they will typically tell you what kind of support they need or you can ask the customer to guide you. Below are some questions you can ask to assess the customer’s needs:

• How can I best support you with this request?
• What can I do to make this situation easier for you?
• How can I make this an effortless experience?
• I want to find a solution that fits your needs, how can I help facilitate this?

Note: We should ensure that we balance the need for sufficient information to help the customer with their enquiry, without prying into unrelated areas of a customer’s personal life.

1.5 Supporting Vulnerability 

Supporting a vulnerable customer requires compassion, patience and thinking outside the box. The support we provide should be flexible and may fall outside our usual processes. The customer should walk away feeling that Foxtel has helped facilitate a tailored solution that meets their individual needs.

When providing information to a vulnerable customer, it’s imperative that we take time to clarify important information, give the customer space to ask questions or give the customer an opportunity to seek external consultation from their own support networks before a decision is made. Take time to summarise all points to ensure the customer has a full understanding of the conversation that has taken place, the resolution you’ve provided and the next steps. At the end of the interaction, we should clarify whether the customer needs us to explain or go over anything else. Below are some examples on how we can support vulnerable customers.
Selling and Contracts:

• Communicate in plain English, avoid using jargon, acronyms or technical terms
• Assess the suitability and affordability of the product you're selling to make sure sure the customer isn't buying products they do not need or cannot afford
• Ensure the customer understands what they are agreeing to and the ongoing costs by going over important information
• Don't push the customer to complete a sale, give them time to think things through or seek external support
• If you don't believe the customer can understand the agreement they're entering into, encourage the use of a support person
• Refer the customer to our website information so they can read product information in their own time
• If the customer indicates another person takes care of their financial decisions, you must not sell to the customer and instead encourage the use of a support person.

Installation:

Offer to send a technician for SIK/DIY if the customer cannot physically install a box. 

Process:

• Escalate the customer scenario with your team leader for assessment and approval
• Team leader to send a request to [e-mail] including the below information:
• Subject: Site Request - Customer’s name and account number
• Customer name
• Account
• Address
• Brief explanation of need
• CIT note to be documented on the account

Billing:

• Take time to breakdown the bills in detail and discuss each itemised charge
• Ensure the customer has a copy of the bill in front of them so they can follow along
• Ask questions along the way to ensure the customer has a complete understanding
• Explain when the bill is due and how payments can be made
• Raise a financial hardship request  if the customer is struggling to pay their bills
• If the customer is experiencing domestic violence, follow Foxtel's Domestic Violence policy.

Collections:

• Provide flexible ways to pay for the Foxtel service or follow Foxtel's financial hardship processes.
• Refrain from asking a customer to pay for their Foxtel services when they cannot afford food, medication or rent as these basic living needs come first.

• Identify where Foxtel may have contributed to hardship and address any issues identified (e.g. sales agent has taken advantage of a vulnerable customer leading to debt accrual), reporting incidents in the Compliance SharePoint.

TV Faults:

• Help the customer setup Foxtel Go so they can continue to enjoy their Foxtel service while a TV fault is being repaired
• If the customer is elderly or has a physical disability, ensure you’re not insisting on the customer completing troubleshooting steps they are unable to physically perform as it could cause serious injury
• Ask if there are any friends or family around that can support with troubleshooting
• If a deaf customer relies on Closed Captions & is unable to access closed captions due to a fault, offer to credit downtime as this equates to a full loss of service for a customer with a sensory disability
• If the customer is overwhelmed by new technology, patiently walk the customer through how to navigate their new box to watch & record shows as well as accessing OnDemand content.
• Offer to send a Customer service call at no cost if the fault cannot be resolved over the phone by following the below process:
  • Escalate the customer scenario with your team leader for assessment and approval
  • Team leader to send a request to [e-mail] including the below information:
  • Subject: Site Request - Customer’s name and account number
  • Customer name
  • Account
  • Address
  • Brief explanation of need
  • CIT note to be documented on the account

Broadband and Home Phone Faults:

• If the customer is elderly or has a physical disability, ensure you’re not insisting on the customer completing troubleshooting steps they are unable to physically perform
• Escalate Home Phone faults to the Level 2 Technical Team if the customer is unable to resolve their fault on first contact
• The Level 2 Technical Team should escalate the customer’s fault through Foxtel’s wholesale provider, clearly communicating the urgency due to the customer’s vulnerability
• Offer an interim mobile solution until the service can be fixed
• If the customer requires Priority Assistance, advise the customer that Foxtel does not offer Priority Assistance, they should be encouraged to move their service to Telstra to ensure they can receive fast connection & fault repair

Disconnection:

• If a customer is disconnecting as a result of a traumatic life event (domestic violence, natural disaster or domestic violence), do not transfer the call to Retention
• If a vulnerable customer did not understand the original agreement they made with Foxtel they should be released them from contract without penalty
• If a customer wishes to disconnect their service via chat as a result of being deaf, ensure you accommodate this request
• Inform the customer of our equipment pick-up process and how they can arrange this type of request
• If the account holder has passed away, follow the deceased estates process in FoxHow
• Waive equipment return where a customer has been displaced from their home due to domestic violence or natural disaster & can no longer access the Foxtel equipment.

2. Regulatory Requirements

2.1 ACMA Consumer Vulnerability Statement of Expectations
2.2 ACCC Don't Take Advantage of Disadvantage

Foxtel is required to comply with a number of regulatory requirements relating to vulnerable and disadvantaged customers.

2.1 ACMA Consumer Vulnerability Statement of Expectations

In June 2022, the ACMA introduced the Consumer Vulnerability Statement of Expectations (CVSE). The purpose of the CVSE was to openly recognise the importance of having telecommunications processes and practices that service the needs of customers experiencing vulnerability.

2.2 ACCC Don't Take Advantage of Disadvantage

Foxtel is also required to comply with the ACCC Guidelines Don't Take Advantage of Disadvantage which was designed to help businesses recognise when they are dealing with a disadvantaged or vulnerable customer, ensuring they are treated fairly and not taken advantage of.

3.Support Person / Authorised User/ Power of Attorney (POA) / State Trustee

3.1 Involving a Support Person
3.2 Authorised Users
3.3 Power of Attorney
3.4 State Trustee
3.5 Multi-factor authentication 

 

3.1 Involving a Support Person

If during an interaction with a vulnerable customer, they are finding it difficult to communicate or understand the interaction and you do not believe the customer can make an informed decision, you should ask whether the customer has a family member, friend or support person that can assist. Here are some ways you can recommend the involvement of a support person:

• I want to make sure you fully understand what we’ve discussed today, do you have a friend or family member that can help us with this?
• I want to make sure this decision is right for you, is there a friend or family member that we could include in this conversation?
• I can add an authorised representative on your account, like a friend or family member in case you’d like some additional help with your Foxtel account

If the customer insists on proceeding anyway or they do not wish to use a support person, it’s important to give the customer the right to exercise their own decision-making. If you decline to assist the customer when they have expressed a desire to make their own independent decisions, you may be inadvertently discriminating against the customer. However, it’s crucial that the customer leaves the conversation feeling fully informed so take the time to explain important information in detail to ensure a complete understanding.

3.2 Authorised Users

Rules in the TCP (Telecommunications Consumer Protections) Code state that we must ensure that all customers are aware that they can appoint an authorised user to act on their behalf. 
Customers who wish to nominate an authorised user to speak on their behalf must notify Foxtel either via phone or in writing. See Procedure - add or remove authorised contact. for information on adding an authorised user to an account.

Important: You cannot speak with another person about the customer's account unless the customer has given permission.

3.3 Power of Attorney

A Power of Attorney (POA) gives an individual the authority to act for another person and make personal and/or financial decisions on their behalf. The POA also has the ability to act as the account holder on a Foxtel account. This means that the POA would have the authority to add another authorised user on the account, or disconnect the account.
For the POA to be recognised on the account, they need to provide the authorisation documents via an email to [e-mail]. The caller will be contacted within 5-10 business days via either email or phone.

Authorisation documents
The authorisation documents include a copy of their Power of Attorney documents for the account holder. This needs to have both the account holder's name and the POA's name and signatures on the form to prove that the account holder has appointed the POA to act on their behalf.

3.4 State Trustee

Sometimes people need help with their financial & legal affairs. The State Trustee is a government organisation that can step in when a customer can no longer manage their own finances because of disability, illness or injury. The State Trustee may be appointed by a court initiated by a family member, friend or carer when a customer is not able to manage their finances on their own. For more information on how to handle a State Trustee call please refer to Overview - Foxtel account types.

3.5 Multi-factor Authentication

You will be required to multi-factor authenticate on all customer accounts with Broadband and Home Phone services in Zendesk. If you are speaking with a customer who is vulnerable, they may be eligible for an override of authentication. Make sure you are leaving detailed override notes whenever this is completed. 

View the overview article here: Overview - Multi-Factor Authentication.

4. National Relay Service (NRS)

4.1 About the National Relay Service (NRS)
4.2 NRS services
4.3 Handling NRS calls 
4.4 Contact information for the NRS

4.1 About the National Relay Service (NRS)

The NRS (National Relay Service) is an Australia-wide phone service for people who are deaf or have a hearing or speech impairment. The NRS is also available to anyone who wants to call a person with a hearing or speech impairment. 
 
The service allows people to communicate 24/7 via a relay officer - a government employee who is the link between 2 phone users. Customers may potentially contact us via the NRS if they are unable to communicate directly to Foxtel.

Note: The NRS is available to everyone at no additional charge. 

How it works
The customer will communicate their needs to a relay officer using either a:

• computer
• tablet
• mobile phone
• landline
• Teletypewriter (TTY), a special phone with a small keyboard and screen.

4.2 NRS services

The NRS (National Relay Service) offers the following services. 
Internet relay
Internet relay involves the customer typing the conversation on their computer, laptop or internet-enabled mobile device. The relay officer will then read the customer's questions to you, and type your responses back to the customer.
 
Captioned relay
Captioned relay involves a 3-way chat with both the customer and relay officer present on the phone call. The customer can hear what you are saying but requires assistance from the relay officer to understand what you are saying. The relay officer will type what you say to the customer.
 
SMS relay
SMS relay involves the customer text messaging the relay officer, who will then read the text message to you. The relay officer will then send a text message to the customer with your response.
 
Video relay
Video relay involves the customer connecting to the relay officer via a video conference. The customer will use sign language and the relay office will say what the customer is signing. You will talk with the relay officer, who will sign your response back to the customer.
 
Teletypewriter (TTY)
A TTY (teletypewriter) is a special type of phone. The customer types a message onto the TTY phone, which the relay officer reads to you. The relay officer types back your response to the customer on the TTY phone.
 
Speak and Read
Speak and Read is used by customers who can speak on the phone, but cannot hear. The customer speaks directly to you, but the relay officer types your responses back to the customer.
 
Type and Listen
Type and Listen is for customers who can hear, but have trouble speaking on the phone. The customer can hear what you are saying, but will type their responses to the relay officer, who will then read them to you.
 
Speak and Listen
Speak and Listen is for customers who can use their own voice but may find it hard to understand on the phone. The customer will talk directly to you, but the relay officer will listen and re-speak part or all of what the customer says if there are any misunderstandings.

4.3 Handling NRS calls

When you receive an NRS (National Relay Service) call, it will come through as a normal call. The relay officer will advise you at the beginning of the call that it is an NRS call. A relay officer is a third party aimed at allowing you and the customer to communicate with each other.

Important: All call compliance and ID processes still apply to NRS calls.

The relay officer will help you and the customer communicate in line with the customer's special needs. 

Note: The relay officer is a neutral party and will not participate in any discussion. 
When taking an NRS call, you should:

• speak clearly to make your responses easy to communicate
• provide the best possible experience for the customer -  no need to focus on AHT (Average Handling Time)
• pause at the end of each sentence, as this gives the relay officer time to communicate what you are saying
• say 'Go Ahead' after each response, which indicates to the relay officer that you have finished with your sentence, statement or explanation
• repeat and spell difficult words, names or numbers
• stick to only 1 topic at a time
• follow call quality as closely as possible, but if the call becomes difficult, there is no expectation to tick the quality boxes - focus on the customer experience.

4.4 Contact information for the NRS

General contact details

Contact	Number
Internet relay	Make an internet relay call now and ask for 1800 555 660
Voice	1800 555 660
TTY	1800 555 630
SMS	0416 001 350
Fax	1800 555 690
Email	[e-mail]
Mail	Level 2, 10 Mallett Street Camperdown NSW 2050
Website	www.relayservice.gov.au

Contact details for NRS users

TTY users (Speak and Read, Type and Read, Type and Listen)
Standard and overseas calls	133 677
1800 calls	1800 555 677
Emergency calls	106

Speak and Listen users
Standard and overseas calls	1300 555 727
1800 calls	1800 555 727
Emergency calls	1800 555 727 and ask for triple zero (000)

Internet relay users
All calls	internet-relay.nrscall.gov.au/
Emergency calls	internet-relay.nrscall.gov.au/ and ask for triple zero (000)

SMS relay users
All calls	0423 677 767
Emergency calls	0423 677 767 and ask for triple zero (000)

5. Translating and Interpreting Service (TIS)

5.1 About the Translating and Interpreting Service (TIS)
5.2 Handling TIS calls

5.1 About the Translating and Interpreting Service (TIS)

The TIS (Translating and Interpreting Service) provides language services in Australia. TIS is an Australian government initiative from the Department of Home Affairs that offers a translating and interpreting service for non-English speakers. TIS provides access to phone and on-site interpreting services in over 160 different languages. This allows non-English speakers to independently access services and information in Australia.
 
Contact the TIS
Customers can contact the TIS by calling 131 450 (within Australia), or [phone] (outside Australia). 
Note: Any cost of using the TIS are at the customer's expense. 
 
For more information, see www.tisnational.gov.au.

5.2 Handling TIS calls

When you receive a TIS (Translating and Interpreting Service) call, it will come through as a normal call. The interpreter will advise you at the beginning of the call that it is a TIS call.
Important: All call compliance and ID processes still apply to TIS calls.
 
The interpreter will communicate your response(s) to the customer, the customer will then type communicate back to the interpreter, who will communicate the response with you.
Note: The interpreter is a neutral party and will not participate in any discussion.
 
When taking a TIS call, you should:

• speak clearly to make your responses easy to communicate
• provide the best possible experience for the customer, no need to focus on AHT (Average Handling Time)
• pause at the end of each sentence, as this gives the relay officer time to communicate what you are saying
• say 'Go Ahead' after each response, which indicates to the interpreter that you have finished with your sentence, statement or explanation
• repeat and spell difficult words, names or numbers
• stick to only 1 topic at a time
• follow call quality as closely as possible, but if the call becomes difficult, there is no expectation to tick the quality boxes - focus on the customer experience.

6. External support for vulnerable customers

The following services can support vulnerable customers with external, impartial consumer advice and/or financial counselling services. This information can be shared with vulnerable customers to provide additional support:

First Nations Support
The Indigenous Consumer Assistance Network (ICAN) provides consumer advocacy and financial counselling services to First Nations consumers across Australia.
Website: https://ican.org.au/
Phone: [phone]

Financial Counselling
Customers experiencing financial hardship can access free financial counselling by contacting the National Debt Helpline.
Website: https://ndh.org.au/
Phone: [phone]

Mental Health Support
Head to Health is a government initiative that helps connect people to mental health services from some of Australia’s most trusted mental health organisations.
Website: https://www.headtohealth.gov.au/

Disability Consumer Support
The Australian Competition & Consumer Commission can provide information about consumer rights and have a number of factsheets to support disabled customers with navigating consumer products & services.
Website: https://www.accc.gov.au/
Phone: [phone] 

Reading Writing Hotline
The Reading Writing Hotline is a free national referral service for adults needing help with reading, writing or basic maths.
Website: https://www.readingwritinghotline.edu.au/
Phone: [phone]

Domestic Violence Support
The National Family & Domestic Violence Counselling Line is available for any Australian who has experienced or is at risk of family or domestic violence. Services are available 24 hours a day, 7 days a week.
Website: https://www.respect.gov.au/
Phone: 1800 RESPECT

Grief Support
The Australian Centre for Grief & Bereavement is an independent, not for profit organisation, available to support customers with bereavement & grieving support.
Website: https://www.grief.org.au/
Phone: [phone]

7. Resolving disputes

In the unlikely event that a vulnerable customer has been mistreated or has been taken advantage of by a Foxtel employee, it’s important that we escalate the complaint to the Foxtel Executive & Regulatory Complaints Team under the Procedure - raise a severity 1 complaint.

The Executive & Regulatory Complaints Team will investigate how the incident occurred and resolve the customer’s complaint, returning the customer to the position they were in before the incident took place.