Vulnerable Clients Policy

A vulnerable client is someone whose personal circumstances make them especially susceptible to harm or disadvantage if a business does not act with appropriate care. Vulnerability may be temporary, permanent, visible or hidden, and it may change over time.

Being vulnerable does not prevent a person from applying for finance. It means that we may need to adapt how we communicate or provide support.

Vulnerability can arise from one circumstance or a combination of circumstances, including:

• Physical or mental-health conditions, disability, cognitive impairment or sensory needs;
• Bereavement, relationship breakdown, redundancy, job loss or another major life event;
• Low or unstable income, debt, financial shock or limited financial resilience;
• Limited financial understanding, literacy, numeracy, digital confidence or language proficiency;
• Domestic or financial abuse, coercion, dependency or reduced ability to act independently; and
• Any situation affecting a person’s ability to understand information, weigh options or communicate a decision.

Our staff will remain alert to signs that a client may need additional support and will respond respectfully, without making assumptions. We may ask suitable questions to understand the client’s needs and will record only information that is relevant and necessary.

Clients are encouraged to tell us about any support or adjustment that would help them.

Depending on the client’s needs, we may offer:

• More time to consider information or make a decision;
• Clearer explanations without unnecessary jargon;
• Information in large print or another accessible format;
• Communication by telephone, email, video call or an office appointment;
• Portuguese-language support where available;
• Appropriate breaks or a follow-up appointment; and
• Involvement of an authorised representative or support person.

We will discuss the most suitable option with the client rather than automatically requiring a face-to-face meeting.

Yes. A client may ask an authorised representative, attorney, family member, advocate or trusted person to support them, subject to appropriate authority, identity and confidentiality checks.

Unless a valid legal authority permits the representative to decide on the client’s behalf, we will continue to seek the client’s own instructions and consent.

Health and certain vulnerability information may be special-category personal data. We will collect only what is necessary, limit access to people who need it and handle it in accordance with our Privacy and Cookie Policy and the Data Protection (Jersey) Law 2018.

Where sharing vulnerability information with a lender or another party would help provide suitable support, we will explain what information is proposed to be shared, with whom and why.

Where explicit consent is the appropriate legal basis, we will obtain and record that consent before sharing. Disclosure of vulnerability by itself is not treated as blanket consent for all sharing. We may share without consent only where another lawful basis permits or requires it.

A client can withdraw consent for future consent-based sharing by contacting us. Withdrawal does not make earlier lawful processing invalid, but it may limit the adjustments, application support or services that Versus Finance or a provider can offer.

The relevant lender or finance provider makes all decisions about approval, rejection, affordability, product terms, repayment plans, payment holidays and other lender actions. Versus Finance Limited cannot require a lender to approve an application or change its decision.

We will nevertheless take reasonable steps to communicate the client’s agreed support needs to the provider where we have an appropriate lawful basis to do so.

Clients experiencing financial difficulty should contact their lender promptly. Independent local support is also available from:

• Citizens Advice Jersey: 01534 724942, advice@cab.org.je, citizensadvice.je;
• Mind Jersey: 01534 880584, admin@mindjersey.org, mindjersey.org.

These organisations are independent of Versus Finance Limited.

Please call 01534 769669 or use our Contact page. We will discuss the client’s preferred communication method and reasonable adjustments.

A concern about how we have handled a client’s needs can also be raised under our Complaints Procedure.