Opening Statement

Highland Broadband Networks Limited takes its responsibility towards vulnerable customers seriously. We are committed to making sure that wherever possible we will support a vulnerable individual to take full advantage of our services. Wherever possible, we will work with our customers to identify their specific needs and provide them with a suitable solution.

This policy outlines some of the practical steps we take to adhere to this commitment.

How we define vulnerability

Vulnerability comes in many forms, may not always be visible, and can be acquired, temporary or situational. It is also a matter of perception, whereby two people experiencing very similar issues may view their degree of vulnerability differently. Whatever the specific issue, we will always engage with you empathetically to understand your requirements and provide relevant support measures.

The list below broadly defines the conditions we consider would qualify a person to be considered as vulnerable:

• Is managing poor physical or mental health and/or a long term injury
• Has a physical or intellectual disability
• Is blind or has restricted vision
• Is deaf or has restricted hearing
• Has a carer or support person to assist in their daily life
• Is undergoing changes in their personal circumstances such as bereavement or unemployment which is impacting their ability to manage expenses.

This list is not intended to be exhaustive, and we will always consider cases that don’t clearly fit within these parameters.

What we can do for you

As part of our onboarding process we will direct you to this vulnerability policy, and how you can inform us of any specific requirements you may have. You can also update us at any time if your circumstances have changed.

There are a number of measures we can consider as part of our ways to help you. At a minimum – and with your permission – we will make a note on your account that will flag to us that you are a vulnerable customer and what your specific needs may be.

Once your needs are understood, some practical measures we can look to implement would be:

• Naming an additional support person on your account to make enquiries and/or manage things on your behalf
• Examining a technical solution to ensure VoIP services can continue being operational in the event of a power cut*
• Where you are experiencing financial hardship we will work constructively with you to manage your costs
• Where a debt has been accrued, we can direct you to debt support organisations such as Citizens Advice and Step Change to develop a manageable repayment plan

Lastly, where other solutions are requested we will always consider them.

Our Staff

All staff that interact directly with customers are provided with training on how to identify and assist customers who may have a vulnerability.

This training is reviewed regularly to ensure it remains fit for purpose. Where we are alerted to a shortcoming in our approach, we commit to addressing this by updating our processes and training as quickly as possible.

Confidentiality

We understand the importance of maintaining your confidentiality at all times, and especially if you have informed us of a vulnerability. As an organisation we take our obligations under the Data Protection Act (GDPR) very seriously, and will always do our utmost to protect all information that we hold on you.

*Please refer to section 4.3 of our Terms and Conditions for further information on our VoIP services.