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DC-Services — Digital Claims Services Limited
Legal Documentation

DC-Services UK Vulnerable Clients Policy

How DC-SERVICES UK identifies vulnerability and applies reasonable adjustments.

This policy explains how Digital Claims Services Limited (trading as DC-SERVICES UK) identifies clients in vulnerable circumstances and the reasonable adjustments that may apply. It is informational only and is not legal, financial, medical or social-care advice.

Last reviewed: February 2026 · 20 sections

vulnerable-clients-policy.pdf · A4 · brandedAll documents
01

Purpose of the policy

  1. 1.1DC-SERVICES UK publishes this policy so clients in vulnerable circumstances know what support is available.
  2. 1.2Vulnerability is recognised as a circumstance, not a label, and may change over time.
  3. 1.3The policy applies across the engagement lifecycle from enquiry to closure.
  4. 1.4Clients can rely on this policy as a baseline standard.
02

Meaning of vulnerability

  1. 2.1A vulnerable client is someone whose personal circumstances make them especially susceptible to harm or unfair outcomes.
  2. 2.2Vulnerability may be permanent, temporary or situational.
  3. 2.3Vulnerability does not imply incapacity or limit a client's rights.
  4. 2.4Recognition of vulnerability triggers reasonable adjustments, not exclusion.
03

Temporary vulnerability

  1. 3.1Temporary vulnerability covers situations such as ill health, recent bereavement, sudden financial pressure or a stressful life event.
  2. 3.2Temporary vulnerability is handled with the same care as longer-term vulnerability.
  3. 3.3Adjustments may be lighter-touch and time-bounded.
  4. 3.4Clients are told they may ask for adjustments at any time.
04

Permanent vulnerability

  1. 4.1Permanent vulnerability covers situations such as long-term disability, chronic illness or persistent cognitive challenges.
  2. 4.2Adjustments may be ongoing and integrated into the standard engagement plan.
  3. 4.3Communication channels and pace are adapted to the client's needs.
  4. 4.4Clients may also nominate a representative to assist them.
05

Financial stress

  1. 5.1Financial stress may affect a client's ability to engage with documentation work and respond on time.
  2. 5.2Where financial stress is disclosed, deadlines and fee plans may be revisited.
  3. 5.3DC-SERVICES UK does not provide debt advice; clients should consult an appropriately qualified service.
  4. 5.4Information about reputable free debt-advice services can be provided on request.
06

Bereavement or distress

  1. 6.1Bereavement and other forms of acute distress are recognised as vulnerability triggers.
  2. 6.2Engagement pace, contact frequency and tone are adapted in those circumstances.
  3. 6.3Where consent is needed from someone in distress, extra time is given.
  4. 6.4Clients may pause an engagement and resume it later within reasonable limits.
07

Accessibility needs

  1. 7.1Accessibility needs may relate to vision, hearing, mobility, cognition or neurodivergence.
  2. 7.2Reasonable adjustments are made to make engagement accessible, in line with the Accessibility Statement.
  3. 7.3Adjustments are agreed with the client and not imposed.
  4. 7.4Clients are invited to describe what works best for them.
08

Language or comprehension needs

  1. 8.1Where a client's first language is not English, plain-English documents and additional time can be provided.
  2. 8.2Where formal translation is needed, this can be arranged through an appropriately qualified service.
  3. 8.3Comprehension needs are addressed without judgement.
  4. 8.4Key points are confirmed in writing where useful.
09

Reasonable adjustments

  1. 9.1Reasonable adjustments may include extra time, simplified materials, alternative channels and supported sessions.
  2. 9.2Adjustments are agreed with the client and recorded in the engagement file.
  3. 9.3Adjustments do not change the substantive work; they change how it is delivered.
  4. 9.4Clients can ask for adjustments to be reviewed at any time.
10

Clear communication

  1. 10.1Communications use plain language and avoid unnecessary jargon.
  2. 10.2Important communications include a short summary at the top.
  3. 10.3Clients can ask for an explanation of any term they do not understand.
  4. 10.4Communications can be repeated in another format on request.
11

Extra time for decisions

  1. 11.1Where a decision is significant, additional time is offered before a response is required.
  2. 11.2Clients are not asked to make significant decisions during obvious distress.
  3. 11.3Deadlines are flexible where the engagement allows.
  4. 11.4Where a deadline is statutory, the client is told and supported to meet it.
12

Escalation to senior review

  1. 12.1Cases involving significant vulnerability are escalated to a senior member of staff.
  2. 12.2Senior review confirms that adjustments are appropriate and proportionate.
  3. 12.3Escalation is logged in the engagement file.
  4. 12.4Clients are told when their case is being handled at senior-review level.
13

Consent and representative support

  1. 13.1Clients may nominate a trusted representative to assist with engagement, subject to identity checks.
  2. 13.2Representative arrangements are recorded and the scope of authority confirmed in writing.
  3. 13.3Representatives are bound by confidentiality on the client's information.
  4. 13.4The client retains overall control and may revoke a representative's authority at any time.
14

Safeguarding concerns

  1. 14.1Where there are credible concerns about a client's safety, DC-SERVICES UK may take steps that include pausing the engagement.
  2. 14.2Concerns are escalated to senior staff and recorded.
  3. 14.3Where appropriate, clients are signposted to specialist support services.
  4. 14.4Safeguarding actions are not a substitute for emergency services where life or safety is at risk.
15

Confidentiality

  1. 15.1Information disclosed about vulnerability is treated as confidential and access-restricted.
  2. 15.2Confidentiality is maintained internally and externally, subject to lawful disclosure obligations.
  3. 15.3Information is shared internally only with people who need to know.
  4. 15.4Clients can ask which staff hold information about their vulnerability.
16

Data protection

  1. 16.1Information about vulnerability may be special category data and is handled under our Privacy Policy.
  2. 16.2An Article 9 condition is applied before processing such data.
  3. 16.3Data is retained for the minimum period needed to support the client.
  4. 16.4Clients can exercise their UK GDPR rights in respect of vulnerability information.
17

Staff awareness

  1. 17.1All client-facing staff are trained to recognise common signs of vulnerability and to respond with care.
  2. 17.2Training is refreshed at least annually and on material policy changes.
  3. 17.3Training emphasises avoiding assumptions and asking the client what they need.
  4. 17.4Training records are maintained internally.
18

Complaint route

  1. 18.1Clients who feel they have not received appropriate support may make a complaint under the Complaints Policy.
  2. 18.2Complaints involving vulnerability are reviewed at senior level.
  3. 18.3Outcomes feed back into staff training and policy review.
  4. 18.4Independent escalation routes are available where internal resolution fails.
19

Review of client needs

  1. 19.1Vulnerability needs are reviewed at meaningful milestones and on client request.
  2. 19.2Reviews confirm that adjustments remain appropriate and proportionate.
  3. 19.3Changes are recorded and confirmed with the client.
  4. 19.4Clients are reassured that asking for changes will not disadvantage them.
20

Policy review schedule

  1. 20.1This policy is reviewed at least annually and whenever applicable guidance materially changes.
  2. 20.2Reviews are owned by the Compliance Office.
  3. 20.3Updates are version-controlled and published with a new 'Last reviewed' date.
  4. 20.4Material changes are notified to active clients where relevant.
Frequently Asked Questions

Questions about this page

How do I tell you I need extra support?
Just tell us — by email, secure portal message or during a call. We will record the need with your consent and agree adjustments with you.
Will telling you affect my engagement?
Yes, in a good way. It allows us to apply reasonable adjustments and senior review. It does not disadvantage you or limit your rights.
Can someone help me on my behalf?
Yes. You can nominate a representative subject to identity checks. You stay in control and can revoke their authority at any time.
Where can I get debt advice?
We don't provide debt advice. We can signpost you to reputable free services such as those listed on the MoneyHelper website.
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