Inclusive design: the next step for the vulnerability agenda
Our chief executive discusses how inclusive design can improve outcomes for vulnerable consumers
Posted January 29, 2021
Money Advice Trust chief executive and former chair of the Financial Services Vulnerability Taskforce, Joanna Elson CBE, discusses the role of inclusive design in improving outcomes for vulnerable consumers.
_“Firms may wish to use an inclusive design approach for … providing products and services that are available and accessible to all consumers equally, regardless of their personal circumstances” - _The FCA
The above quote, taken from the FCA’s draft Vulnerability Guidance (a final version of which is expected soon), is indicative of an increasing focus from essential services regulators on the concept of inclusive design. Others, including the CMA and Ofgem, have said similar, and there is growing recognition from firms that the way products and services are designed is critical in ensuring customers in vulnerable circumstances are treated fairly.
However, inclusive design isn’t always a well-understood concept. The principle of designing for all consumers, including people with additional or out-of-the-ordinary needs, is perhaps simple to articulate. Yet it can be more difficult to understand exactly what this means in practice. More so, it is understandable that firms, particularly those with numerous different products and services across different markets, might be daunted or unsure where to start.
These are legitimate questions, and ones that led us at the Money Advice Trust to partner with Fair By Design to explore what inclusive design means in the context of essential services, such as credit, insurance and energy. This week, we released two new, practical guides – one for firms and one for regulators - on inclusive design, which we hope will answer these questions and more.
Building on progress in the treatment of vulnerable customers
I want to applaud the progress made on improving support for customers in vulnerable circumstances in recent years. Firms have really stepped up, taking action to build their understanding, improve how vulnerability is identified and deliver more effective support to their customers, and I’m sure the clear focus from regulators has helped too. Through the Money Advice Trust’s work with creditors, we’ve supported over 265 firms and more than 22,000 frontline staff to improve outcomes for vulnerable customers.
However, it’s also right to keep challenging ourselves, as organisations and firms, to be better. Despite the good progress, it remains the case that all too often products and services that we all rely on have been designed to be ‘one size fits all’ – often leaving people in vulnerable circumstances worse off.
That this is still happening flies in the face of what we all know to be true: that any one of us could find ourselves in vulnerable circumstances, at any time. Inclusive design recognises this reality: telling us to start by talking to people with additional or out-of-the-ordinary needs, and involve them in designing solutions. Doing so not only helps these consumers but also leads to solutions that work better for all consumers too.
Embedding inclusive design
The hope is that, in time, the principles of inclusive design will become engrained in the heart of organisations’ culture. However, we know this takes time and there is no expectation that firms can transform their design processes overnight. Instead, the guide is focused on supporting firms to take the first step toward a more inclusive approach to designing products and services. It is deliberately focused on the practical, setting out activities that can be used to embed vulnerability and inclusivity into design processes.
The guide also highlights a number of good practice case studies. For, while talking about inclusive design specifically in the context of essential services might be relatively new, the principles of it aren’t – and there are good examples of firms using inclusive approaches already. Gambling blocks on debit cards, for example: initially designed to help those with gambling addictions, but in reality also benefitting customers worried about fraud. Another example, discussed in further detail in the guide, shows how an energy company worked directly with people on low incomes to develop a new solution to give people greater control over their energy costs and an easier way to understand exactly what they needed to spend to stay warm.
Taking the first step
At the Money Advice Trust and Fair By Design, we hope that the new guides will help firms – and regulators – to better understand inclusive design and maximise the opportunities to use this in their work. Whether you work in your firm’s vulnerability team, as a designer, or a senior leader, the guidance sets out how everyone has a role to play and aims to give them the tools to do it.
Inclusive design has the potential to transform the way markets, products and services work and to deliver significantly improved outcomes for people in vulnerable circumstances and those on low incomes – but only if it can be translated into practice. We hope the new guides will help firms and regulators to do exactly that, and we are excited to see the change it can bring about.
Find out more and download ‘Inclusive design in essential services: A practical guide for firms and suppliers’, as well as the guide for regulators here.
Joanna is chief executive of the Money Advice Trust. Previously, she was Executive Director at the British Bankers' Association and a Parliamentary researcher and prior to that, a primary school teacher. She has a CBE for services to people in debt. View all posts from Joanna Elson.
