Statement
We recognise that there are consumers who, due to their particular circumstances, characteristics or needs are or may be vulnerable. We aim to ensure that they are protected from harm as far as is reasonably possible and that they do not suffer detriment as a result.

We will train our staff to identify the characteristics that may lead to a consumer being considered vulnerable such as

•    Lack of English language skills or low literacy and/or numeracy skills
•    Disability or mental health condition
•    Low level of technical/IT literacy
•    Age – including children (defined as under 16 years of age) and older people
•    Learning difficulties or low mental capacity
•    Addiction.

And also circumstances that may lead to a consumer being temporarily vulnerable such as

•    Income shock, e.g. Due to job loss or being victim of a financial scam
•    Bereavement
•    Domestic abuse, including financial control and abuse
•    Sudden and unexpected situation causing strife, e.g. Illness or relationship breakdown.

We have considered the elements of our service that may put vulnerable customers at greater risk and will aim to mitigate them where possible.

•    Services that are low value, quick transactions leading to impulse purchases
•    Services that are Purchases often made on the go, using a small screen
•    Services that are attractive to children and younger people
•    Services that are attractive to people in difficult circumstances which could lead to them being vulnerable, e.g. Information, Connection and Signposting Services (ICSS)  for people under financial pressure seeking to make insurance claims or reach their banks or people trying to access essential public services such as jobseekers allowance

•    Services that are attractive to people with existing vulnerabilities
•    Gambling services which appeal to people with gambling addiction or
•    Psychic services which may be attractive to recently bereaved people

Identification of Risks

Target Market
Our target market ishigh street mobile phone shop traders.
This may attract vulnerable customers in the following category.

•    People with language problem.
•    Having difficulty in understanding the total cost of the service.

Since our target market is high street mobile phone shops. we will aim to mitigate this risk by contacting our clients in personal and explaining the full procedure of our service as well as providing them a free dedicated help line to be contacted for any assistance prior placing any orders.

Marketing and Promotion Assessment
We will be promoting our services in the following places:
We aim to provide clear marketing that is not likely to attract any users identified in the above categories. We will ensure our promotions:

•    Are clear in pricing
•    Are designed with our target market in mind
•    Are not attractive to children
•    Are not misleading in any way
•    Contain a clear refund policy
•    Contain terms and conditions
•    Have a non-premium means of customer contact
•    Are regularly reviewed to check if there is evidence that the service is attracting vulnerable customers – this can be through complaints, refund requests, enquiries, online blog reports.

Controls
Parental Controls / Age Verification
Our service dose not require age restriction.

Advertising Partners
If  we consider that our advertising partner is driving vulnerable callers to our service, we will notify them of our policy and take remedial measures accordingly but either changing the parameters of our marketing strategy or changing our advertising partner to one that is more sympathetic to this policy.

Staff Training
We will ensure that customer care staff have appropriate training,  resources, and reference materials at their disposal, so they can speak with vulnerable customers with knowledge and confidence and provide a level of service that meets their needs

Complaint Handling
We will ensure that our complaint handling process is sensitive and aware of the potential for consumer vulnerability . In the event of third party complaints such as from a carer, family member, or friend of the caller, we will deal with the complaint sympathetically and take appropriate remedial action on behalf of the caller.

Monitoring

-    Method: We review statistical information provided by Our Service Provider as well as  individually received orders through emails.
-    How Often: Every Month.
-    Responsible person / department: Asim Mehmood (Technician)

Monitoring Data

Monitoring data will be recorded and made available to the PSA on request
•    Volume of calls for a particular period (available from the network)
•    Feedback from any user testing
•    Complaint trends or patterns
•    Patterns of unusual use and/or spend
•    Feedback from customer care staff
•    Call recordings of customer care staff dealing with vulnerable consumers
•    Training evaluation to ensure it has been well understood and implemented effectively.

Evidence Gathering

Evidence of successful implementation of this policy will be retained and made available to the PSA on request. Such as:
•    Indications an increased level of satisfaction with the service and/or quicker resolution of complaints received from vulnerable consumers
•    Increased satisfaction scores from vulnerable consumers
•    Demonstrations of how complaints data or other information from vulnerable consumers has been used to make improvements to the design of services (including promotions) and/or procedures
•    Materials used for staff training
•    Materials available for staff to assist them in identifying both the explicit and implicit signs of potential consumer vulnerability
•    Changes made to the design and promotion of phone-paid services as a result of identifying particular risks
•    Any additional requirements placed on any contractors in relation to vulnerable consumers, e.g. affiliate marketers.

A review  of this policy will be completed annually
Contact Information
Service Provider Name:Vibe Tech -  the fone master
Responsible Person: Mr Rizwan Arshad
Service and Charge:0333 301 0925
Website:  www.vibetechonline.com
Customer Contact Email:vibetech.po@gmail.com