Written evidence submitted by Barclays Bank PLC (CAF0023)

Contents

Introduction

Supporting vulnerable consumers…………………………………………………………p.4

Access to banking……………………………………………………………………………p.6

Driving accessibility………………………………………………………………………….p.14

Ensuring fair and equal products and services……........................……………………………….p.17

Introduction              Barclays welcomes the opportunity to input into the Treasury Committee inquiry into consumers’ access to financial services. As a consumer markets business with a relationship with over 24 million individuals in the UK, we understand the importance of providing fair and accessible products and services to all of our customers.

Introducing Barclays

As a transatlantic consumer and wholesale bank, we offer products and services across personal, corporate and investment banking, credit cards and wealth management. We are headquartered in London and New York, operate in over 40 countries and employ 85,000 people globally. However, despite our global reach, our longest consumer markets experience has been in the UK. Barclays has been part of the fabric of the UK for over 327 years, and our success as a business has always been inextricably linked to the progress of the people and the businesses we serve.
 

Our relationship with over 24 million individuals in the UK provides us with a strong understanding of modern consumer patterns, and the changing trends in their behaviour which are dictating how modern consumer products and services must evolve and adapt. In addition, we have a relationship with one in every four UK businesses, with over 50 industries benefitting from dedicated relationship teams across Barclays Group. In 2017 we supported UK SMEs with £2.8bn of new lending and helped over 98,000 start-ups establish themselves, thrive and grow. We are also the UK’s largest provider of services to UK merchants – with over 1m relationships, representing c20%of the UK’s retail market. Whether it is a partnership, medium or large business, multinational corporation or financial institution, Barclays works to support business owners and leaders to realise their ambitions.

Moreover, we are one of the largest long-term lenders to the public sector in the UK, last year raising over £600m for universities, colleges and schools, adding £13.6bn to the UK economy overall.

It is from this unique vantage point – as a large and experienced modern consumer services company, a champion of the UK consumer and a provider of services to so many other businesses that succeed by serving the UK consumer well – that we seek to support this inquiry.

Supporting vulnerable consumers

Defining vulnerability (Q.1)

Barclays works to the same definition of vulnerability as the FCA, namely: ‘Any potential or existing customers who, due to their personal circumstances, e.g. financial difficulty, long-term medical conditions, or other personal circumstances, are especially susceptible to detriment’.

The definition is necessarily broad to reflect the reality that vulnerability is not black and white – it can be permanent or temporary, and a customer could be vulnerable in some types of interaction with their bank (e.g. applying for a loan) but not in others (e.g. paying in a cheque).

This means there is no ‘one size fits all’ approach to ensuring the right outcome for vulnerable customers. Barclays tailors its approach accordingly, with some examples of differing scenarios below

1. Business as usual: There may be circumstances where the member of staff supporting a potentially vulnerable customer should carry on as normal, as the activity being carried out is not affected by the vulnerability and therefore no unusual action should be taken.
2. Change the ‘how’ but not the ‘what’: Equally, there will be circumstances where it is appropriate for the member of staff to alter how they interact with the customer, but not what they actually do, e.g. speak slower, be more patient, take the customer to a private meeting room and show increased levels of empathy.
3. Change the ‘how’ and the ‘what’: And finally, there will be customers whose vulnerability requires the member of staff to change what they do as well as how they do it, e.g. declining a lending application as the customer does not understand the product they are applying for at that point in time.

Ensuring customers in vulnerable circumstances get the right outcomes in interactions with their bank is about ensuring all customers get the right outcome for their needs, whatever their circumstances. Bank products, services and processes must be flexible enough to accommodate the needs of all our customers.

Identifying vulnerability

As outlined throughout this response, Barclays has extensive work in progress to support customers in vulnerable circumstances, while facing significant challenges in identifying those customers. Many customers in vulnerable circumstances do not inform us of their circumstances and we face significant limitations in inferring vulnerability based on customer interaction and behaviour.

In any inferences we make, Barclays has to be mindful of sensitivities around use of data, as well as the requirements we have under GDPR. Whilst there may be some clear indicators of vulnerability, making broader inferences runs the risk of making misleading assumptions which could lead to consumer detriment.

The need for caution is further supported by forthcoming consumer research Barclays commissioned from GfK which found that, whilst consumers were generally supportive of banks using data to identify vulnerability in some instances, vulnerable consumers expressed concerns about their data being used to spot signs of vulnerability for fear it may lead to further detriment.

Shared responsibility group-wide

Our Group-wide policy makes clear the responsibility of every part of the business in ensuring the right outcomes for their vulnerable customers. Whilst this requires services and processes to contain sufficient flexibility to accommodate different needs, we also know that many customers in vulnerable circumstances can benefit from mainstream interventions being delivered for all of our customers. Examples of this include: 1) New functionality on our debit cards which allows customers to block cards or turn off remote purchases in our mobile app; 2) Secure chat in mobile banking, which allows customers with hearing loss or mental health problems to communicate securely with Barclays colleagues without having to speak to someone on the phone.

In addition, we have a specific customer segment team within Barclays UK focused on developing new propositions to enhance how we support customers in vulnerable circumstances, including disability, financial vulnerability and mental health. Key areas of the bank such as Fraud and Barclays Financial Assistance also have specialist vulnerable teams to support customers in these particularly stressful circumstances.

Case study:

Training and practices to support vulnerable consumers (Q.2)

Colleague training and education:

Over the past 18 months there has been a significant investment in colleague learning to ensure customers who may be vulnerable receive the right outcome. Barclays have worked closely with external organisations such as the Money Advice Trust to ensure this learning is fit for purpose. This training includes:

1. An annual e-learning module and accreditation for customer-facing roles, which covers:
• What is vulnerability;
• How to spot it; and
• How to support vulnerable customers and clients.
   
2. In-depth training for colleagues most likely to engage with vulnerable customers: Colleagues in the vulnerable teams across all portfolios within Barclays Financial Assistance receive two days of face to face training covering a range of skills, including:
• How to recognise a customer in distress or who may be vulnerable;
• Being able to empathetically engage with vulnerable customers;
• Understanding and being alert to a range of mental health conditions, and being able to apply the Mental Capacity test;
• Identifying the appropriate level of support and solutions to different customer’s needs and circumstances.

This approach is supported by specialist vulnerability teams in areas of the bank that manage circumstances which could be particularly difficult for a customer, including fraud and scams and arrears management. These teams receive an additional level of training on vulnerability. For example, within our mortgage arrears department, colleagues have been given specific guidance on how to support a customer who has indicated that they are suicidal or who have stated they are at risk of harming themselves. 

Reviewing and enhancing our training materials

To ensure our colleagues remain properly equipped to identify and support our customers in vulnerable circumstances, we regularly review and enhance training content as well as consider the most effective delivery mechanisms. To this end, refreshed training is due to land in the first half of 2019 that we hope will see 20,000 customer-facing colleagues across Barclays receive face-to-face training on customer vulnerability. Topics to be covered include understanding, identifying and offering appropriate support with regard to various forms of vulnerability. This includes financial ill-health, disabilities, mental health and financial abuse, as well as how to support these customers both within the physical branch and via a virtual channel. 

Supporting our colleagues

Colleagues are also supported by a range of mechanisms, including additional online learning material and knowledge tools, that give them instant access to more detailed information on support, processes, our range of services and how to direct customers to the appropriate external agencies that can help. Colleagues in our Customer Support teams in credit cards, overdrafts and loans have also recently had training from Samaritans; focusing on their own colleague well-being when supporting our vulnerable customers.

The merits of a ‘duty of care’ for financial services providers to increase protection for vulnerable customers (Q.3)

We believe that a duty of care is not currently needed in light of the wide range of measures currently in place. The FCA’s existing framework is sufficient to protect consumers and it is unclear how a new duty would apply in practice or result in different outcomes for clients.

The FCA has a broad and flexible existing toolkit which is sufficient to protect consumers including those who might be classified as vulnerable.

There are a number of regulatory developments which have either been recently introduced (such as the Senior Manager & Certification Regime) or are yet to be implemented (such as the FCA’s guidance on vulnerable clients) which address perceived historic failures. These initiatives have not yet been given time to properly bed down nor to be properly evaluated. We therefore recommend that this review should be delayed until the existing initiatives can be fully evaluated.

The introduction of stricter rules – in effect of an over-arching new duty – would hinder firms' ability to apply flexibility in their approach to supporting customers and could result in firms introducing additional checks and balances which are designed to mitigate increased litigation risk that may arise, for example, by claims management companies.

We do not think that the introduction of a new duty will be more effective than the FCA's existing regulatory toolkit in preventing harm, however support work that the FCA might undertake in refocusing its existing tools to better prevent harm, that could as a consequence reduce redress.

Access to banking

Promoting financial inclusion and capability

Barclays recognises the importance of financial inclusion and capability, and as such has a long-standing commitment to both. We also recognise the importance of drawing a distinction between financial capability (people having the confidence and know-how to manage their money) and financial inclusion (people having access to banking services, as they need) to enable comprehensive management of both issues.

Groups at risk of financial exclusion have historically included those who have difficulty providing proof of address, customers with disabilities, and people in financial difficulty or bankruptcy who struggle to access some mainstream services, such as credit. However, new groups may be at risk of exclusion, in particular customers without digital access and skills. Those without internet access are also increasingly vulnerable to financial exclusion as a result of digital exclusion.

Products which promote financial inclusion

Before requirements existed for us to provide basic bank accounts we provided accounts that people in bankruptcy, financial difficulty or for other reasons were not eligible for a standard account could use. Historically we have had a disproportionate share of these accounts (although this is rightly changing with requirements for all major banks to provide basic bank accounts).

We promote our basic bank account on parity with our standard current accounts and it offers customers many of the tools and functionality our standard account customers have (e.g. cards hub- giving customers control over how their cards are used, setting their own ATM limits and turning off international transactions). Further details of this product is set out below.

Alongside basic bank accounts our commitment to financial inclusion is demonstrable by:

• Our product set, which includes: Barclaycard Initial Credit card for customers with little credit history, and our Help-to-Buy, Shared Ownership and Springboard mortgages, helping aspiring first-time buyers get on the property ladder where they might otherwise have struggled.
• Our commitment to an omni-channel approach, including: online, telephone banking and in our branches. We recently successfully lobbied for stronger measures around financial inclusion to form part of LINK proposals for ATMs.
• Championing of Credit Unions: We are in our final year of a four-year programme to support credit unions through capacity building and improving financial capability and resilience in the sector. In this we have delivered robustly evaluated training and direct support to 60 credit unions. We are now focusing on ten of these in the final year and will be offering local Credit Union Champions to mentor and support credit unions.

The increasing link between digital and financial inclusion

The digital revolution means that financial inclusion and digital inclusion are increasingly intertwined. Even with a strong physical presence through bank branches, telephone banking and Post Offices, customers with digital access will have more functionality within, control of and choice between the services they use. With the advent of open banking and the drive towards an increasingly data driven economy, as outlined in the Government’s Consumer Green Paper, there is a real risk that a new gulf in financial inclusion opens up between those who have digital capability and access and those who do not.

See below (Q 5 & 7) for more information on how our Digital Eagles are helping communities, both customers and non-customers, become more digitally confident.

Barriers to consumers having a bank account (Q.8)

Barclays basic bank account

As previously mentioned, Barclays has a longstanding commitment to providing accounts for people who would otherwise face barriers opening or accessing bank accounts, and have offered a basic bank account since 2000, when it was known as the Barclays Cash Card Account.

In December 2015, we replaced the Cash Card Account with our new Basic Current Account which meets HM Treasury’s Memorandum of Understanding on basic bank accounts. These financial inclusion accounts are designed to provide access to transactional banking to consumers who might otherwise struggle to access a mainstream account, including consumers who have experienced a serious financial event, such as bankruptcy. They are available to anyone who does not already have a bank account in the UK or who is not eligible for a standard account.  Since September 2016, this account has also been available to non-UK EU residents, as required by the Payment Accounts Directive.

Our Basic Current Account is positioned with equal prominence to our standard current account on our website and in our product literature.  It provides much of the same functionality as our standard current account, including over-the-counter services (at Post Office counters as well as our own), access to the ATM network and digital banking.  It also offers free text alerts to help customers manage their money and stay in control of their finances.  There were more than 674,000 Barclays Basic Current Accounts open at the end of 2017.

We will normally provide a bank account to anyone who provides acceptable evidence of identification and proof of address and does not have a record of fraud. 

Barriers to those without a bank account

The specific barriers for consumers without a bank account are varied, including a lack of financial capability. Barclays has been at the forefront of work to tackle this, including:

• Support for prisoners: Barclays knows that many people in prison may struggle to access banking on their release.  We work with the National Offender Management Service to enable prisoners approaching release to open basic bank accounts.  This programme, to which other major UK banks are signatories, was developed following a successful Barclays prisoner banking pilot with a number of UK prisons.
• Supporting Armed Forces personnel: We have a longstanding commitment to ensuring banking is accessible for members of the armed forces and those leaving the services, who we know may face challenges because of lack of fixed abode and frequent deployments overseas.  Our services for these customers include flexible forms of third party access and account access for service personal overseas or on deployment.
   

The future of banking is changing (Q.5 and Q.7)

Changing consumer behaviour is leading to a reduced branch network

There is no doubt that the rapid growth of digital is changing customer behaviour and expectations, meaning the way that businesses deliver their services is changing too. The digital revolution has led to an adjustment in customers’ banking expectations, and Barclays has responded by creating leading digital banking products and services – ready to support our customers wherever they are, whenever they would like.

As a result of this shift, our overall branch network is reducing, while remaining a core part of our offering. And for those who are reluctant to ‘go digital’, we maintain a strong high-street presence (with still the biggest branch network of any banking brand in the UK), a 24 hour, seven day per week phone service and a dedication to digital education and safety across all our channels.

In the instance of a branch closure, we work hard to manage the transition closely with the local community. This includes:

1. Community stakeholder engagement, both pre and post-closure support;
2. Promotion of suitable face-to-face alternatives; and
3. Support to transition to digital banking.

Here we will take each in turn.

Advance notice and pre-closure support

When the difficult decision is made to close one of our branches, we work hard to support the local community with this transition, reaching out to identified key stakeholders within the community (at the point of announcing our decision and during the closure countdown period) to understand the potential impacts that the closure may have on the local community. We seek to ensure customers experience as little disruption as possible, and that suitable measures are taken to support vulnerable customers in particular.

We have a range of customer notifications and communications to provide a minimum of 12 weeks’ advance notification of the branch closure which includes promotion of all of the alternatives that are available to customers locally. We are committed to and comply with the UK Finance Access to Banking Standard and publish a ‘Reason for Closure’ booklet at the time of announcement, and ‘Branch Closure feedback’ booklet two weeks prior to physical closure. This enables us to share the feedback we have received and actions we have taken to address any concerns raised.

As part of any closure, customers who have been identified as being dependent on the branch or who we believe will be at increased risk of vulnerability due to the closure are proactively contacted to discuss the various alternative options available and support them in accessing these. The alternatives include: 1. Other nearby branches; 2. Mobile and digital banking – supported with the help of our Digital Eagles; 3. Use of a local free-to-use ATM or 4. Use of the local Post Office, which offers many basic banking services to the local community.

Our ambition is to ensure customers understand the most appropriate alternatives available to them, and how to access such services moving forward.

Promotion of suitable face-to-face alternatives such as the Post Office

Barclays recognises that when a local bank branch closes some customers will continue to want to use face-to-face services on their doorstep, such as the Post Office. To ensure strategic and holistic marketing and communications of this service, Barclays has worked with UK Finance and industry peers to develop a five-point plan, with the ultimate ambition to raise awareness of the banking services available at Post Offices across the UK.

The five-point plan promotes awareness of the Post Offices’ day-to-day banking services, which includes the ability to pay in and withdraw cash, and where bank and building society customers can access up to at 11,500 Post Office branches across the UK. It has also delivered a series of co-ordinated activities, including targeted media campaigns, local community events and enhanced support for vulnerable customers who benefit most from the service. The broad ambitions of the plan are to:

• Raise awareness of banking services available at the Post Office via regional and targeted localised media campaigns;
• Support specific communities, including those impacted by bank branch closures, through information leaflets, joint Post Office and bank outreach and improved collaboration between the Post Office and the bank;
• Promote the Post Office as an integral channel for day-to-day banking, with clear and prominent information for customers in literature, on websites and via our telephony channels;
• Provide enhanced support for vulnerable consumers based on Citizens’ Advice best practice guidelines; and
• Carry out ongoing monitoring of awareness and confidence in the Post Office counter service.

After a branch closes, we monitor how impacted customers continue to access our services and our experience shows an increase in use of Barclays Mobile Banking as well as online banking more widely. We recommend continued collaboration and support between the banking industry and parliamentary representatives to continue to raise awareness of the Post Office services.

Support to transition to digital banking

As part of consumers’ broader movement away from physical bank branches and towards digital banking (our data shows that we experience up to 28 digital transactions per second and counting – with the average customer visiting a branch less than two times per month) – we recognise the importance of supporting the transition to digital banking of those who are less digitally savvy.

Our nationwide network of Digital Eagles has led the industry on digital empowerment since their formation in 2013. We now have over 18,000 individuals qualified as ‘Digital Eagles’, and thus experts in all-things digital banking. This network of volunteers are passionate about up-skilling and empowering our customers, colleagues and local communities to be more confident with technology in order move forward in the digital world. They deliver a wide range of future skills no matter where consumers are on their digital journey, and importantly, also support consumers to stay safe online.

Digital banking now enables our customers to manage their money 24 hours a day via our online banking service or by downloading our Barclays Mobile Banking application. Our mobile banking app has been chosen by over seven million customers and our Digital Eagles provide support to all customers so they can benefit from using this service. They also work closely with local branch colleagues to raise awareness of how to use technology and avoid internet fraud, whether via group sessions or on a one-to-one basis.

Supporting vulnerable consumers to prevent financial exclusion (Q.4)

We understand that when a bank branch closes it can risk the feeling of detriment among the local community, and in particular amongst customers who rely heavily on the closing branch. Such detriment includes longer distances to travel to the nearest branch, and a sense that basic access to banking has become more problematic, particularly for those who are not confident using digital channels.

As part of any closure, we work hard to prevent this sense of detriment, and offer additional support to consumers who may be particularly vulnerable to such a transition.

Identifying consumers’ who may be particularly vulnerable when a branch closes

This additional support begins before any branch closes. We identify customers who are active users of the branch, and then further screen this customer group to identify those customers who:

• Based on their transaction history appear to be dependent on the branch i.e. those who only transact over the counter in the closing branch, who do not use any other services, and who have completed 12 transactions or more in the last three months.
• Have registered a Power of Attorney with us, have a Chip & Sign debit card, or who receive braille, large print, or audio communications from us.
• Use the bank’s existing Vulnerable Customer marker capability, who already have an existing marker registered, all of whom may have an increased risk of vulnerability due to the closure.

Supporting customers during a branch closure

The alternative options and support on offer for such customers is discussed as part of their normal visits to the branch by the local branch team, and if after six weeks the identified customers have not visited the local branch, the local team will reach out via letter or telephone to arrange a face to face meeting for them to discuss the transition in their banking needs and to support them with this transition.

This meeting will cover the alternative options available to these customers, the identification of which are the most suitable alternatives for them based on their individual requirements, and to ensure that they have everything they need to access such alternatives. Alternative options include:

• Other nearby branches;
• Mobile, digital and telephone banking – supported with the help of our Digital Eagles;
• Use of a local free-to-use ATM; and
• Use of the local Post Office, which offers basic banking services to the local community.

As stated in the ‘Driving accessibility’ section of this paper, Barclays makes it a priority to be easily accessible to all consumers, no matter what their circumstance, which becomes even more important during a branch closure.

The impact of reducing the number of free-to-use ATMs on vulnerable consumers (Q.16)

LINK UK has recently announced pricing changes designed to maintain and re-balance the UKs ATM network; shifting incentives from ATMs in city centres to rural communities, and deploying ATMs to strengthen and increase the geographical ATM coverage across the UK. The plan to pay an enhanced subsidy to ensure ATMs are distributed in locations that could not otherwise sustain them, is seen as fundamental to the ongoing provision of cash (in addition with the Post Office) to rural communities and vulnerable customers.      

Barclays is committed to supporting continued to access to free-to-use ATMs in local communities across the UK, and in the last 12 months we have installed seven remote ATMs in the following communities: Cavern Arms, Barmouth, Loddon, Shifnal, Moston, Wolsingham and Llanwrst.

Managing the systems and controls in place for Power of Attorney (Q.9)

A dedicated specialist team within Barclays manages all forms of delegated authorities, including Powers of Attorney for personal customers. The team uses a specific training and accreditation framework which is applicable both for new starters and for the ongoing development of colleagues. This training covers both a customer’s particular situation i.e. their specific vulnerability, as well as the technical and legal aspects associated with some forms of powers of attorney.

We know that a number of customers use the branch network to initiate both discussions and requests about delegated access. In response to this, we introduced an application (app) in May 2017 to enable the automatic set up of "informal" delegated arrangements known as third party authorities and simple powers of attorney. The app also enables the set-up of a case for more complex arrangements/powers of attorney. Currently, the team undertake a 100% quality check on all delegated authorities automatically set up by the application.

All postal requests and arrangements are handled directly by the dedicated team. The team also provides specialist support to colleagues on the process as well providing a dedicated help line for customers.

There are presently 19 automated controls to ensure the power of attorney is applied correctly. The team complete two specific attestations for the FCA’s Consumer Credit sourcebook, CONC:

• Monthly to confirm that the end-to-end process is operating in line with expectations in relation to mental incapacity and the appropriate marker has been applied on the account.
• Annually to confirm procedures and letters are up to date with present regulations/requirements.

The team are also in regular contact with the Office of Public Guardianship ("OPG") when requiring advice on a specific case/document and also to understand any industry trends or potential changes to documentation etc.

How Barclays complies with equality legislation and the mechanisms for enforcement (Q.10)

The characteristics protected by the Equality Act overlap with the definition of vulnerability, but obviously without matching it precisely. Compliance with the Act is embedded in our product design and ongoing product governance processes, meaning that we consider equality legislation when launching, materially changing, or reviewing our products and services. Besides Legal colleagues, our accessibility team operates as a centre of excellence with regards to protected characteristics that may impact customers’ ability to access our products physically (such as disability or age).

In terms of the enforcement of the legislation, we would observe that we see more activity in financial services among consumers (in terms of challenging banks to improve) rather than via direct action by the Equality and Human Rights Commission. Broadly speaking, our view is that this reflects the fact that the focus on customer vulnerability encompasses Equality Act compliance and has driven improving customer outcomes.

How regulators hold financial services providers to account for how they treat vulnerable customers, and instruct financial services companies to comply with equalities legislation (Q.11)

The FCA has a broad and flexible toolkit covering rules, principles, guidance, speeches, supervision and enforcement powers (including competition powers) plus a host of other letters and materials. We note that many of these are in the form of high-level guidance/principles which can be applied by the FCA as appropriate and depending on the specific scenario.

The FCA announced in its “Approach to Consumers” that it would be consulting on and publishing formal regulatory guidance on customers in vulnerable circumstances. We welcome this guidance, as it was a key ask of industry to help ensure approaches meet regulatory expectations and provide consistency across industry. This guidance, once published next year and given time for implementation, could have significant impact on treatment of vulnerable customers by firms.

Driving Accessibility

Driving the accessibility of our products and services through our marketing and communication channels, and via technological innovation (Q.6 and Q.12)

The ambition to be accessible to all

We understand the importance of ensuring that our marketing, communications and support services are accessible to all consumers, including vulnerable consumers, and take measures to make sure that this is the case. Our aim is to be the most accessible and inclusive Bank, which means endeavouring to create barrier-free access to all products, services and channels for customers – regardless of any access need they may have.

Barclays follow internationally recognised accessibility guidelines (WCAG) in the design and development of our online banking website and mobile banking apps, ensuring that digital channels and content are accessible to and usable by the widest audience possible. To check our efforts, we carry out independent accessibility accreditations by AbilityNet (a leading accessibility consultancy), demonstrating that we are serious and committed to accessibility.

Accreditation involves external accessibility experts as well as real-world disabled people doing user testing on our online banking website and mobile apps, resulting in issues being identified and addressed. This results in the platform being compatible with assistive technologies like text-to-speech software used by visually impaired customers and also ensures digital content is responsive so that text size or colours can be easily adjusted. 

Accessible products and services

In addition to adhering to best practice accessibility standards, we have been at the leading edge of offering new services which remove historical barriers – with our approach being to go beyond the legal minimum to ensure that customers receive an equal, accessible and excellent customer experience. In the last six years we have been first-to-market with the following services:

• Talking ATMs – c.4000 across the UK.
• Instant sign language: Interpretation for Deaf people from home and in-branch. If a consumer uses British sign language they can use our SignVideo service, which securely connects to a BSL interpreter who can translate the sign language to one of our colleagues. See Services for people with hearing or speech impairments
• High Vis and tactile debit cards to help people with low/no vision, dyslexia/dyscalculia etc.
• Lip Speaker service to allow deaf people who don’t use BSL to have a third party relay for them when calling us.
• Dexterity difficulties: If a customer uses online banking and has access needs, we offer a fully accessible talking PinSentry security token to assist customers with a range of sight or dexterity difficulties.

Innovation with big accessibility potential

In addition to services specifically designed to remove access barriers for disabled customers, many innovations will also have disproportionate benefit for disabled customers, including:

• Mobile banking: As mobile banking becomes increasingly popular, we’ve received great feedback from customers with access needs who appreciate the streamlined services and simpler information served up to them through a smaller smartphone screen. Built-in accessibility settings within smartphones have improved significantly too, enabling users to personalise their experience.
• Money management tools within mobile banking also helps customers understand, manage and make the most of their money, easily seeing recent transactions, their location or having transactions grouped by category such as bills or leisure. 
• Fingerprint and face recognition: Simpler security through fingerprint or face recognition is of significant assistance to those customers with learning or cognitive difficulties. 
• Our omni-channel approach: The provision of multiple communication channels to get in touch also removes barriers to access. For example, customers can instigate a direct phone call within the app or instant messaging a call centre agent directly through our mobile or online banking platforms. These are popular with customers with hearing or speech difficulties as well as mental health issues. Not having to repeat ID processes also makes these channels popular with customers who struggle to remember passwords and PINs.
• Mobile cheque imaging: New features like mobile cheque imaging are proving particularly beneficial for customers with mobility difficulties who would otherwise struggle getting to their local bank branch. It’s not just convenient but transformational for a wheelchair user who can now take a photo of a paper cheque and have it processed and paid near instantly.
• Open Banking also provides greater choice and control for Barclays customers to aggregate and view their accounts from other banks in one accessible place in our mobile banking app.
• Video banking and voice payments are starting to be rolled out more widely too – helping those who may not be so confident with technology to do their banking digitally.
• Voice recognition technology: Designed to make telephone banking easier for all our customers, but of transformational benefit to customers who find it difficult to remember password information. The technology enables us to confirm their identity using voice recognition technology when they call us, so that they don’t have to go through security questions.
• Contactless wearables: bPay is a range of contactless wearable devices that let consumers make fast and secure payments. They’re designed for everyone, including people with mobility or dexterity limitations, sight loss or dyslexia, and the user doesn’t even need to have a Barclays or Barclaycard account as they can be linked to most major UK debit or credit cards and managed online or via our bPay app. The devices come in the form of a wristband, key fob or sticker to pay for anything up to £30 wherever you see the contactless symbol.

Supporting those with low levels of literacy

We recognise that people with low literacy skills or learning difficulties may be able to manage basic finances, but need more guidance and instruction for doing so. This is why we have worked with the British Institute of Learning Difficulties to produce an Easy Read guide to simple banking transactions and processes (‘Banking Made Clearer’). It uses clear language and illustrations to explain how consumers can carry out their everyday banking, and is available at no cost in-print or online:

https://www.barclays.co.uk/content/dam/documents/personal/accessibility/BAR_9913024_UK_Hi_Crop.pdf

Barclays is also a member of the Plain English campaign, which supports the full accessibility of banks and building societies for all consumers:

http://www.plainenglish.co.uk/services/crystal-mark/crystal-mark-holders/876-banks-and-building-societies-with-crystal-marks.html.

Further information on our accessibility services

Full details of the additional accessibility services and support we offer customers are available online at www.Barclays.co.uk/accessibility and in a dedicated section on our mobile banking app, as well as in our vulnerability service information : https://www.barclays.co.uk/important-information/vulnerability-services-information/.

Ensuring fair and equal access to products and services

Reducing complexity and increasing transparency (Q.13)

Barclays considers that increasing transparency and decreasing complexity is key to ensuring that customers properly understand the products they are purchasing, alongside offering additional support to customers at the point at which they are purchasing these products if required.

For example, with respect to savings accounts, the industry has worked with the FCA in undertaking considerable change to provide clarity and transparency for customers with the aim of making switching easier and helping customers to make informed choices. This has included the provision of detailed summary boxes, one click access to interest rates online, faster internal switching and cash ISA transfers, and enhancements to customer notifications for interest rate reductions including 14 day reminders.

Simplifying our product range

In addition, since 2014 Barclays has been radically simplifying its product range, working to remove duplication and aligning pricing of products with similar features. For example, in savings this has resulted in the removal of approximately 40 products from the range, helping to support customers who are “more likely to defer choices when faced with complexity”. In credit cards we now have a reduced and simplified set of products available for new customers with a clear explanation of how each can help the customer meet their goals. Barclays is aware that some providers still have large product ranges, which can make it difficult for customers to identify whether they are on the most suitable product.

In the mortgage market, where product ranges typically reflect greater variety and options, nearly all customers securing a Barclays mortgage against their residential home receive advice when borrowing funds. Advice incorporates an assessment of suitability and product recommendation based on the customer’s circumstances, preferences and needs, either from a qualified Barclays mortgage adviser, or intermediary. Barclays mortgage customers continue to be supported through their mortgage term with the availability and accessibility of further advice, should it be required, which is signposted through a variety of customer communication channels in advance of any scheduled changes to their rate.

Supporting staff to support customers

All frontline staff are trained to identify vulnerability/ mental capacity limitations so additional support can be provided to customers during the application process as required.  

Online, the customer is presented with a message and contact telephone number if they require additional support. If there is a concern as to whether a customer has the mental capacity to understand the financial decision they are making the call will be conferenced into the Specialist Support Team. The Specialist agent will then use specialist questioning techniques to determine if the customer has capacity to understand the financial decision they are making, and will advise the application agent if the application can continue based on their assessment.

Ensuring vulnerable consumers do not pay prohibitively more for financial services products, including travel and home insurance, and have appropriate and affordable access to credit (Q.14, Q.15)

Barclays takes very seriously its responsibilities towards vulnerable customers and does not penalise such customers by charging higher prices. Barclays has a strong track record for its commitment to vulnerable customers, including our Group-wide policy, mentioned above, which makes sure every part of the business responsible for ensuring the right outcomes for their vulnerable customers.

Fair pricing structures

Barclays agrees that it is important for businesses to consider carefully the needs of vulnerable customers in the development of their products and pricing strategies.

For example, with regard to home insurance specifically, Barclays delivered important changes to its pricing in 2014, introducing a ‘defined upper limit’ for home insurance premiums. This caps the amount of profit earned by Barclays and its underwriting partner Aviva, which in turn means that customers’ premiums are not subject to unreasonable increases year-on-year. This change benefits all Barclays’ insurance customers, in addition to vulnerable consumers.

Appropriate and affordable access to credit

Barclays takes very seriously its responsibilities towards vulnerable customers, and where customers request either a new credit line, or an extension to their existing credit we do not discriminate based on information a customer has chosen to share about their vulnerability, as long as the customer has the mental capacity to make that decision. Likewise, the price we charge is not impacted based on a consumer’s vulnerability.

Of course, where a customer’s vulnerability impacts their affordability, as a responsible lender we will not lend to customers where it would not be affordable for that customer.

In addition, through our new product approval process, colleagues consider the needs of vulnerable customers and ensure that all new products are meeting these needs. This, alongside the support mechanisms for vulnerable customers at point of acquisition as detailed in question 13, is designed to ensure that vulnerable customers are supported to access credit where appropriate and affordable for them.

How regulators assess whether financial services providers are providing products to consumers at a fair price (Q.17)

The fairness of pricing of financial services products is the subject of scrutiny by the FCA, of which some examples are provided below.  When regulators design any intervention to assist such customers, Barclays considers that it is important to consider carefully whether this could lead to any unintended consequences for customers and providers (including new entrants or smaller players) and to ensure that any interventions which are designed to (or could be expected to) alter the competitive dynamic, including the potential for innovation, are justified and proportionate.

Examples of scrutiny of the fairness of pricing of financial services products include:

• Fair Pricing in Financial Services (DP18/9) – This paper is intended to prompt public debate on the fairness of certain pricing practices in financial services, with particular focus on any potential disadvantage to ‘the most vulnerable and least resilient consumers’.  The FCA have requested comments by 31 January 2019.

• General Insurance pricing practices market study – on the FCA launched a market study in relation to how insurers charge home and motor insurance customers in October 2018. 

• Cash savings -  Following on from its 2015 market study, the FCA continued its scrutiny of the cash savings sector through its discussion paper DP18/6 “Price discrimination in the cash savings market”. If the FCA decides to take a proposal forward, it will publish a Consultation Paper in early 2019.

In addition, the Competition and Markets Authority (CMA) is currently considering a super-complaint submitted by Citizens Advice in September 2018, which argues that consumers pay a “loyalty penalty” in relation to broadband, mobiles, home insurance, mortgages and savings. The CMA has until 27 December to respond.

Conclusion

Barclays will remain committed to consumers’ access to financial services in changing times. As noted above, we are dedicated to supporting fair and free access to banking for all consumers, and will continue to work hard to be the most accessible bank in the UK.

We support the work of the Treasury Committee in exploring these issues further, and would be happy to discuss in detail as is useful. 

Submitted December 2018