At Paystro UK Limited (Paystro, we, us or our), we are committed to making sure that all customers, including vulnerable customers, are treated fairly and have equal access to Paystro’s products and services.

This means that we need to recognise and understand the impact that life events, health, resilience and financial capability may have on our customer’s needs.

This is why we have a Vulnerable Customer Policy at Paystro which sets out our expectations when dealing with vulnerable customers.

Our employees are trained to identify vulnerable customers and provide the additional support they may require to meet their needs and achieve positive outcomes. We also acknowledge that vulnerability can take many forms and is specific to each individual customer.

To register as a vulnerable customer, please contact us via:

Paystro are committed to ensuring that all customers, including vulnerable customers, are treated fairly and have equal access to our products and services.

We must operate appropriate processes that consider the circumstances of individuals and are able to identify whether they are vulnerable or susceptible to a detriment (whether permanently or temporarily) and tailor the way in which we communicate and deal with them to take account of the vulnerability.

If you feel that you may be in a position of vulnerability, please contact us via:

The main objective of this policy is to set out Paystro’s approach when dealing with vulnerable customers to ensure that we deliver fair customer outcomes.

The Financial Conduct Authority’s (FCA) definition of a vulnerable customer is “someone who, due to their personal circumstances, is especially susceptible to detriment, particularly when a firm is not acting with appropriate levels of care towards them”.

The FCA considers the following factors act as drivers to actual or potential vulnerability:

An individual may suffer from one or more of these types of vulnerability at the same time, which may make them especially susceptible to harm.

Vulnerability is a key priority for the FCA. It expects firms, including Paystro, to exercise extra care when customers may be vulnerable because, where vulnerable customers are not treated fairly, their circumstances often mean they face an increased risk of harm.

The FCA expects us to have policies and procedures in place to deal with customers who may be at greater risk and to take into account the potential negative impact on vulnerable customers in product availability, product design, distribution channels and post-sales servicing of Paystro’s products and services.

One of the FCA’s operational objectives is to secure an appropriate degree of protection for customers. The FCA would be more likely to intervene where they identify actual or potential harm for vulnerable customers.

In meeting this objective, the FCA have regard to the general principle that customers should take responsibility for their choices and decisions. However, there can be factors that may limit the ability of vulnerable customers to take on this responsibility.

This risk is further supported by the recent introduction of the ‘customer best interest rule’ which requires Paystro to act in the best interests of their customers, considering the capabilities of the customer, their current and future needs and the appropriate support required to prevent any potential or actual vulnerability being perpetuated or worsened by our employees’ actions, inaction or Paystro’s processes.

The FCA also has regard to the general principle that Paystro should be expected to provide customers with a level of care that is appropriate, having regard, amongst other things, to the capabilities of the customers in question.

The level of care appropriate for vulnerable customers may therefore be different from what is required for other customers. The FCA will take action against firms, including Paystro, that do not afford appropriate processes and procedures for vulnerable customers, whether intentionally or not.

This Policy acts in accordance with the Equality Act 2010, which provides that it is illegal to discriminate and strengthens protection for specific protected characteristics. This means when a customer who has a disability is identified through Paystro’s operational processes or service, reasonable steps must be taken to ensure they are treated equally, fairly and with respect.

We also act in accordance with the requirements of the UK General Data Protection Regulation. In practice, this means that Paystro employees are required to obtain explicit consent from the customer regarding the recording of information, including both medical data (the vulnerability) and the duration of any vulnerability, for example, whether the vulnerability is thought to be temporary or permanent. Paystro employees are expected to ensure the recording of a vulnerability is accurate and reflective of the customer’s most recent circumstances.

We can record the interventions or adjustments requested by a customer rather than the vulnerability itself. In these instances, Paystro employees are still required to obtain the customer’s consent before making a record.

An individual may suffer from one or more of these types of vulnerability at the same time, which may make them especially susceptible to harm.

The FCA expects us to be able to spot a vulnerable customer should they provide personal details during a call or in customer correspondence and respond appropriately to this information.

Paystro employees receive training on communicating with vulnerable customers to ensure they are empowered and trusted to be alert to the signs that the person they are talking to may not have the capacity, at that moment in time, to make a decision or provide the correct information. As such, Paystro employees are expected to be able to confidently, competently and effectively identify the customers’ needs and adjust their approach accordingly.

It is acknowledged that vulnerability can take various forms. The identification of vulnerable customers must be individual, proactive and aimed at removing barriers to accessing our products and services, to result in both a good and fair customer outcome.