Vulnerable Customer Policy – Mobility Disabled

Last reviewed: 9 November 2026

1. Purpose and scope

Mobility Disabled treats every customer fairly, and gives extra time, care and support to anyone whose circumstances make them more likely to be harmed or disadvantaged when buying or owning a vehicle.

We are a small, family-run dealership at Kington Garage, Thornbury, Bristol, selling wheelchair accessible vehicles (WAVs). Many of our customers are disabled, elderly, or buying on behalf of someone they care for. Supporting people in these situations is not an add-on for us; it is the core of what we do.

This policy applies to:

Everyone who works for or represents Mobility Disabled, including family members helping out
Every stage of our dealings with a customer: adverts and website, phone and email enquiries, viewings, test drives, sale, finance and part-exchange, delivery and handover, and after-sales support and repairs
Customers, and the family members, carers and representatives who deal with us on their behalf

2. What we mean by a vulnerable customer

A vulnerable customer is someone who, because of their personal circumstances, is especially susceptible to harm, particularly when we do not act with appropriate care.

Vulnerability is not a fixed label. Anyone can become vulnerable, and it can be temporary, intermittent or permanent. Being disabled does not in itself make someone vulnerable, and we never assume a customer cannot make their own decisions.

We look out for four main drivers of vulnerability, in line with FCA guidance and the Digital Markets, Competition and Consumers Act 2024:

Driver	Examples relevant to our customers
Health	Physical disability, long-term or terminal illness, cognitive impairment, dementia, mental health conditions, sensory impairment, fatigue or pain on the day
Life events	Bereavement, recent diagnosis or hospital discharge, becoming a carer, relationship breakdown, job loss, urgent need for transport (e.g. to get home from hospital)
Resilience	Low or irregular income, debt, relying on benefits or a one-off payout to fund the vehicle, little support from others
Capability	Limited English, low literacy or numeracy, little confidence with cars, finance or paperwork, no internet access

Customers may have more than one of these at once, and a carer or family member buying for someone else can be vulnerable too.

3. Our commitments

Every customer who shows signs of vulnerability should get an outcome at least as good as any other customer. In practice we will:

Never pressure anyone. No time-limited deals, no “someone else is coming to look at it” tactics, and no rushing a decision.
Be clear and honest. Show the full price up front, explain any extras or fees, and describe each vehicle’s condition, history and conversion accurately.
Make sure the vehicle fits. Check the wheelchair, the user’s height and seating position, and how the vehicle will be used before agreeing a sale.
Adapt how we communicate. Offer more time, repeat information, put key points in writing, use large print, or talk to a nominated helper.
Respect independence. Treat customers as able to make their own decisions unless there is clear reason to think otherwise.
Keep things confidential. Only record what we need, and only share it with permission.
Stay with the customer after the sale. Support continues through faults, repairs and complaints, not just until the keys are handed over.
Speak up if we are worried. Act on any concern that someone is being exploited, neglected or put at risk.

4. Recognising vulnerability

Customers rarely tell us they are vulnerable, so we pay attention to what we see and hear and ask open, respectful questions such as “Is there anything that would make this easier for you?”

Signs to look out for include:

On the phone or by email: confusion about what was agreed earlier, asking the same question repeatedly, difficulty hearing or following, distress, mentioning a recent bereavement, diagnosis or hospital stay, or urgency (“I need something by Friday”)
At a viewing or home visit: tiredness or pain, difficulty reading documents, someone else answering every question for the customer, the customer seeming anxious about another person present
About money: unclear how they will pay, using all their savings or a compensation payment, asking about finance they may not afford, or someone else controlling the money
About the vehicle: unsure what wheelchair or measurements they need, or choosing a vehicle that does not seem suitable for the user

If we notice any of these, we slow down and adjust our approach (sections 5 to 8). We do not label or record someone as vulnerable without good reason.

5. Supporting customers through the sale

The sale is where a vulnerable customer is most at risk of a poor decision, so each step has a built-in check.

Enquiry and advice

Ask about the wheelchair user, their chair (make, model, height when seated) and how the vehicle will be used before recommending anything
If a vehicle in stock is not right, say so, even if it means no sale
Offer to send details, photos and prices in writing, by post if the customer prefers

Viewings and test drives

Allow plenty of time and offer breaks; offer viewings at home where that is easier
Let the customer try loading their own chair, with their carer present if they wish
Encourage them to bring a family member, friend or carer

Price, part-exchange and payment

Give the full price in writing, including any delivery, warranty or admin charges
Value part-exchanges fairly and explain how the figure was reached
Never take a deposit or payment on the first contact from a customer who seems confused, distressed or under pressure; suggest they take time to think

Finance (if we arrange it)

Only introduce finance if the customer asks or clearly needs it, and only within our FCA permissions
Explain the total cost, monthly payment and any commission we receive, in plain words
Do not proceed if the customer does not appear to understand the agreement or it looks unaffordable; tell the lender about any vulnerability with the customer’s consent

VAT relief for disabled customers

Explain the VAT relief rules simply, but make clear the eligibility declaration is the customer’s own
Never fill in, sign or encourage someone to sign a declaration they may not qualify for

Cooling off

Remind customers of their rights, including the 14-day cancellation period for sales agreed at a distance or away from our premises, and their rights if the vehicle is faulty
If a customer has second thoughts soon after buying, listen and look for a fair solution rather than relying on the small print

6. Home visits, deliveries and handovers

We drive vehicles to customers ourselves, often to their homes, so we take extra care to keep both customers and ourselves safe. Everyone at Mobility Disabled who visits or deals with customers holds a current DBS (Disclosure and Barring Service) check.

Before the visit

Agree a date and time in writing and tell the customer who will be coming
Ask if anyone else should be there, such as a carer or family member
Tell a colleague where we are going and when we expect to be back

At the visit

Show ID on arrival (and confirmation of our DBS check if asked), and never enter the home unless invited
Be patient, polite and respectful of the person’s home, routines and equipment
Do not accept gifts or money beyond the agreed payment, and do not handle cash except against a written receipt

At handover

Demonstrate the ramp or lift, wheelchair restraints and occupant seatbelt with the actual wheelchair, and let the carer practise until they are confident
Explain controls, servicing, MOT date and who to call if something goes wrong
Leave written instructions and our contact details
If the customer seems unable to use the vehicle safely, or we are worried about the person’s wellbeing, do not just leave: talk it through and follow section 11

7. Carers, family members and representatives

Many purchases are made by, or with help from, someone other than the wheelchair user. We welcome that help while keeping the user’s interests central.

Helpers: a customer can ask us to speak to a named family member or carer. We note this permission and who it covers.
Legal authority: if someone is buying on another person’s behalf using a Lasting Power of Attorney (property and financial affairs) or a deputyship order, we ask to see a copy and keep a note of it.
Mental capacity: under the Mental Capacity Act 2005 we assume a person can make their own decisions unless shown otherwise. If we have real doubts that a customer understands the purchase, we pause, involve their chosen helper, and do not complete the sale until we are satisfied.
Who the vehicle is for: we speak directly to the wheelchair user where possible, even when someone else is paying.
Warning signs: we take care if a third party seems to be pushing a purchase the customer does not want, controlling their money, or stopping them speaking for themselves. See section 11.

8. After-sales, faults and complaints

For many of our customers the vehicle is their only way to get to appointments, work or family, so a fault can cause real hardship. We prioritise these customers.

Faults and repairs: within our roughly 100-mile delivery area we collect and repair vehicles where there is a problem. Where a customer depends on the vehicle for medical appointments or care, we treat the job as urgent and keep them updated.
Getting home safely: if a vehicle breaks down or cannot be used, we help the customer think through alternatives, such as a breakdown service, a friend or family member, or community transport.
Complaints: customers can complain by phone, email, letter or in person, or ask someone to complain for them. We acknowledge every complaint promptly, never make it harder for a vulnerable customer to complain, and explain their next steps if they are not happy with our answer.
Keeping in touch: we contact customers in the way they prefer and avoid calls at times they have told us are difficult.

9. Recording information and data protection

We only record information about a customer’s circumstances when it helps us support them, and we handle it in line with UK GDPR. Mobility Disabled is registered with the Information Commissioner’s Office (ICO) as a data controller (registration number ZB124121).

Health information is special category data. We record it only with the customer’s explicit consent, or where needed to keep them safe.
We note the adjustment needed (for example “send everything in large print” or “speak to daughter, Sarah”), rather than a diagnosis or label, wherever possible.
Notes are stored securely on the customer’s record and are only seen by those who need them.
We do not share a customer’s circumstances with lenders, garages or anyone else without their permission, unless the law requires it or someone is at risk of serious harm.
We delete information when it is no longer needed.

10. Privacy and discretion

Buying a WAV often means sharing personal details about health, mobility and family life. We treat those conversations with the same discretion customers would expect from a doctor or solicitor.

We never discuss one customer’s circumstances with another customer, neighbour or anyone not authorised by them
We hold personal conversations somewhere private, whether at our premises, at the customer’s home or by phone
We use unmarked paperwork and plain envelopes on request, and we never leave documents where others can see them
We ask before calling someone at work, leaving a voicemail or speaking to whoever answers the phone
We never use a customer’s name, photo, story or vehicle handover in marketing or on social media without their written consent
We are discreet when delivering or collecting vehicles, and we respect any request about when or where to arrive

11. If we are worried about someone

If we believe a customer is being abused, exploited, neglected or is at risk of harm, we act on it rather than hoping someone else will.

Immediate danger: call 999.
Pause the sale: do not take payment or hand over a vehicle while the concern is unresolved.
Talk to each other: discuss the concern with the other person at Mobility Disabled the same day.
Talk to the customer (where safe): ask whether they are okay and whether they want help.
Report it: contact the adult social care team at the customer’s local council to raise a safeguarding concern. For suspected fraud or scams, contact Action Fraud or the police on 101.
Write it down: record what we saw or heard, when, and what we did.

Useful contacts

Need	Who
Emergency	999
Non-emergency police	101
Safeguarding concern	Your local council’s adult social care team (ours: South Gloucestershire Council)
Free money and debt advice	MoneyHelper, Citizens Advice, StepChange
Emotional support	Samaritans, 116 123 (free, 24 hours)
Benefits and disability advice	Citizens Advice, Scope

12. Responsibilities, training and review

C Allen is responsible for this policy and for making sure everyone who deals with customers follows it.

Everyone working for Mobility Disabled reads this policy and signs to confirm they understand it
We refresh our knowledge each year, using free resources such as FCA guidance on vulnerable customers and local safeguarding awareness training
We talk through any difficult cases together and update how we work if something could have gone better
This policy is reviewed every year, or sooner if the law or our business changes

Further reading