Vulnerable Customer Policy
How we identify customers who may be in vulnerable circumstances, adapt our service to their needs, and make sure no one is disadvantaged or exploited.
OneCloud Pvt Ltd trading as FundingNearMe · Company no. 16991609 · ICO ZC130857 · Last updated 6 November 2026
Need help right now? See Need extra help? for the ways we can adapt, or call us on 020 8097 8468. If you or someone else is in immediate danger, call 999.
1. Policy statement
OneCloud Pvt Ltd, trading as FundingNearMe, is committed to identifying customers who may be in vulnerable circumstances, adapting our service to meet their needs, and ensuring that no customer is disadvantaged or exploited because of those circumstances.
We introduce businesses to providers of business finance. Getting it wrong for a vulnerable customer can mean unaffordable debt or a commitment they did not fully understand. This policy exists to prevent that.
| Policy owner | Sankalp Awiskar, Director and Vulnerable Customer Lead |
| Review | Every 12 months, or earlier after a regulatory change or serious incident |
| Related policies | Complaints Policy · Privacy Notice · Terms & Conditions · Treating Customers Fairly · Data Protection Policy |
2. Scope
This policy covers every director, employee, contractor and lead partner who speaks to customers or handles their data, across all channels: phone, WhatsApp, email and web forms.
Business customers are covered. A sole trader, a small family business or a charity run by volunteers can be just as vulnerable as a household.
3. What we mean by vulnerability
A vulnerable customer is someone who, because of their personal circumstances, is especially likely to suffer harm, particularly when a firm does not take appropriate care. This follows the FCA's definition. Vulnerability can be permanent, temporary or come and go, and anyone can become vulnerable. For a business customer, we look at the person we are dealing with and the business itself.
| Driver | Examples |
|---|---|
| Health | Physical or mental illness, disability, cognitive impairment, dementia, addiction, sight or hearing loss, pregnancy |
| Life events | Bereavement, relationship breakdown, caring duties, job loss, domestic abuse, a new business owner with no experience |
| Resilience | Low or erratic income, debt, arrears, a business close to insolvency, county court judgments, no savings |
| Capability | Low literacy or numeracy, limited English, poor digital skills, no experience of contracts or finance, low confidence |
| Business-specific | Sole trader running everything alone, director recently bereaved or ill, cash-flow crisis, bad credit, a volunteer-run charity |
Vulnerability is about circumstances, not labels. A customer does not have to tell us, and we never demand proof before adapting our service.
4. Our commitments
Every customer who may be vulnerable will get outcomes as good as any other customer. We commit to:
- Notice: train staff to recognise signs of vulnerability and to ask open, respectful questions.
- Adapt: offer more time, other channels, plain-English and large-print documents, interpreters, and the involvement of a trusted person.
- Never exploit: no pressure selling, no urgency tactics, no introduction when we doubt the customer understands or can afford it. Commission never outweighs suitability.
- Record with consent: note only what we need, with the customer's agreement, so they do not have to repeat themselves.
- Refer: signpost free, independent help and, with consent, pass needs to lenders.
- Pause or stop: any member of staff may pause an introduction if they are worried, without penalty.
- Make complaints easy: accept complaints in any form and handle them with extra care.
- Check it works: monitor outcomes for vulnerable customers and act on what we find.
5. Who is responsible
| Role | Responsibilities |
|---|---|
| Directors | Own the policy, approve it yearly, review quarterly reports, make sure targets and commission never reward poor outcomes |
| Vulnerable Customer Lead (Sankalp Awiskar) | Day-to-day owner; advises staff; signs off pauses and escalations; runs file reviews; reports to directors; keeps training current |
| Data Protection Lead | Lawful basis for recording health and other sensitive data; retention; access and deletion requests |
| Team leaders | Coach staff, listen to calls, check records are complete, escalate concerns |
| Advisers and support staff | Spot and respond to vulnerability, record it with consent, adapt service, refer, escalate when unsure |
| Lead generators and partners | Must follow this policy under contract; we audit their calls and scripts and stop working with any who breach it |
6. Our procedure
- Spot it. At the start of every enquiry we ask: "Is there anything that would make it easier for us to help you, or anything about your circumstances we should know?" We do not diagnose or assume, and age alone does not make someone vulnerable.
- Respond. We thank the customer, explain how we will use the information and that it stays confidential, ask for consent to record it, ask what would help, and signpost support if appropriate.
- Record it. We record facts, not opinions. Health details are recorded only with explicit consent. If a customer refuses consent, we record only the adjustment needed (for example "prefers email, large print") and still make it.
- Adapt. We slow down, offer a call back and a break before any decision, send a plain-English summary of costs, term, fees and security, and wait for the customer to confirm. A trusted person can be involved with the customer's permission.
- Decide whether to proceed. We stop or pause if the customer does not appear to understand, seems pressured by someone else, cannot afford the product, or may lack mental capacity for the decision. Only the Vulnerable Customer Lead can approve proceeding with a paused introduction.
- Refer, follow up and review. With consent, we pass needs to the lender, signpost free help, and review needs after 6 months.
Urgent situations
- Immediate risk to life: we call 999.
- Distress without immediate danger: we offer Samaritans (116 123) and, with consent, a call back from the Lead.
- Suspected abuse, coercion or financial exploitation: we stop and the Lead decides on a referral to the local authority safeguarding team or the police.
- Suspected scam targeting the customer: we stop, warn the customer, and report it to Action Fraud.
7. Extra safeguards for business finance
- We do not push a merchant cash advance or other high-cost product as a default for "bad credit" customers.
- Personal guarantees and security are flagged clearly and in writing.
- Where a director or sole trader is in financial difficulty, we signpost Business Debtline or a licensed insolvency practitioner before any new borrowing.
- We never advise a customer to hide information from a lender.
8. Sales conduct, complaints, data and training
- Sales and marketing: no false urgency; marketing claims must be accurate and evidenced; commission and targets are reviewed yearly so no one is rewarded for introductions that later cause complaints.
- Complaints: accepted in any form, including from a representative with consent. Complaints from vulnerable customers get priority handling by a senior handler.
- Data protection: information about health, disability or similar is special category data under UK GDPR. We record it only with explicit consent or a lawful exemption, restrict access, and share it only with consent or where the law allows. Customers can ask to see, correct or remove their information at any time.
- Training: all customer-facing staff are trained before first contact and every 12 months. The Lead reports to directors quarterly on outcomes for vulnerable customers, and any gap triggers an action plan.
9. Free, independent support
| Need | Organisation | Contact |
|---|---|---|
| Emotional distress, suicidal thoughts | Samaritans | 116 123 (24/7, free) |
| Business debt | Business Debtline | 0800 197 6026 |
| Personal debt | National Debtline | 0808 808 4000 |
| Personal debt | StepChange | 0800 138 1111 |
| Consumer rights | Citizens Advice consumer helpline | 0808 223 1133 |
| Domestic abuse | National Domestic Abuse Helpline | 0808 2000 247 (24/7) |
| Mental health information | Mind | 0300 123 3393 |
| Older people | Age UK Advice Line | 0800 678 1602 |
| Bereavement | Cruse Bereavement Support | 0808 808 1677 |
| Hearing or speech impairment | Relay UK | 18001 020 8097 8468 |
| Fraud and scams | Action Fraud | 0300 123 2040 |
| Finance disputes | Financial Ombudsman Service | 0800 023 4567 |