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Course: Supporting Vulnerable Customers in Prope...
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Supporting Vulnerable Customers in Property Transactions – England

Text lesson

Lesson 7 – Removing Barriers and Applying Procedures Fairly

7.1 Identifying barriers

Barriers may arise from:

  • Inaccessible offices;
  • Steps or narrow entrances;
  • Small-print documents;
  • Complicated language;
  • Telephone-only procedures;
  • Digital-only systems;
  • Inflexible appointments;
  • Poor website accessibility;
  • Automated identity checks;
  • Lack of alternative document formats;
  • Staff attitudes or assumptions;
  • Unnecessarily short deadlines; or
  • Refusal to communicate with an authorised supporter.

7.2 A practical barrier review

Employees should ask:

  1. What is the customer trying to do?
  2. What part of the process is causing difficulty?
  3. Is the barrier created by MyEstate’s normal procedure?
  4. Is the difficulty connected with a disability?
  5. What change would reduce the disadvantage?
  6. Can the employee authorise that change?
  7. Is a manager’s approval required?
  8. How will the arrangement be recorded and reviewed?

7.3 Consistency and individual needs

Consistency means applying the same lawful standards, not refusing every exception.

For example, MyEstate may consistently require:

  • Identity verification;
  • Affordability information;
  • Right to Rent checks;
  • Signed instructions;
  • Evidence of authority; and
  • Accurate transaction records.

However, the method used to satisfy a requirement may sometimes need to change.

A visually impaired customer may receive the same essential information as everyone else, but in a different format.

7.4 Reasonable support versus preferential treatment

Reasonable support removes a barrier. Preferential treatment gives someone an advantage unrelated to removing a disadvantage.

Reasonable support

  • Providing a larger-print application;
  • Allowing a support person to attend;
  • Explaining a process in simpler language;
  • Offering a lawful non-digital verification route;
  • Allowing additional time where practicable; or
  • Arranging a step-free appointment.

Not normally required as an adjustment

  • Ignoring essential identity checks;
  • Guaranteeing that an application will succeed;
  • Concealing important information from a client;
  • Waiving every financial requirement;
  • Accepting false or incomplete information;
  • Disregarding a genuine safety risk; or
  • Acting unlawfully.

7.5 Right to Rent and alternative processes

Right to Rent checks must be carried out consistently. Where lawful checking routes differ, applicants should not be disadvantaged because they require a manual check, online check or Home Office service.

Staff must follow the version of the official guidance applicable on the date of the check.

Lesson 7 key point

Fair procedures preserve essential requirements while changing the method of access where reasonably necessary.