"To provide quality data, a consistent method of measuring and recording the vulnerability is vital."
MorganAsh and Investor in Customers have partnered to provide firms with reports to meet the needs of Consumer Duty.
Investor in Customers already provides a suite of reports, assessing outcomes for firms, while the MorganAsh Resilience System (MARS) assesses, measures and reports on the vulnerability of consumers.
Under Consumer Duty, firms must report on outcomes for consumers – including how these affect vulnerable consumers. By incorporating vulnerability data from MARS, Investor in Customers can now correlate for consumers’ characteristics. This meets the evidence and reporting requirements of Consumer Duty for the four outcome areas and the cross-cutting rules.
The analysis includes the proportions of each characteristic at several layers of granularity and severity (for example, health – physical health – sight loss; and engagement capability – language issues – degree of language capability). This means that firms can understand how they perform for the numerous consumer characteristics and can then accurately target improvements, where required.
Details of any next steps which have been implemented can also be compared, to see if these have been effective in mitigating the potential harms identified.
MARS also enables firms to collate protected characteristics data on consumers. Protected characteristics are the list of characteristics specified within the Equalities Act 2010. Under Consumer Duty, firms are required to report on how they meet the Equalities Act. Using MARS, firms can now report on how their outcomes map across groups of similar protected characteristics – and if there any biases of concern.
James Edmonds, director at Investor in Customers, commented: “We can provide granular detail on the performance of companies across the numerous consumer characteristics – and on how mitigating strategies are being received by the customers. This is far more sophisticated than just comparing performance against the vulnerable and the resilient, an approach which will leave firms struggling to understand the cause of any underperformance.”
Andrew Gething, managing director of MorganAsh, added: “The most cost-effective way to provide data on vulnerability characteristics for outcome reporting is to collate data from individual vulnerability assessments. To provide quality data, a consistent method of measuring and recording the vulnerability is vital. Far too many organisations undertake subjective vulnerability assessments; these embed inconsistent data and are a nightmare to unscramble for firm-level outcome reporting.”
