ACCC Debt Collection Guideline Updates to vulnerable customers & what it means for your business.
At the end of last year, the ACCC updated the Debt Collection Guideline. It now includes further provisions and recommendations around training and policies to identify better and support vulnerable customers, such as those affected by family violence and mental illness. You can access the full document here: Debt collection guideline for collectors & creditors | ACCC.
Additional guidance on interactions with debtors experiencing family violence and having family violence is an example of why debtors may be unable to make substantial repayments or are otherwise vulnerable. There are also case studies to illustrate contact for a reasonable purpose, including family violence.
ACCC Debt Collection Guideline mentioned, “There is a need to develop robust compliance programs for identifying and dealing with vulnerable customers concerning mental illness and family violence”.
In addition, there is mention of vulnerable customers concerning mental illness and family violence in particular and the need to develop robust compliance programs for identifying and dealing with vulnerable customers.
If you haven’t already, you may want to consider the following:
- Do you have robust policies and processes in place to assist and protect customers that may be experiencing family violence, mental illness and other vulnerabilities?
- Does your process support the customer only telling their story once?
- Are your frontline teams aware of the financial impacts of family violence, mental illness and other vulnerabilities?
- Do your frontline teams know the red flags to look out for that may indicate a customer is experiencing family violence or mental illness?
- Do you have a list of external support services a customer can access should they require it?
- Are your staff properly supported to have these conversations with customers that may be experiencing these vulnerabilities?
- How do you handle staff disclosure of family violence? Do you have established training and processes to deal with this?
- Are your suppliers familiar with your approach, and do they reflect your policies in their dealings with your customers?
Please don’t hesitate to reach out if you require any assistance with navigating these updates, including drafting policies and/or improving soft conversational skills around better identification, service, and support of vulnerable customers.
Jodie Bedoya is Director of eMatrix Training, specialising in Collections & Vulnerability Training. eMatrix has valuable experience developing policy, processes, and training around these changes. They have assisted many industry sectors through a similar regulatory change to family violence and mental illness, including Banking & Finance, Energy, Water, Government, Insurance & Commercial. You can reach Jodie on 0438 391 500 or send us a message for further assistance.
