Partnership approach vital to address consumer vulnerability

A blog post by Consumer Scotland Head of Research Jane Williams

Understanding and addressing how markets impact on consumers in vulnerable circumstances is an integral part of the work undertaken by Consumer Scotland. As Scotland’s statutory consumer advocacy body, our founding legislation specifically empowers us to have regard to the interests of vulnerable consumers, and this is fundamental to our approach. An inclusive and universal approach to consumer issues makes markets work better for all of us, not just those at greater risk of harm.

Consumer Scotland’s literature review of existing evidence published today demonstrates just how significant that challenge is. Current definitions of consumer vulnerability highlight how it can be temporary, sporadic or permanent. For one reason or another most of us are likely to be ‘vulnerable’ or at greater risk of harm at some point in our lives – in some cases that risk is persistent and deeply entrenched. While vulnerability should not be thought of simply in terms of specific characteristics, the review highlights there are also risk factors such as being younger or older, living in poverty, being disabled, living in a rural community or being from a minority ethnic household which can increase the risk of consumers experiencing vulnerability. Consumers can also be at heightened risk of vulnerability in some markets, especially where they have no choice about whether to purchase goods or services or need to do so at stressful times. Consumer vulnerability can also be cumulative and the risks for consumers whose lived experience include multiple and compounding inequalities are particularly severe.

What is Consumer Scotland doing to address these issues?

Since our establishment last year we are already undertaking work in partnership with others to tackle some of those issues. In the energy market our research has highlighted the disproportionate impacts increased energy costs are having on prepayment meter customers and disabled consumers. We are also modelling the impact of social tariffs in different markets to help identify interventions which are likely to be the most effective in ensuring that consumers can access services at affordable prices. We are working with regulators, policy makers and other advocacy organisations to ensure the measures put in place reflect this and are fair.

The literature review also highlights several areas where there are gaps in the evidence base in relation to consumer vulnerability in Scotland. One of our roles will be to consider what research we should undertake in relation to addressing those gaps. We are keen to work with a variety of organisations, including universities and other research bodies, to ensure that our research does not unnecessarily duplicate what others are already doing and instead builds on the existing evidence base.

We are listening to and working in collaboration with frontline organisations to ensure our research is developed with, and by those, with personal experience of vulnerability. We are keen to ensure consumers themselves have the opportunity to influence and participate in our research.

We have also established an Advisory Committee on Consumers in Vulnerable Circumstances which will play an important role in supporting Consumer Scotland’s work on consumer vulnerability by helping inform and advise us on our research, advocacy, and policy work.

The literature review we are publishing today also highlights how language matters. While the legislation that establishes Consumer Scotland refers to “vulnerable consumers” many organisations have moved away from this language using ‘consumers in vulnerable circumstances’ or ‘consumer vulnerability’ instead.  The review highlights how describing someone as vulnerable can be unhelpful since many of us do not like or do not identify with this term. It can be misleading since it potentially ignores the wider contextual factors that affect vulnerability.

But although language matters, so does action. As with any difficult or complex issue consumer vulnerability is challenging. As a newly created body we can’t claim to have all the answers. We know addressing consumer vulnerability can only be done in partnership with others and a lot of important work is already going on - although more still needs be done. Our Strategic Plan 2023-2027 sets out our intention to work across three cross-cutting themes - net zero and climate change adaptation, the cost of living and consumers in vulnerable circumstances. The publication of this review is a first step, but we will continue to focus on how we can better understand and address consumer vulnerability across all our work.