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Work in progress - ratings and comments are still to be finalised

Vulnerability Registration Service

1.1 Stated purpose

People can register with VRS and declare various "vulnerabilities" (the term is not defined). It will then be shared with "various organisations so that they are aware of your vulnerability if they are dealing with you."

1.2 Episodic or relational

2.1 Statutory notification

2.2 Info validated by

Sector

4.1 Personal identifier used

Online portal

Offline alternative

1.3 Data included

Relational

No

Financial services, Utilities

Name, address, address history, DoB

Yes

No

Communication preferences

Reasonable adjustments

Benefits entitlement

Benefits claimed

Debt

Risk of eviction

Loneliness or isolation

Unpaid care responsibilities

Lifecycle events

Any other factors or circumstances

Diagnoses (confirmed and provisional)

Physical disabilities

Sensory impairment

Cognitive impairment

Mental health

Mental capacity

Dyslexia, literacy and numeracy

Further info

Source URL

Privacy URL

Recipients

Bailiffs, debt recovery and enforcement agents

Banks/financial services

Utility companies

Local Authority - Debt Advice

Local Authority (U) - Social Care

Strengths

A detailed and comprehensive list of actionable support needs (other than those given under mental health needs), although the list itself is relatively difficult to access.

Weaknesses

VRS is the lowest scoring platform we have reviewed against all five groups of functional criteria. Of greatest concern is the complete lack of transparency, choice and control over who receives the information and how they use it. Information is passed to all subscribing organisations, whether or not they have (or are likely to have) a business relationship with the person; and neither VRS nor the subscribing organisations offer clarity or reassurance in their privacy statements about how it will be used.

Other significant weaknesses include:

• VRS appears to be a platform for sharing actionable support needs, but in practice behaves more like a tool for assessing financial risk.
• There is no provision to provide specific detail, e.g. nominating someone as your proxy.
• There is no acknowledgement of receipt of your information by subscribing organisations.
• Although VRS claims to operate across sectors, at best it offers little confidence that information will be shared with the right recipients, and at worst it’s misleading, and implies that your information will reach recipients who will never see it.
• A poorly designed online interface, loaded and judgmental language, and no provision to share your information offline.
• Inbuilt obstacles to the (otherwise good) list of actionable support needs, which involves selecting the right "vulnerability flag" (sic).

Overall, VRS is more likely to engender anxiety than trust among the people expected to use it.

Further information

Overall functional rating

3. Transparency, choice and control

3.1 Transparency

Generic statements about which organisations will have access to the data, with very limited/open-ended information about how it will be used. Unlikely to offer any real confidence to someone who may be anxious about sharing their information - more likely to increase their anxiety.

3.2 Choice and control

One element of choice included: whether future credit applications should be pre-declined. Unclear whether the alternative is for them to be automatically or manually processed – this is much clearer on the Experian Support Hub. No choice or control over who receives the information.

4. Functionality

4.2 Structured data

4.3 Free text

Structured data is uneven, and focuses on the condition rather than the needs which arise from it.

4.4 Carer role

There are options to say "I may want someone to speak on my behalf", but no way to say who that will be or to give them authority in advance to do certain things for you. This would need to be done on a case by case basis, defeating the object of "telling us once".

4.5 Acknowledgement of receipt

No evidence of an acknowledgement from data recipients

4.6 Updates

System allows for updates

4.7 Access to records

This is one platform where it would really help to see the context in which organisations might use the information

5. Reach

5.1 Multi-sector acceptance

Multi-sectoral but relies on the organisation subscribing. Some local authorities subscribe, but it's unclear who in the authority would receive the information.

5.2 Recipients within orgs/services

Unclear how far recipients share (e.g.) reasonable adjustment/communication needs within the organisation. For example: Hampshire County Council subscribes; the contact point given is for the Client Affairs team, who look after the financial affairs of people who lack mental capacity. Does HCC communicate ASNs to other teams across social care, TEC etc? Do they share comms needs with district/borough partners in respect of Council Tax, benefits, housing etc? (Almost certainly not, per the HCC Client Affairs team privacy notice.) Would someone sharing needs through the VRS understand which bit of HCC will receive and act on information? (I had to go digging)

5.3 Proactive sharing

No provision

6. Language and user experience

6.1 Language

'Vulnerable' is a loaded word and will act as a barrier for many potential users of the platform. The language in general could easily come across as judgmental.

Words to watch

6.2 Conditions vs actionable support

A fairly wide-ranging list of ASNs, but these can only be accessed by selecting the right "vulnerability flag" (sic). There may not be a direct correlation between these flags and the needs listed, so you may not be presented with the "circumstances outcomes" options that relfect your ASNs.

Focus on "vulnerability flags" as a gateway to ASNs suggests undue emphasis on a condition rather than on the impact that condition has on your day-to-day life. Equality Act statutory guidance states ("There is no need for a person to establish a medically diagnosed cause for their impairment. What it is important to consider is the effect of the impairment, not the cause."

6.3 Online UX

Cumbersome and poorly designed. The site throws up error messages at step 1, but doesn't say what you need to do to correct them. Access to relevant ASNs is dependent on ticking the right box at step 2.

6.4 Offline UX

No offline alternative to the online platform

7. Outcomes

7.1 Actionable support needs

Positive score for options available, reduced due to the barriers to accessing those options. However, choices available under mental health needs are extremely poor and do not reflect the actual ASNs of people experiencing mental health difficulties.

7.2 Trustworthiness

'- Breadth of subscribers may be offputting to some users.
- Privacy notice is fairly generic in respect of who receives data and what they use it for.
- Little or no transparency

Think Local Act Personal: Data for People
Ratings against the 15 Principles

Overall

TLAP 2

TLAP 3

TLAP 4

TLAP 5

TLAP 6

TLAP 7

TLAP 8

TLAP 9

TLAP 10

TLAP 11

TLAP 12

TLAP 14

Money Advice Trust
Ratings against the 10 principles for designing vulnerable consumer data-sharing programmes

Overall

MAT 1

MAT 2

MAT 3

MAT 4

MAT 5

MAT 6

MAT 7

MAT 8

MAT 10-

Conditions/diagnoses identified
VRS "Vulnerability" flags: Physical disability Mental health Physical health Cognitive disorder Lifecycle event Gambling addiction Deceased Financial difficulty Financial capacity Risk of Coercion Accessibility Sight – Blindness Sight – Partial sight Hearing – Deaf Hearing – Partially deaf Low level of literacy Low level of numeracy Limited technological capability Dyslexia Loneliness/isolation Debt Management Plan Debt Relief Order Bankruptcy Old age (increased chance of cognitive or physical impairment) Addiction to alcohol or drugs Victim of Fraud Unpaid Carer Affected Other Neurodevelopmental Disorders Bereavement Limited or No English Language Individual Voluntary Arrangement
Actionable support needs identified
Accessibility I have limited access to public spaces and social events, which can lead to social isolation and reduced opportunities for interaction and inclusion. I have difficulties in accessing information, finding support, and using technology. I have specific accessibility needs and need to discuss / I need personalised financial support I need all communication to be digital Addiction to alcohol or drugs My dependency may affect my decision making so I need any decisions reconfirmed I need to restrict my access to credit I need to discuss my circumstances with somebody who I can trust Affected Other I need to discuss my circumstances – my income is being impacted because of someone else's actions I need to discuss what I need to do to act on someone else's behalf I need help protecting my finances from the actions of someone else / I need to set up automatic payments for certain bills I am at risk of having my identity used by somebody else Bereavement I am newly on my own, and am not used to making decisions alone. I have lost someone close to me, and it is affecting my ability to manage my affairs I need help in sorting out joint finances My income has been affected owing to the loss of a partner / loved one and I need to discuss future steps and understand my options / change in the services you provide Probate has impacted my cashflow and I need to discuss how I manage while this is resolved. Coercion Please be aware that any applications for credit or terms may not be of my free will. I no longer have control over my own finances. I find it hard to afford necessities like food, housing, and transportation. The consequences of financial abuse have made it extremely difficult for me to regain my financial stability and independence. I am paying back debts I was coerced into / my credit history has been affected through coerced debt. I am / I have been a victim of illegal money lending / a loan shark Cognitive disorder Please [use] clear and simple language, allow extra time for processing information, and avoid complex instructions or quick speech. I have memory loss, so please follow up any conversations in writing, with clearly understandable language. Please follow up any conversations with a written summary. I need somebody to act on my behalf when communicating with service providers Coronavirus Long Covid has led to lingering symptoms including fatigue, shortness of breath and brain fog. Covid led to anxiety, depression, and other mental health challenges. Dyslexia Use short, simple sentences and avoid jargon. Speak clearly and directly, avoiding complex explanations. Use large font sizes on documents and displays, and key points in text. Please use coloured paper or backgrounds that may aid readability. Offer audio versions of information where possible. Use bullet points and lists to break down information. Financial capacity I struggle to make appropriate decisions about my finances. I sometimes find it difficult to understand my finances, products, and services. I need extra support around budgeting, saving, investing, and managing debt. I need all conversations to be summarised in writing Financial difficulty My financial situation is impacting my mental and physical health, and I need help to understand my options and how to get things under control I need help prioritising my bills / I need help to manage all my debts together and not deal with multiple organisations My income is lower than my outgoings/ I am in budget deficit – I need help to identify what steps I can take I need to discuss a repayment plan / payment break I am in temporary financial difficulty and need to discuss managing this period without getting further into debt Gambling addiction I chase losses with further gambling and need support. My decision making is sometimes affected by my addiction and need any decisions to be reconfirmed I need gambling-related transactions to be blocked / I need spending limits introduced I need help identifying when I have reached a spending threshold / help with budgeting Hearing – Deaf [ replicated for Partially Deaf] I would like every communication to be written. I cannot use the telephone. I would appreciate sign language services by video call. Please speak slowly and clearly when talking to me. Lifecycle event I am newly on my own and am not used to making decisions alone and require support. My relationship has broken down which has impacted by finances short-term and need to discuss my options / need help with existing joint financial arrangements I am facing a temporary loss of income owing to illness / pregnancy / job loss and need to discuss flexible management of my finances Limited or No English Language I would appreciate if conversations could use translation services. I would like written communications to be translated. I might ask a member of my family or a friend to take calls for me. Limited technological capability I struggle to access information online, navigate websites, or use online forms to resolve issues. I would like simple, step-by-step instructions in plain language. I prefer to speak with a customer service representative over the phone rather than engaging through digital channels. I need an alternative to online banking or chat rooms or Apps Loneliness/isolation I have Increased Risk of Mental Health Conditions, like depression, anxiety, and suicide so would appreciate a trusted person / a single point of contact I have nobody to support me in managing my finances I need help ensuring I do not become a victim of fraud or a scam Low level of literacy Please use voice-based services if possible. Please use simple language. I will struggle to understand written communications Low level of numeracy I struggle to understand percentages or decimals. I struggle to calculate total costs based on quantities and price per unit. I misunderstand complex billing methods. Please use clearly explain interest and fees, and total prices. Mental health My memory is affected, so I would like any conversations to be followed up by an email summary. My decision-making is affected, so if I am required to make a decision, I would like clear information and time to consider it. I would like a choice of communication channels / I am being overwhelmed by the number of communications I am getting. I struggle to understand complex processes or detailed product information / I need to discuss my circumstances with a staff member and help understanding my options I need a family member / friend to help manage my accounts. Neurodevelopmental Disorders I cannot take or make phone calls and may ask a family member to do it instead. I might become non-verbal due to a situation and be unable to process the information or ask appropriate questions. I may not be able to concentrate for periods of time so communication needs to be adapted. Old age I have short-term memory loss, potentially impacting daily functioning. I feel at risk of dementia and need to discuss my circumstances. I am facing reduced mobility and this affects my ability to deal with my affairs. I need communication to be in writing Physical disability I have Accessibility Barriers, which limit my access to buildings, transportation, healthcare, and the workplace, leading to social isolation and reduced participation in daily activities. Mobility impairments make mobility difficult for me I need telephone or video banking / voice activated banking / I cannot use PINS I need fast-tracked support for my condition Physical health I need telephone or video banking / voice activated banking / I cannot use PINS I need fast-tracked support for my condition I am sick or have a disease which impacts my ability to communicate . Some products need adapting for me. Risk of Homelessness I am at risk of losing my home and I need to discuss how you can help reduce my outgoings in the short-term I need emergency financial support / access to hardship funds I need to discuss flexible payment options I need to discuss how to manage my finances if I have no fixed address Sight – Blindness [replicated for Partial Sight] Please use braille in communications with me. Please use large print in communications with me. Please give me telephone support. Please use accessible chat platforms that allow for screen reader compatibility and keyboard navigation. Speech, Language, Communication Differences I may require more time when speaking There may be periods of silence when responding or during conversation I might ask to nominate someone to speak on their behalf I might want to use 'text to speech' software to communicate verbally I may repeat words or sounds whilst speaking Please do not interrupt me Unpaid Carer I need help with my finances – my income has unexpectedly reduced I am in debt because my ability to work has temporarily been removed I need to receive paper / text communication – my time is impacted I need a phone number to call an appropriate representative directly because it is difficult to manage my time because of caring responsibilities I need help understanding how I can act on someone else's behalf Victim of Fraud Fraudsters may use my personal information attempting to open fraudulent accounts or incur debts in my name. Extra authentication needs to be in place I have lost money or assets as the result of fraud which have impacted my finances and I need to discuss my options. I am being chased for debt that I have not incurred and need to discuss with someone I have increased vulnerability to fraud and need help to protect myself My credit history has been affected by fraudulent activity and I need help resolving it
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