Vulnerable Customers Policy

Last updated: 19 January 2026

Please read this policy carefully. It explains how Optua Telecommunications Limited supports customers who may be in vulnerable circumstances and the additional measures we provide to ensure fair treatment and accessible services.

If you require an accessible version of this policy, for example in large print, Braille, audio format, or by post, please contact us at contactus@optua.co.uk or call 0800 054 8330 (free to call).

1. Introduction and Commitment

1.1 At Optua Telecommunications Limited ("Optua", "we", "us", "our"), we are committed to treating all customers fairly and with respect. We recognise that some customers may be in circumstances that make them vulnerable, and we are dedicated to providing appropriate support to ensure these customers can access and use our telecommunications services effectively and safely.

1.2 This Vulnerable Customers Policy sets out how we identify, support, and protect customers in vulnerable circumstances in accordance with Ofcom's General Condition C5 and applicable law, including Scots law.

1.3 Our legal name is Optua Telecommunications Limited, registered in Scotland under company number SC872607. Our registered office is located at 2nd Floor, 48 West George Street, Glasgow, G2 1BP, United Kingdom.

1.4 This policy applies to all our customers and forms part of our broader commitment to customer service excellence and regulatory compliance.

2. What is Vulnerability?

2.1 Definition

A customer in vulnerable circumstances may be:

(a) Age-Related Vulnerability:

  • Elderly customers (typically 75+) with limited digital literacy or mobility
  • Young customers or dependents with limited decision-making capacity
  • Customers requiring support from family members

(b) Health-Related Vulnerability:

  • Customers with physical disabilities affecting communication or service use
  • Customers with visual or hearing impairments
  • Customers with mental health conditions or cognitive difficulties
  • Customers requiring life-line or medical alert services
  • Customers with chronic illnesses affecting employment or income

(c) Financial Vulnerability:

  • Customers experiencing financial hardship or difficulty
  • Customers with irregular income or precarious employment
  • Customers in receipt of means-tested benefits
  • Customers facing redundancy, bereavement, or sudden income loss
  • Customers with existing debt or credit difficulties

(d) Social Vulnerability:

  • Customers experiencing domestic abuse or controlling relationships
  • Customers with language barriers or literacy difficulties
  • Customers with limited access to support networks
  • Customers who are carers for dependents or elderly relatives
  • Customers experiencing homelessness or housing instability

(e) Digital Vulnerability:

  • Customers with limited digital literacy or internet access
  • Customers unable to use online services or digital channels
  • Customers unable to understand complex technical information
  • Customers preferring traditional communication methods

2.2 Recognition and Identification

We identify vulnerable customers through:

  • Direct disclosure by the customer
  • Information provided during initial contact or during an existing relationship
  • Patterns of service use or payment
  • Feedback from support agencies or family members
  • Third-party referrals

We do not make assumptions about vulnerability based on protected characteristics alone (age, disability, gender, etc.), but we recognise that these factors may contribute to vulnerability.

3. Our Commitment to Vulnerable Customers

3.1 Principles

We commit to:

(a) Fair Treatment:

  • Treating all vulnerable customers with dignity and respect
  • Not discriminating or disadvantaging vulnerable customers
  • Providing equal access to services and support
  • Using plain, clear language in all communications
  • Offering flexible and accessible service options

(b) Transparency:

  • Being clear about charges, terms, and conditions
  • Explaining options in understandable terms
  • Providing information in accessible formats
  • Offering time to understand and consider options
  • Being honest about limitations and support available

(c) Accessibility:

  • Making services accessible to all customers
  • Providing alternative communication methods
  • Offering documents in accessible formats
  • Supporting customers with additional needs
  • Removing barriers to service access

(d) Accountability:

  • Listening to customer feedback and complaints
  • Responding promptly to concerns
  • Taking corrective action when things go wrong
  • Regularly reviewing and improving our support
  • Publishing information about vulnerable customer support

3.2 Non-Discrimination

We will not:

  • Refuse service to vulnerable customers (unless legitimate grounds exist unrelated to vulnerability)
  • Charge different prices based on vulnerability status
  • Treat vulnerable customers less favourably
  • Refuse requests for accessible formats or communication methods
  • Require vulnerable customers to access services through single channels only

4. Identification and Registration of Vulnerable Customers

4.1 Customer Notification

When we identify a customer as vulnerable (or they disclose vulnerability to us), we:

  • Confirm our understanding and the specific vulnerability identified
  • Explain the support and protections available
  • Register them on our Vulnerable Customer Register
  • Confirm in writing (in accessible format if required)
  • Provide a dedicated contact for ongoing support

4.2 Vulnerable Customer Register

We maintain a confidential Vulnerable Customer Register containing:

  • Customer name, account number, and contact details
  • Nature and date of vulnerability identification
  • Support measures in place
  • Designated support contact name
  • Regular review dates
  • Data protection compliance measures

Access to Register:

  • Accessible only to authorised staff
  • Protected by confidentiality obligations
  • Subject to Data Protection Act 2018 and UK GDPR compliance
  • Accessible to customer on request
  • Updated when circumstances change

4.3 Opt-Out Option

Customers may opt out of vulnerable customer status:

  • By written request to contactus@optua.co.uk
  • By phone to 0800 054 8330
  • By post to our registered office
  • For any reason without penalty
  • With confirmation provided

Opting out does not remove our legal obligations to treat customers fairly, but removes access to additional support measures.

5. Accessible Communication

5.1 Formats Available

We provide documents and information in the following accessible formats:

(a) Visual Accessibility:

  • Large print (minimum 16-point font, Arial or similar)
  • Braille (on request, typical turnaround 5-7 working days)
  • Audio format (MP3 or other format, read by professional narrator)
  • High-contrast black and white versions
  • Digital accessible PDF (screen-reader compatible)

(b) Communication Methods:

  • Email communication
  • Telephone communication (with transcription available)
  • SMS/text messaging
  • In-person meetings (local office or by arrangement)
  • Video relay services or BSL (British Sign Language) interpretation
  • Written confirmation after verbal conversations

(c) Language Support:

  • Interpretation services in common languages (on request)
  • Documents in alternative languages (on request)
  • Support for customers with literacy difficulties
  • Plain English explanations of technical terms

5.2 How to Request Accessible Format

Customers can request accessible formats by:

  • Calling 0800 054 8330 (ask for Vulnerable Customers Team)
  • Emailing contactus@optua.co.uk with format requirements
  • Selecting preferences on online account (if available)
  • Informing any Optua staff member during contact

No additional charges apply for providing documents in accessible formats.

Turnaround Times:

  • Standard formats (large print, email): 2-3 working days
  • Braille: 5-7 working days
  • Audio: 3-5 working days
  • Interpretation services: 5-10 working days (or as soon as practicable)

6. Support Services for Vulnerable Customers

6.1 Dedicated Support Team

We have a dedicated Vulnerable Customers Support Team available:

  • Phone: 0800 054 8330 (free to call, 08:00-20:00, seven days a week)
  • Email: vulnerable.customers@optua.co.uk
  • Post: Vulnerable Customers Team, Optua Telecommunications Limited, 2nd Floor, 48 West George Street, Glasgow, G2 1BP
  • Textphone (for hearing-impaired): 18001 0800 054 8330
  • Response Time: Within 2 working days for non-urgent matters, within 4 hours for urgent issues

6.2 Account Management Support

(a) Designated Support Contact:

  • Named individual or team assigned to each vulnerable customer
  • Consistent point of contact for continuity
  • Knowledge of customer's specific circumstances
  • Available during business hours and for emergency contact

(b) Proactive Outreach:

  • Regular check-ins (quarterly minimum)
  • Advance notice of service changes or contract renewals (45 days minimum)
  • Proactive offer of support if payment difficulties detected
  • Seasonal support (winter fuel assistance, etc.)

(c) Account Arrangement:

  • Simplified billing options
  • Payment arrangement flexibility
  • Budget billing options (where available)
  • Credit limit adjustments based on circumstances

7. Financial Hardship Support

7.1 Recognising Financial Difficulty

We identify customers in financial hardship through:

  • Direct disclosure
  • Payment defaults or arrears
  • Contact from debt advice agencies
  • Reduced or irregular payment patterns
  • Referrals from support agencies

7.2 Hardship Support Measures

(a) Payment Arrangements:

  • Extended payment terms (up to 12 months)
  • Reduced minimum payments
  • Debt write-off consideration (in exceptional circumstances)
  • Temporary service suspension (rather than disconnection) during hardship
  • Reconnection without full debt payment in some circumstances

(b) Service Protection:

  • No disconnection without prior contact attempts
  • Minimum 30 days' notice of disconnection (45 days for vulnerable customers)
  • Warning of disconnection, not immediate action
  • Right to discuss arrangements before disconnection
  • Reconnection support after payment resumption

(c) Charging Fairness:

  • No additional charges for hardship arrangements
  • Clear explanation of charges
  • Regular review of charges
  • Advice on reducing consumption or switching to cheaper packages
  • Signposting to subsidised services where available

(d) Debt Advice:

  • Referral to Money Advice Service (www.moneyadviceservice.org.uk)
  • Referral to StepChange (www.stepchange.org)
  • Referral to Citizens Advice Consumer Service (consumer.adviceguide.org.uk)
  • Local council hardship schemes information
  • Community support services signposting

7.3 Disconnection Policy for Vulnerable Customers

We will not disconnect or refuse reconnection to vulnerable customers except as last resort, and only after:

  • Minimum two contact attempts (phone and letter)
  • Clear explanation of options and support available
  • Opportunity to discuss arrangements (minimum 7 days)
  • Written confirmation of disconnection intent (minimum 7 days before)
  • Confirmation that no alternative support is viable
  • Referral to support agencies offered

Even after disconnection, reconnection support is available without payment of full arrears in appropriate cases.

8. Service Accessibility

8.1 Service Design

Our services are designed to be accessible to vulnerable customers:

(a) Billing:

  • Clear, simple billing statements
  • Option for paper bills (not digital-only)
  • Itemised billing available
  • Explanation of charges on request
  • Budget billing options
  • Consolidated billing (multiple services on one bill, if required)

(b) Account Access:

  • Online account access (with accessibility features)
  • Telephone account access (no online requirement)
  • Third-party access (power of attorney, representative, etc.)
  • Regular confirmation of account details
  • Easy account updates and changes

(c) Customer Service:

  • Multiple contact channels (phone, email, post, SMS)
  • No channel restrictions for vulnerable customers
  • Trained staff to handle vulnerable customer interactions
  • Extended support hours
  • Escalation procedures for concerns

(d) Technical Support:

  • Remote support options (phone-based, no screen sharing required)
  • In-home technical visits (where appropriate)
  • Equipment simplification options
  • Router explanation and support
  • Regular equipment maintenance reminders

9. Specific Vulnerabilities - Tailored Support

9.1 Elderly Customers

  • Proactive support and regular contact
  • Simplified billing and payment options
  • Telephone-based customer service priority
  • Larger print documents (16pt+ standard)
  • Slower service changes (extended notice periods)
  • Family member contact option (with consent)

9.2 Customers with Disabilities

  • Accessible format documents (as per Section 5)
  • Service adaptations (e.g., accessible website features)
  • Support animal accommodation in appointments
  • Extended appointment times
  • Accessible office locations
  • Sign language interpretation (on request)

9.3 Customers with Hearing Impairment

  • Textphone support: 18001 0800 054 8330
  • Email and SMS communication preference
  • Video relay services (via BSL interpreter)
  • Written confirmation of all verbal conversations
  • Captioning on video content (where applicable)

9.4 Customers with Visual Impairment

  • Large print documents (minimum 16pt, sans-serif font)
  • Audio format support
  • Digital accessible PDFs
  • Phone-based account management
  • No reliance on online-only services

9.5 Customers with Language Barriers

  • Interpreter services (on request, common languages covered)
  • Documents in alternative languages (on request)
  • Community liaison support
  • Extra time for conversations and understanding
  • Written confirmations in preferred language

9.6 Customers in Financial Hardship

  • Immediate referral to hardship team
  • Flexible payment arrangements
  • Temporary credit support (where available)
  • Free energy advice services
  • Fuel poverty support signposting
  • Assistance with benefits applications (information only)

9.7 Customers Experiencing Domestic Abuse

  • Confidential support contact (separate contact details)
  • Safety considerations in all communications
  • Sensitive handling of sensitive circumstances
  • Signposting to domestic abuse services
  • Support with emergency contact changes
  • Flexible notice periods for service changes

10. Staff Training and Competency

10.1 Staff Training Requirements

All staff interacting with customers receive training on:

  • Vulnerable customer identification and support
  • Communication skills for difficult conversations
  • Accessibility and accessible formats
  • Data protection and confidentiality
  • Relevant consumer rights legislation
  • Complaint handling and escalation
  • Products and services available
  • Support agency referrals and signposting
  • Equality, diversity, and inclusion principles

Training Schedule:

  • Initial training: During staff induction
  • Refresher training: Annually (minimum)
  • Specialist training: Vulnerable Customers Team (quarterly)
  • New policies/procedures: As they are implemented
  • Competency assessment: Annually

10.2 Complaints Handling

Vulnerable customers receive enhanced complaint procedures:

  • Single point of contact for complaint handling
  • Acknowledgement within 1 working day
  • Response within 5 working days (not 8)
  • Clear explanation of next steps
  • Regular updates during complaint process
  • Alternative resolution options offered
  • Escalation to management review
  • Independent review referral (Ofcom)

11. Service Continuity During Crisis

11.1 Emergency Support

During emergencies or crises, we:

  • Prioritise vulnerable customer support
  • Maintain service where possible
  • Provide information in accessible formats
  • Offer temporary flexible payment terms
  • Increase support team availability
  • Coordinate with local emergency services (where appropriate)
  • Keep vulnerable customers informed of disruptions

11.2 Illness or Absence

If a vulnerable customer becomes ill or is temporarily unable to contact us:

  • Support can be provided to designated representative or family member (with consent)
  • Service can be temporarily suspended (rather than disconnected)
  • Bills can be held pending recovery
  • Support arrangement continuity maintained
  • Recovery support plan discussed

12. Data Protection and Confidentiality

12.1 Data Protection Compliance

All vulnerable customer information is protected under:

  • Data Protection Act 2018
  • UK GDPR (General Data Protection Regulation)
  • Scots Law confidentiality principles
  • Our Privacy Policy and Data Protection Policy

12.2 Use of Vulnerable Customer Data

We only use vulnerable customer information:

  • To provide appropriate support and services
  • To comply with regulatory requirements
  • To improve service design and accessibility
  • To support research (anonymised, with consent)
  • For legitimate business operations

We do not:

  • Share data with third parties without consent
  • Use data for marketing purposes (without explicit consent)
  • Make automated decisions based on vulnerable status
  • Retain data longer than necessary
  • Use data for profiling or discrimination

12.3 Confidentiality and Sensitivity

  • Vulnerable customer status is confidential
  • Information disclosed only on need-to-know basis
  • Staff subject to confidentiality obligations
  • Service accessed from secure locations
  • No disclosure in shared or open environments
  • Consent required for third-party access

13. Monitoring and Review

13.1 Service Monitoring

We monitor vulnerable customer support through:

  • Regular feedback from vulnerable customers (quarterly surveys)
  • Mystery shopping of support services
  • Complaints analysis and trends
  • Staff feedback and suggestions
  • Third-party agency feedback
  • Regulatory feedback and observations

13.2 Performance Metrics

We track:

  • Number of vulnerable customers identified and supported
  • Support requests and response times
  • Complaint rates and resolution times
  • Accessibility formats requested and provided
  • Payment arrangement success rates
  • Hardship case outcomes
  • Disconnection/reconnection rates for vulnerable customers

13.3 Annual Review

This policy is reviewed annually:

  • Assessment of effectiveness
  • Stakeholder feedback (customers, staff, advocates)
  • Regulatory guidance updates
  • Legislative changes (Scots Law, consumer law)
  • Industry best practice review
  • Update and publication of revised policy

Next Review Date: January 2027

14. Regulatory Compliance

14.1 Ofcom General Condition C5

This policy complies with Ofcom General Condition C5 (Protection of Vulnerable Customers) by:

  • Identifying vulnerable customers and their needs
  • Providing appropriate support measures
  • Making information accessible
  • Offering flexible service and payment options
  • Training staff appropriately
  • Monitoring compliance and effectiveness
  • Publishing information and policies

14.2 Consumer Rights Act 2015

This policy reflects requirements under the Consumer Rights Act 2015:

  • Fair treatment of all consumers
  • Transparency of terms and conditions
  • Accessible dispute resolution
  • Protection from unfair contract terms

14.3 Data Protection Compliance

This policy complies with Data Protection Act 2018 and UK GDPR:

  • Lawful basis for processing (legitimate interest, consent, contract)
  • Fair and transparent processing
  • Data minimisation and security
  • Individual rights (access, rectification, erasure)
  • Data protection by design
  • Data Protection Impact Assessments where required

14.4 Scots Law

This policy complies with Scottish law principles:

  • Contract law fairness and good faith
  • Equitable principles
  • Consumer protection legislation
  • Disability discrimination law
  • Human rights protections

14.5 Equality Act 2010

This policy reflects commitments under the Equality Act 2010:

  • Reasonable adjustments for disabled customers
  • Non-discrimination on protected characteristics
  • Accessibility and inclusion
  • Fair and equal treatment

15. Support Agency Contact Information

We work with and signpost customers to support agencies:

Money and Debt Advice:

Health and Wellbeing:

Housing and Social Support:

Domestic Abuse:

Consumer Rights:

16. Contact Details and Access

Our Contact Details:

General Customer Service:

  • Phone: 0800 054 8330 (free to call, 08:00-20:00, seven days a week)
  • Email: contactus@optua.co.uk
  • Post: Optua Telecommunications Limited, 2nd Floor, 48 West George Street, Glasgow, G2 1BP
  • Web: www.optua.co.uk
  • Textphone (Hearing Impaired): 18001 0800 054 8330

Vulnerable Customers Support:

  • Phone: 0800 054 8330 (ask for Vulnerable Customers Team)
  • Email: vulnerable.customers@optua.co.uk
  • Response Time: Within 2 working days (or 4 hours for urgent issues)

Complaints Handling:

  • Email: complaints@optua.co.uk
  • Phone: 0800 054 8330
  • Response Time: Within 5 working days for vulnerable customers

Regulatory Matters:

Accessibility:

18. Commitment Statement

At Optua Telecommunications Limited, we are committed to supporting vulnerable customers and ensuring they receive fair, accessible, and appropriate service. This policy reflects our values and our legal obligations under Ofcom regulations, consumer law, data protection law, and Scots law.

We welcome feedback on how we can improve our support for vulnerable customers and commit to reviewing this policy annually and acting on customer feedback.

For questions or feedback on this policy, please contact: vulnerable.customers@optua.co.uk or 0800 054 8330