Step One - Introducing the Questionnaire

The Customer Wellbeing Questionnaire is online so the customer will need to have an email, or have access to an email, to be able to complete.

For our Lifetime Mortgage application journey this questionnaire is mandatory and advisers can assist the customers to complete if they do not have an email.

Customers must be clearly informed about the purpose of the Customer Wellbeing Questionnaire and must give explicit, informed consent before participating. They should also be told their responses will be kept confidential, used only for support purposes, and that they can withdraw consent at any time.

All customers will complete the same questionnaire, but may be asked to complete at different points of the customer journey.

We recommend introducing as early as possible in onboarding journeys as it will enable us to identify signs of vulnerability at an early stage.

Introducing assessment on phone

To ensure we obtain the appropriate level of consent use the wording below. (This has been approved by our data protection team)

“We’re offering a questionnaire that can help us understand if you might need any extra support or assistance when dealing with us. The questionnaire is provided by our trusted partner, Comentis who will collect and process your information on our behalf.
The questionnaire is completely optional. If you choose to take part, some of your answers may include sensitive information, such as details about your health, finances or other personal circumstances. Comentis will collect your answers on our behalf, and we will only use the information to identify you and make sure you get the right support from us.

You can withdraw your consent at any time by contacting us.

Do you give your explicit consent for us to share the questionnaire with you and for Comentis to collect and process your answers for this purpose? "

Once consent has been received we need to record this on the customer policy. For each system this will be different so refer to your local processes for more information on how to do this.

Overcoming objections

To help you confidently support customers and navigate challenging conversations, here are some helpful phrases you can use to overcome common objections with empathy and clarity

“Why are you asking me these personal questions?”	Response: "I completely understand—it can feel a bit personal. We use these questions to help us understand if there’s anything affecting how we support you. It’s about making sure we’re doing the right thing for you, not about judging or profiling
“I don’t want to be labelled as vulnerable”	Response: "That’s totally fair. This isn’t about labelling—it’s about recognising if there’s anything going on that might make things harder for you right now. It helps us tailor our support so you’re not left to manage alone"
“Is this going to affect how you treat me?”	Response: "Only in a positive way. If the questionnaire shows you might need a bit more support, we’ll make sure you get it. It won’t affect your rights or access to services—it just helps us be more responsive to your needs"
“What happens to the information I give you?”	Response: "We take your privacy seriously. Anything you share is kept secure and only used to help us support you better. We follow strict data protection rules and only record what’s necessary, with your consent"
“Do I have to do this questionnaire?”	Response: "Not at all—it’s completely your choice. We offer it because it can help us understand your situation better, but if you’re not comfortable, we’ll respect that and still do our best to support you"
“Who is Comentis?”	Response: "Comentis is a trusted provider of vulnerability assessment tools, used by many regulated organisations to help identify and support customers who might need extra help. Their platform was developed with clinical experts and aligns with FCA guidance, so it gives us a consistent and respectful way to understand your needs"
“Why are you using an outside company to assess me?”	Response: "That’s a great question. Comentis helps us make sure we’re not relying just on gut feeling or assumptions. Their tool gives us a fair and structured way to identify where you may benefit from additional support, or adaptions. It’s all about doing better by our customers"
"How long will Comentis hold my information?"	Response: "Comentis will only keep your information for as long as we need to, whether that’s to provide our services or meet legal requirements. You can also ask us to delete your information at any time — just get in touch and we’ll take care of it, unless we’re required to keep it for legal reasons"

 

Step two - Sending the Questionnaire

You will need to have access rights to the Comentis platform to send an questionnaire. If you do not have access speak to your VC Champ. You can find names of Champs in your area in the 'Need help' section in the Customer Support Guide.

If you have access rights use this link Comentis: Duty of Care

If you have any issues logging into system/ or while using the system let your Comentis administrator know and they can contact Comentis on your behalf.

Retail - Manpreet Thethi 

HUB FS-GIFL -  Raise a Service Now ticket for your Change Team

HUB FS - LLL - Charlotte Brain

HUB PC -   Seb Sherbourne 

DB - Carol- Anne Daniels (Caz)

In order to send the questionnaire, the customer needs to be added to the Comentis Platform (following their explicit consent)  

This can be done by selecting ‘Create new client/customer’, and entering the required information (this can vary between departments so refer to your local processes for more information).

Once the record has been added, you can:

• Open their record.
• Beside Assessments, select + New Assessment.
• Choose Email to Customer.
• And then you can send the email to the customer.

For more information you can locate the 'User Guide' in Resources in the Comentis platform

Step Three - Accessing and Downloading the Report

Once the customer has completed the questionnaire you will receive an email in the designated inbox - if this has been set up for your team.
If not you can log into the Comentis platform and can check what questionnaires have been completed.

Click into customer's record, beside assessments, select Action > Download Report.

You will find the customer report in your 'Downloads' Attach this to your customer record.

It’s essential to download and attach the Comentis report to the correct customer record—adding it to the wrong file could lead to inappropriate decisions, data breaches, or missed support opportunities.
Delete customer report from your downloads once you have added to customer record. 

Step four - Interpreting the report

Is this customer vulnerable?

The Comentis platform assesses customer vulnerability through a clinically developed questionnaire that evaluates responses against key indicators such as health, life events, resilience, and capability.

It uses a RAG status to provide a structured, objective view of vulnerability levels to help teams identify where support may be needed and guide appropriate next steps.

The report will show either a Green / Amber or Red vulnerability rating. While the Comentis report currently displays a RAG status, as a firm we are moving away from categorising vulnerability in this way

Green - the questionnaire has not identified any indicators of vulnerability, so likely no additional support required right now. No further action required at this point - unless we pick something up when interacting with the customer, or customer discloses information.


Amber - the responses from the customer has identified indicators of vulnerability meaning we may need to adapt our approach, or do something different when interacting with this customer.


Red - the responses from the customer has identified multiple indicators of vulnerability and likely to have specific support needs. Check whether there is anything in the report that means you need to escalate to a VC Champ or Team Manager (check local processes for this)

Because this assessment of vulnerability is indicative we do not add a vulnerability flag in our system until we have spoken to customer and agreed appropriate support and gained explicit consent to record.

The customer has indicated the following

This tables below are designed to help frontline colleagues use the report to identify and respond to different types of customer vulnerability during calls. It includes four key categories

• Low financial capability
• Low emotional resilience
• Financial difficulties
• Communication challenges

	What to look for in report	How you can support
Indicators of low financial capability Customers may struggle to grasp financial concepts, products, or terminology. They might need extra support to understand options, implications, or processes. This can affect decision-making and confidence in managing money.	Neurodiverse condition * Comprehension Concentration Decision making Engagement Lack of confidence Poor English Poor recall Strategic thinking Undue influence Victim of fraud * ADHD,  Dyslexia,  Dyspraxia,  Dyscalculia,  Autism , Aspergers	Avoid assumptions – use IDEA to ask open questions Book longer appointment Offer short breaks in longer appointments Use clear, simple language Speak slowly and clearly Avoid jargon and explain complex terms Recap previous conversations Suggest bringing in a trusted person – check for a PoA Keep conversations focused and structured Break information into smaller chunks Allow extra time for processing and decision-making Use visual aids or diagrams Check for understanding without pressure Encourage time before deciding Signpost to specialist support – internal or external Offer written summaries of key points If signs of undue influence or fraud escalate concerns to your VC Champ and MRLO
Indicators of low emotional resilience  Customers may be emotionally overwhelmed due to recent life events or ongoing stress. They may find it difficult to cope during the call, express their needs, or make decisions.	Negative life events * Anxiety or stress Mood Mental health Social support network Safeguarding Physical health Victim of fraud * divorce,  bereavement,  caregiver,  moving home,  change of employment status	Book longer appointment Offer short breaks in longer appointments Listen actively and empathetically Acknowledge experience with compassion Use calm and reassuring tone Allow space to speak without interruption Avoid overly formal language Check for additional support needs Ask gently about support network Suggest bringing in a trusted person – check for a PoA Offer to pause or reschedule if overwhelmed Signpost to specialist support – internal or external Ensure emotional safety before ending call Follow safeguarding protocols and escalate concerns
Indicators of financial difficulties Customers may be experiencing financial hardship due to changes in income, debt, or life circumstances. They may need tailored solutions, signposting to support services, and reassurance that help is available.	Negative life events * Change of financial status Bankruptcy * divorce,  bereavement,  caregiver,  moving home,  change of employment status	Offer practical help – fast tracking or payment breaks Check for dual needs – emotional and financial Signpost to specialist support Avoid judgmental language – focus on solution
Indicators of communication challenges Customers may face barriers due to physical, cognitive, sensory, or language-related challenges. They may require adjustments in communication, format, or process to fully engage and access services.	Hearing impairment Physical health Visual impairment Poor English comprehension	Avoid assumptions – use IDEA to ask open questions Check preferred communication channel Support Relay UK and offer video calls Send documents in alternative formats Offer practical help – pre-populating forms, accepting stamps Check for need of third-party support or interpreter

Step five - Stepping into the conversation

Once a need for support has been identified through the wellbeing questionnaire, it's important to respond sensitively in conversations with customers and work with them to establish tailored support that meets their individual needs.

Step one - Thank customer for completing
It's important to start by acknowledging that customer has taken time to complete the questionnaire and we now know more about customer.
Here are some suggested conversation starters you can use. These are not scripted so feel to tweak to meet your own style. Just ensure you use a clear and conversational style.

Customer has completed questionnaire and there are no indicators of vulnerability identified
“Thank you for taking the time to complete the questionnaire. From what you've shared, there’s nothing that suggests you need any extra support right now — which is great.

Just so you know, if anything ever changes or you feel we could adapt something to make things easier for you, please don’t hesitate to let us know. We’re always here to help.”

Customer has completed questionnaire and there are indicators customer has low financial understanding and needs support with decision making
“ Thank you for completing the questionnaire. From what you've shared, it looks like you might benefit from a bit of extra support when making decisions — and that’s absolutely okay. We want to make sure everything feels clear and comfortable for you. Would it be alright if I asked a few quick questions, just to understand how we can best support you?"

Customer has completed questionnaire and there are indicators customer may have low emotional resilience
“Thank you for completing the questionnaire. We really appreciate you sharing that with us. From what you've told us, it sounds like it might be helpful for us to take a bit of extra care in how we support you. Would it be okay if I asked a few quick questions, just to make sure we’re doing that in the best way for you?”

Customer has completed questionnaire and there are indicators customer may be experiencing financial difficulties
“Thanks again for completing the questionnaire — we really appreciate you sharing with us. From what you've told us, it sounds like it might help if we move things along a little quicker and offer some extra support where we can. Would it be okay if I asked a few quick questions, just to make sure we’re doing what’s right for you?”

Step two – Use IDEA to understand support needs

After acknowledging vulnerability, you can use the IDEA conversation tool to explore the customer’s situation further and agree on the right support.
The information in the report lets us know that customer has a characteristic of vulnerability but this does not automatically mean they are vulnerable.
Always avoid assumptions - use IDEA to ask open questions to understand customers' current situation.
For more information on using IDEA click here.

Step Six - Creating a safe place to disclose

We recognise that vulnerability is not always visible, and even when identified, it may not require immediate action. However, creating a safe and supportive environment encourages customers to share important information when they feel ready — and helps us respond appropriately if their circumstances change.

Let customer know that sharing information helps us tailor support to their needs — now or in the future.
Explain the benefit of disclosure: For example, “If anything changes, letting us know means we can look at options that might make things easier for you.”

If a customer chooses not to disclose, that’s okay. Focus on building trust and keeping the door open.

Key Message to Reinforce
“You don’t have to tell us everything now — but if things change, we’re here to help. Sharing what’s going on means we can offer the right support when you need it.”

Step Seven - Recording vulnerability and support needs

We will want to add a vulnerability flag where we've identified a customer has a characteristic of vulnerability.

If the vulnerability also means additional support we will also want to record this - so we can adapt each time we speak to customer and customer does not need to repeat themselves.

Ensure you use TEXAS and ensure you have the appropriate level of consent.

Where we have updated our systems with 'new data fields' you will be able to have the option of using the drop down options to record support (How we adapt)

If there are signs of vulnerability but you have been unable to gain consent then we may be able to add a flag to policy using legitimate interests as the basis for recording.
Speak to your VC Champ or Data Protection Champ for guidance.

(Tulip / DB only)  In Comentis you are able to log what we have done to support customer - they call these 'Interventions'. When recording interventions use the options in the table below.

Communication preference	Third party support	Adapt Appointment	Decision making support	Adapt process
Communication preference – large font Communication preference – braille Communication preference - audio Communication preference – email Communication preference – in writing Communication preference – no phone Communication preference – Text to Talk / Relay UK Communication preference – Video calls Communication preference – paper-based Communication preference –face-to-Face Communication preference – other	Third party support – verbal authority obtained Third party support – POA/Deputyship (approved) Third party support – POA/Deputyship (in-progress) Third party support – other	Appointments – additional support when face to face Appointments – longer time slots needed Appointments – calls at preferred times Appointment – other	Decision making support – remembering Decision making support – understanding Decision making support – communicating Decision making support– evaluating options	Adapt process – pre-populate forms Adapt process – stamp instead of signature Adapt process – prioritise tasks Adapt process – other