Dealing with Vulnerable Consumers

Dealing with Vulnerable Consumers – Guidance Policy Note

In order to comply with Industry Guidance recommendations1, EISS must:

  • identify vulnerable consumers; and
  • take practical steps to better assist members who may need further support. This may include referral to people or services with specialist training and experience to appropriately engage with and support them.

This must be done when members are accessing insurance, making an enquiry, claiming on their cover, making a complaint and communicating with EISS.

Who is a vulnerable consumer?

Members can be temporarily or permanently vulnerable and their needs can change over time or be exacerbated in certain situations.

A member’s vulnerability may be due to a range of factors including but not limited to: age, mental health conditions, disability, non-English speaking backgrounds, low levels of literacy, incarceration, financial distress, domestic violence, and Indigenous Australians.

Not all vulnerable members will self-identify as ‘vulnerable’. Some may not realise that they are considered vulnerable.

How can we best assist them?

Claims management
  • If the claims management team suspects that the customer is vulnerable, they will take reasonable measures to assist and a flexible approach will be adopted.  
  • The claims management team should also make a referral to people or services with specialist training and experience to appropriately engage with and support the consumer, using the table below for reference.
Providing information
  • Some groups of consumers (for example, people from Indigenous communities or those from non-English speaking backgrounds) may require support in meeting identification requirements. The claims management officer will take reasonable measures to assist and a flexible approach to verification and identification in line with AUSTRAC guidance, while still meeting our obligations under the law.
  • People living in remote and regional communities may have trouble meeting their obligations to provide us with documents and to take part in assessments in the timeframes we set. We will take this into account when going through the claims processes.
  • If customers need help with the claim process, in understanding what is required, completing claim forms or providing requested claim information, we will work with customers and the insurer to find a solution.
Interpreting/ translation services
  • The claims management team will provide access to an interpreter or translator at the customer’s request, or where we need an interpreter or translator to communicate effectively with a customer. This includes AUSLAN translators.
  • The claims management team will record the persons interpreting or translation needs and plan ahead to meet these needs.
  • Where an interpreter or translator is offered but declined, the claims management team will record the decline in the claims workflow system.

The claims management team recognises that where members are under the care of an appointed guardian, administrator or the holder of an enduring power of attorney, any communications they provide will be sent directly to the guardian, administrator or attorney, and the trustee may only accept payment instructions from them.

Index of Referral services

Interpreting services for AUSLAN.

Mental health
Indigenous communities
  • National Indigenous Critical Response Service, 1800 805 801
Domestic violence

1800RESPECT, 1800 737 732

Financial distress

Financial Counselling Network

Non English speakers

The Translating and Interpreting Service (TIS National), 131 450


National Relay Service, 1300 555 727

Older people

NSW Elder Abuse Helpline, 1800 628 221
Dementia Support Australia, 1800 699 799


1 Insurance in superannuation claims handling:  Claims handling standards for superannuation funds