UK Vulnerability
The FCA Consumer Duty legally requires UK payment service providers to ensure that vulnerable customers achieve financial outcomes just as good as anyone else.
Payment providers have to proactively identify and support vulnerable customers, ensuring fair treatment and equitable outcomes for all customer groups.
PayPal was required to cater to customers by vulnerabilities, both financial and non-financial, as well as by their needs, objectives, and product or service type. This meant developing an experience where users could self-identify and report as having a certain kind of vulnerability and then get the needed help.
Business objectives
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Protect PayPal's right to operate in the UK by meeting FCA guidelines.
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Serve and support vulnerable customers with a thoughtful, user-centric experience.
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Allow customers to disclose vulnerabilities voluntarily and securely.
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Maintain secure, auditable, FCA-compliant records of disclosures.
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Link disclosed vulnerabilities to one or more recommended treatments.
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Generate summary reports mapping vulnerabilities to treatments.
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Allow PayPal support teams to view and, where necessary, edit disclosures.
My Guidance
My guidance on this project focused on the experience as a whole: how it begins for the user, how it unfolds progressively, and what language people can easily understand so they can make accurate disclosures. With empathy as our core value, we designed an experience that used everyday language and was accessible and easy to follow.
Foundational work - Understanding vulnerabilities
We considered a broad range of vulnerabilities while designing the experience for UK customers. These included temporary or permanent disability, long-term health issues, addictions, financial hardship, the impact of life events like bereavements or job loss, and other potential vulnerabilities. The team had to understand what treatments and help could be offered for different vulnerabilities.
Core data - Nearly 50% of adults in the UK have some form of vulnerability
Who is a vulnerable customer?
According to the FCA, a vulnerable customer is someone who, because of their personal circumstances, is especially susceptible to harm. Being vulnerable or going through challenging circumstances can lead to support needs. Customers may have impairments or disabilities, but that doesn't automatically make them vulnerable. Customers may also not show obvious vulnerabilities, but there could be hidden ones they're unaware of.
Experience Strategy
The FCA flagged PayPal as non-compliant in serving vulnerable UK users.
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Our role in the solution:
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Building a self-reporting experience for users to disclose vulnerabilities
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Connecting disclosures to treatments within PayPal products
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Powering reporting and dashboards for compliance and oversight
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Experience decisions
Our goal was to make the experience clean and easy for vulnerable users to disclose their issues.
The experience followed these principles -
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Clear entry point for anyone needing support
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Provide a guided experience, with self-serve tools and information that help users make informed decisions - Empathy being the core value
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Progressive sections detailing vulnerabilities and associated support options. Support is designed around diverse needs, making help-seeking safe and welcomed
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Clear, direct, and helpful messaging for users to understand and disclose their vulnerabilities
Discovery
The start of the experience was clear and action-oriented, so users could quickly understand that here's where they could get immediate help.
Choosing vulnerabilities and support
Reviewing support options
Once users had selected their vulnerability type, we displayed a review page that showcased their support options customized to the type of vulnerability they had disclosed. They could use these support options, take needed actions, and get the support they wanted.
They could also schedule customised check-ins offered by PayPal to assess their progress.
