The bottom-line benefits of inclusive design
Good for people, good for growth (and mandated by the FCA)
Hi! 👋 Welcome to The Navigator. A newsletter about people, psychology and design for business leaders who want to make meaningful change. I’m Sarah Ronald, and I write this newsletter with the Nile team.
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No-one wants to think of themselves as vulnerable.
Every day, people silently suffer through depression, bereavement, heartbreak, poverty and illness without breathing a word of it to their friends and family.
They feel ashamed for not being able to “just deal with it”, which only compounds their negative feelings. Studies from psychology tell us that shame makes us cast everything in a negative light, causing us to withdraw and isolate ourselves. And isolated, vulnerable people can make bad decisions, fall for scams or simply be self-destructive.
Organisations often have an ethical or regulatory responsibility to protect vulnerable customers - none more so than financial service providers. But if you’re already quietly hiding vulnerability from families and friends, are you really going to chat to your bank, call your lender, or email your mortgage provider about it?
I know I wouldn’t. I doubt you would, either.
It’s why the Financial Conduct Authority (FCA) issued new guidance on the fair treatment of vulnerable customers earlier this year. We got very excited about these regulations at Nile (we’re cool like that); they’re pretty revolutionary in their conception of vulnerability, and pose a serious challenge to financial services providers.
That’s right: we’re talking about financial regulation this week. Strap in.
Regulating the invisible
It’s probably no surprise then that most business leaders - when pressed - say they don't understand who their vulnerable customers are (or even what it means to be a vulnerable customer).
And honestly? I understand. When customers are actively trying to hide vulnerability, how can you reasonably be expected to discover it? The FCA’s own guidelines point out that “consumers may not want the label ‘vulnerable’ applied to them.”
But there’s another challenge here.
Take a look at the FCA’s table below. Vulnerability is driven by characteristics as broad as health conditions, bereavements, job losses, or relationship breakdowns.
The FCA’s conception matches our own research in this area. ‘Vulnerability’ is far broader, more transient and situational than most of us intuitively understand it. Instead of being a permanent or semi-permanent state of affairs, vulnerability comes and goes. It changes as our context changes. It can fly completely below the radar.
And when you understand vulnerability this way, organisations have a problem. They face a huge degree of hidden intersectionality within their customer base, and it’s largely invisible to everyone involved.
So what can you do?
Let’s imagine you run a bank (this won’t be hard for some of our readers).
You’re regulated by the FCA.
From mid-2023 you need to protect all and any vulnerable customers from harm by your services.
Any one of your customers could be vulnerable at any time, and you have no way of knowing it.
You might think this sounds unworkable. But it doesn’t mean the FCA is wrong to prescribe this definition of vulnerability. In fact, we praised their broad conception of vulnerability shortly after they published.
Instead, the bullet points above leave you with just one reasonable option: you need to re-examine all your customer touch-points through an inclusive design lens: what if every customer was a vulnerable customer?
This is an “inclusive by default” approach.
Inclusive Design & the Curb-Cut Effect
It’s easy to think of designing for vulnerable users as purely an ethical or regulatory responsibility. Either is a more than sufficient reason to build an inclusive design practice in your organisation.
But inclusive design also makes straightforward business sense, for simple reasons: when your business is open, safe, and usable by all, more people can access your products and services.
In the same way that organisations with diverse talent outperform their less diverse counterparts on profitability, we fully expect organisations which build successful inclusive design practices to outperform their less inclusive competitors.
It’s a well known phenomenon in accessibility circles, known as the “Curb-Cut Effect”. Coined by PolicyLink CEO Angela Glover Blackwell, the term describes the universal take-up of street ramps (or curb-cuts) after they were initially installed to make streets more accessible to wheelchair users:
“When the wall of exclusion came down, everybody benefited—not only people in wheelchairs. Parents pushing strollers headed straight for curb cuts. So did workers pushing heavy carts, business travellers wheeling luggage, even runners and skateboarders.”
The Curb-Cut Effect
Angela Glover Blackwell, Stanford Social Innovation Review
(recommends a classic episode of the 99% Invisible podcast on curb cuts if you want to learn more about this revolutionary inflection point in urban design).
Service users rely on accessibility features for their day-to-day work. And nearly all of them will be vulnerable or face accessibility challenges in different situations and at different times while using your services.
So by designing products and services with inclusivity at their heart, not only will you be ethical and compliant, chances are you’ll also outperform your competitors, providing services people prefer to use.
Inclusive design is just good business.
One action to take today
Working in financial services? Ask yourself - or your leadership - the following questions:
What are the specific activities underway in your business which are directly responding to the FCA New Consumer Duty?
Do you suspect you are falling short of market expectations when serving vulnerable customers?
Are your competitors further ahead in building an inclusive design model?
If you’re unsure about any of the answers, you should take a hard look at your roadmap for the next year. The FCA’s New Consumer Duty legislation comes into force in July 2023. If you aren’t taking steps to address vulnerable customers now, you should be banking on a fine later.
Want to learn more?
They’ve pulled together a page to share some of our latest writing, how we can help, and how you might want to get in touch. And if you want to dig deeper, here are some of our latest blog posts on the topic:
Read my initial reactions to the FCA’s regulation in my blog Vulnerable customers: The FCA’s New Consumer Duty is everyone’s duty.
Finally, read Louise’s excellent guide on building your inclusive design capability
Links We Loved this week
Want to read more about the psychology of vulnerability? University of Houston research professor, Brené Brown, is a leading thinker on shame, who’s probably best known for her TED talk on the power of vulnerability. But she also has a brilliant leadership podcast called Dare to Lead, which is about how businesses can use her research to build healthier organisations. A good episode to start with is this one on the difference between armoured and daring leadership.
Our friends over at Nesta have started publishing ‘future signals’. We’re looking forward to reviewing their 2023 edition, but in the meantime, their 2022 Signals review is a fascinating read
Design for Scotland are looking for people to complete their survey, collecting a range of perspectives on how to best support design in Scotland. They’d really value your perspective.
We’ve been helping one of our big clients with a public sector bid recently, persuading people to back important decisions that’ll make the biggest difference to the long-term public good. We found The Workshop’s 2022 handbook How to talk about government and its work for the long-term public good really valuable. if you’re working in, for or around government, give it a read.
Get in touch
Nile is here to help find better solutions for people and businesses. We want to hear from you. Reply directly to this email, or reach out to someone specific via our website or drop us a line on Twitter.
Oh, and forward this email to someone you think will enjoy it!
https://www.fca.org.uk/publication/finalised-guidance/fg21-1.pdf, Section 2.9