Customers in Vulnerable Circumstances.
At Quote Devil, we wish to make the insurance journey as hassle free as possible. At times, a customer may find that their circumstances may make this difficult. Certain situations such as health, life events, financial stress or personal capability may place you in a vulnerable position or circumstance. If this is the case, we have procedures in place to help you with this.
We can ensure that we handle your policy or quote in the most sensitive way required whether that be to slow the process down, arrange a call back or communicate a different way. We can note your file and use this to make sure you have the best support options available; this note does not have to be permanent and can be removed whenever you like.
Under the Consumer Protection Code
“Consumer in vulnerable circumstances” means a consumer that is a natural person and whose personal circumstances, whether permanent or temporary, make that consumer especially susceptible to harm, particularly where a regulated entity is not acting with the appropriate levels of care, and “vulnerable circumstances” shall be construed accordingly; - This can make it more difficult to engage with financial services, such as the purchasing of an Insurance product “Where a regulated entity has identified that a consumer that is a natural person is in vulnerable circumstances, the regulated entity shall provide that consumer with such ongoing reasonable assistance as may be necessary to facilitate that consumer in their dealings with the regulated entity
- Vulnerability may be temporary, permanent, or situational.
Consumer Protection Code – Part 2 - Regulation 34
34 - Consumers in vulnerable circumstances to be assisted
- Where a regulated entity has identified that a consumer that is a natural person is in vulnerable circumstances, the regulated entity shall provide that consumer with such ongoing reasonable assistance as may be necessary to facilitate that consumer in their dealings with the regulated entity.
- A regulated entity shall ensure that any information received from a consumer in vulnerable circumstances and maintained as a record by the regulated entity is, where appropriate and in accordance with the law, accessible to the staff of the regulated entity in the course of the provision by those staff of ongoing reasonable assistance to the consumer.
Trusted Contact Person
In accordance with the Consumer Protection Code 2025, Part 2 – regulation 36. Quote Devil is required at the request of a personal consumer, to record the name and contact information of an individual (referred to as a “trusted contact person”) who the consumer has nominated and agreed, that Quote Devil may contact in circumstances where –
- Quote Devil has a concern about possible financial abuse of the personal consumer,
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Quote Devil needs to confirm the specifics of –
- the consumer’s current contact information,
- the consumer’s health status, or
- the identity of any appointed legal guardian, executor or trustee, or
- Quote Devil are experiencing difficulties in communicating with the consumer.
Under this regulation Quote Devil, is permitted to disclose confidential information about the individual to the trusted contact person for the purpose of discussing the relevant matter above.
Who is not a Trusted Contact Person
A decision-making or co- decision making representative who has been appointed to act on the consumers behalf.
An attorney under an enduring power of attorney that has been appointed to act on the consumers behalf.
Consent
Written consent must be received from the individual to allow Quote Devil contact a trusted contact person and retain the trusted contacts name and contact information which is only for use in line with this regulation.
A trusted contact person has no authority to deal with the affairs of a personal consumer in respect of Quote Devil matters, and is not a legal representative for the purposes of these Regulations, solely on account of having been recorded or contacted by Quote Devil as a trusted contact person.
Consumer Protection Code – Part 2 - Regulation 36
36 - Trusted Contact Person
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A regulated entity shall, at the request of a personal consumer, record the name and contact information of an individual (referred to in this Regulation as a “trusted contact person”) who the consumer has nominated and agreed, in accordance with paragraph (3), that the regulated entity may contact in circumstances where -
(a) the regulated entity has a concern about possible financial abuse of the personal consumer,
(b) the regulated entity needs to confirm the specifics of –- the consumer’s current contact information,
- the consumer’s health status, or
- the identity of any appointed legal guardian, executor or trustee, or
- Where a regulated entity decides to contact a trusted contact person, the regulated entity may, provided that the regulated entity complies with paragraph (3), disclose confidential information about the personal consumer to the trusted contact person for the purposes of discussing the relevant matter referred to in paragraph (1).
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Paragraph (2) does not apply unless the regulated entity has received –
(a) the written consent of the personal consumer that the regulated entity may contact the trusted contact person in the relevant circumstances referred to in paragraph (1) to discuss confidential information in relation to that matter with the trusted contact person, and
(b) the written consent of the trusted contact person confirming that the regulated entity may -- retain the trusted contact person’s name and contact information for the purposes referred to in paragraph (1)
- contact the trusted contact person in the circumstances referred to in paragraph (1), and
- discuss the matters referred to in paragraph (1) with the relevant trusted contact person.
- For the avoidance of doubt, a trusted contact person has no authority to deal with the affairs of a personal consumer in respect of a regulated entity, and is not a legal representative for the purposes of these Regulations, solely on account of having been recorded or contacted by the regulated entity as a trusted contact person.
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Subject to paragraph (6), this Regulation does not apply where the regulated entity is aware that –
(a) a decision-making representative has been appointed in respect of the personal consumer and the appointment is in effect,
(b) the personal consumer has appointed an attorney under an enduring power of attorney and the enduring power of attorney is in effect,
(c) the personal consumer has appointed an attorney under an enduring power under the Act of 1996 and the enduring power under the Act of 1996 is in effect,
(d) the personal consumer has appointed a decision-making assistant and the appointment is in effect, or
(e) the personal consumer has appointed a co-decision maker and the appointment is in effect. - Paragraph (5) does not invalidate the nomination of a trusted contact person who has been nominated and agreed in accordance with this Regulation prior to the coming into effect of an arrangement referred to in paragraph (5)(a) to (e).
- In this Regulation, “co-decision maker”, “decision-making assistant”, “decision-making representative”, “enduring power of attorney” and “enduring power under the Act of 1996” have the meaning assigned to them in section 2 of the Act of 2015.