Vulnerable customers

Vulnerable customer policy

How we identify vulnerability, what adjustments we make, and how to ask for support. Aligned with the FCA Vulnerable Consumers Guidance and the Equality Act 2010.

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Editorial summary

Vulnerable customer policy

Last reviewed: 17 May 2026
Reviewer: cheap car tow editorial team
Reading time: ~6 minutes

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cheap car tow is a booking and price-publication service. The recovery itself is performed by an independent PAS 43 compliant operator dispatched at the published rate. See terms for the operator-panel arrangement.

Vulnerable customers

Vulnerable customer policy

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What vulnerability means

Vulnerability is not a fixed label. It is the state of being at higher risk of harm from a standard interaction. Common drivers: health condition (mental or physical), cognitive capacity (dementia, learning disability), language (limited English fluency), age (older or much younger), economic stress (limited cash flow), or living circumstances (homelessness, recent bereavement).

The framework we use draws on the FCA Vulnerable Consumers Guidance (FG21/1) and the Equality Act 2010. Vulnerability can be temporary; a customer who has just been in a collision is in a heightened vulnerability state for the duration of that incident.

insight

How we identify a vulnerable customer

We listen. The dispatcher is trained to pick up cues (confused phrasing, repeated questions, signs of distress). The dispatcher can ask whether the customer would like an adjustment without putting a label on it.

You can also tell us directly. The booking form has a free-text notes field; the dispatcher reads notes and adjusts the procedure accordingly. There is no diagnosis or proof required.

by the numbers

Adjustments we make

Communication: alternative channel (post, third-party advocate, Welsh language for Welsh callers), simpler language at each step, repeat-back confirmation.

Timing: longer attendance windows where the customer cannot stand at the roadside indefinitely; priority dispatch where the customer is at heightened risk; longer complaint timeline where the customer needs time to compose the complaint.

Process: operator stays with the customer until the recovery completes (this is part of PAS 43 working procedure anyway); recovery sheet sent by post in addition to email; payment options widened to include bank transfer or invoice where card payment is not workable.

the moment

How an advocate can help

A family member, friend, social worker, solicitor or independent advocate can speak to us on your behalf with your written authority. The authority letter does not need a specific form; a one-line note that names the advocate and your booking reference is enough.

The advocate can receive the recovery sheet, the invoice and the complaint correspondence in your place. Where the advocate is paid (for example a solicitor), the fees they charge you are not within our procedure.

in the press

How we store the vulnerability flag

Only with your consent. The booking record carries a free-text note ("preferred communication: post"; "needs longer attendance window"). The note travels with you on subsequent bookings so you do not have to re-explain.

You can ask us to remove the note at any time via the data protection contact email. The privacy policy covers the wider data-rights framework.

Key takeaway · 06

Working with third-party services

Where a vulnerable customer is at the roadside without companion, the operator stays until the recovery completes. Where the customer needs follow-on support (housing, social care, mental health), we can signpost to services such as Citizens Advice, Mind or Age UK but we do not provide those services directly.

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Complaints adjustments

Where a vulnerable customer wants to complain we adjust the procedure: longer timelines, an alternative channel, the use of an advocate. The standard 28-day decision target can extend on request without prejudice to the complaint.

See the complaints policy for the standard procedure.

insight

Staff training schedule and content

Dispatcher and customer-support staff complete vulnerability training on onboarding and a refresher every twelve months. The training content is built from the FCA Vulnerable Consumers Guidance, the Equality Act 2010, and the Mental Capacity Act 2005 (England and Wales) / Adults with Incapacity (Scotland) Act 2000.

Topics covered in the training: identifying vulnerability indicators in a phone call (confused phrasing, repeated questions, signs of distress, language difficulty), the principle that vulnerability is temporary and situational not a fixed label, the published adjustments (longer windows, alternative channels, advocate authority), the boundary between what we can do and what we should signpost, and the data-protection rules for storing a vulnerability flag.

Training is delivered by a UK-registered trainer with experience in financial-services vulnerability frameworks. Completion is recorded against the staff record and is auditable. Failed refresher attempts trigger a remedial session before the staff member returns to dispatch duties.

by the numbers

Third-party advocate authority procedure

A vulnerable customer may prefer that a family member, friend, social worker, solicitor or independent advocate corresponds with us on their behalf. The authority procedure is intentionally light-touch to remove a barrier.

The customer (or the advocate with the customer's spoken consent on the call) emails or posts a short note that names the advocate, names the customer, gives the booking reference, and states the authority. There is no specific wording requirement; a one-line note is enough. The customer can revoke the authority at any time by a similar note.

What the advocate can do once authorised: receive the recovery sheet, the invoice and any complaint correspondence; speak to the dispatcher on the customer's behalf; submit a subject access request on the customer's behalf; complain on the customer's behalf. The advocate cannot change the keeper of a vehicle (DVLA controls that) or commit the customer to a financial obligation (a new booking is initiated by the customer).

Where the advocate is paid for their time (a solicitor, for example) the fees they charge the customer are between the customer and the advocate; they are not part of our procedure.

the moment

Signposting partners

Where a vulnerable customer needs support outside the scope of a recovery, we signpost to specialist services. We do not provide those services directly; signposting means we share contact information so the customer can decide whether to engage.

Citizens Advice for consumer rights, debt, housing, benefits.
Mind for mental health support.
Age UK for older people including support for isolated older drivers after a breakdown.
RNIB for vision impairment, including digital accessibility.
RNID for hearing loss; arranges Relay UK calls.
Royal British Legion for serving and ex-service personnel, including support after roadside incidents.
Refuge for customers in a domestic-abuse situation where the vehicle is the means of leaving safely.

Where a customer indicates an immediate safety risk on a call, the dispatcher asks them to dial 999 and stays on the line until help arrives if safe to do so.

in the press

Training and review

Dispatcher staff are trained in vulnerability awareness on onboarding and annually thereafter. The training covers cue recognition, language adjustments, the FCA FG21/1 framework, and the boundary between what we can do and what we should signpost to a specialist service.

The policy is reviewed annually and updated in line with regulator guidance changes.

Key takeaway · 12

Review and change history

First published 2026-05-17. The vulnerable customer policy is reviewed every 12 months or sooner if the cited primary source changes. Material changes (new lawful basis, new escalation route, new scope) are added below with a date and a one-line reason. Editorial corrections (typo, broken link) are not logged here; the live page is the source of truth.

If anything in this vulnerable customer policy reads as inaccurate, out of date, or unclear, email the editorial team at hello@cheapcartow.co.uk with the page URL and a description of the issue. The editorial team replies inside three business days; a material correction is published with a dated note in this section. External escalation routes (ICO, Trading Standards, Financial Ombudsman Service) apply where the relevant complaint is in scope for the regulator.

Primary sources cited on this page

Common questions

Frequently asked questions

Who counts as a vulnerable customer?

Anyone whose health, cognitive capacity, language, age, financial situation or living circumstances make the standard procedure harder. Vulnerability is not a fixed label; it can be temporary.

How do you identify vulnerability?

We listen. The dispatcher can flag a vulnerability indicator on the booking record; you can also tell us directly. We never demand a diagnosis or proof.

What adjustments do you make?

Longer attendance windows, an alternative communication channel (post, third-party advocate), priority dispatch where appropriate, and a longer complaint timeline where helpful.

Can my advocate speak to you on my behalf?

Yes with your written authority. A family member, friend, social worker, or solicitor can act on your behalf.

Do you record my vulnerability indicator on my record?

Only with your consent. The flag is stored to make sure future bookings get the same adjustments without you having to re-explain.

Can you handle a Welsh-language booking?

Yes; if you tell the dispatcher you prefer Welsh, the booking is handled in Welsh. The operator may not speak Welsh but the booking record is in Welsh.

Need a recovery?

Published price, PAS 43 compliant operator, 24/7 dispatch.

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