Responsible marketing: Engaging with vulnerable customers

There are now 11.5m people in the UK aged 65 or over. Within the next 50 years, that will be 1 in 3 people. The demographic profile of the UK is changing and our marketing needs to change with it.

Databroker do not supply marketing data of the over 60's but we are aware that other data providers do. With that in mind, we want to go further and offer help and advice to companies who may engage with vulnerable persons even if they are not a Databroker client.

Here are some stats for you to consider before conducting your next marketing campaign:

  • 50% of adults have numeracy skills of age 11 or below
  • 15% of adults have literacy skills of age 11 or below
  • 7m adults in the UK are not internet-savvy — half are over 75 years of age, half are disabled
  • By 2020, half of UK adults can expect to be diagnosed with cancer at some point in their lives
  • 16% of working adults have a disability
  • 800,000 adults have some form of dementia


We want to ensure that companies who engage in direct marketing do so with integrity. We should all do this in order to clean up direct marketing.

With this in mind, we will focus on the outbound telemarketing which seems to be getting most media coverage. It's certainly worth expanding this for direct mail also. We also want consumers to feel as secure and comfortable as possible and to understand how direct marketers work.


How can we drive this agenda forward?

  • There needs to a business case for change — businesses need to understand the economic factors, brand reflection and regulatory framework of marketing and engaging with vulnerable consumers
  • An emotional response — businesses need to care about their communication, social responsibility and marketing. Remember what it's like to feel vulnerable.
  • Effort — Getting this right will take time and effort, including ongoing training.


Making change happen

  • Listen to your customers' or prospects' needs
  • Record or acknowledge any vulnerability
  • Define and identify vulnerability — care not to put people in pots and categorise and discriminate
  • Get all staff to take responsibility including front-line telemarketers
  • Think whether information about vulnerability is not offered or even known


We would like all clients of Databroker to adopt resources and planning for vulnerability with all relevant marketing campaigns. Barclaycard have taken a very proactive approach and have been tackling this issue for over 5 years. They have changed their culture, developed a policy, implemented training, processes, MI and put effective controls in seeking professional help to do so. They have an NPS score of 95. 95. One for the business case.


They have 3 principles that Databroker would like all companies to think about or acknowledge:

  1. Vulnerability is a state not a trait — it's not permanent and people can become less or more vulnerable as their circumstances change
  2. Being vulnerable is a scale — it's not clear cut
  3. Everyone is different and everyone reacts differently


They acknowledge that consumers will drift in and out of vulnerability during communication programs. They have trained their staff to look at four factors on a vulnerability scale:

  1. Event — has something happened? Divorce? Accident? Shock?
  2. Existing factor — illness, literacy
  3. Behaviour — confusion, nervousness, stress
  4. Action — is the consumer asking something unusual?


The staff then have an outcome based on those factors:

  1. Carry on as normal — the vulnerability has no impact
  2. Change approach — speak slower, with more patience and empathy. Check the customers' understanding
  3. Change action — make proactive contact, suspend action, etc.


In terms of data and direct marketing, I feel that the majority of of disturbances to vulnerable persons are based around outbound telemarketing and unethical direct mail campaigns. Databroker have taken the decision not to supply marketing data to certain industries or companies that target based on the elderly, health or low incomes. It is impossible to know who and when any person is in a vulnerable state at any given time but you can look out for signs and act professionally and ethically.

Its not just scams or PPI and personal injury companies that we need to stop here but also more ethical industries (in terms of their generalised marketing approach). If we supply marketing data to a brand name retailer as an example, we want to them to acknowledge a duty to have a vulnerability policy.

Databroker recommends that all companies read the training materials and guidance the DMA provide:

We also recommend that all consumers read about how to opt-out of direct marketing and read about the TPS and MPS service.

Databroker is committed to cleaning up the direct marketing and working with the ICO and DMA to achieve this.