Policy development

Vulnerable Circumstances Policy Service

We review, update or write your vulnerable circumstances policy. One flat fee. Three versions — one for charities and fundraisers, one for FCA-regulated firms, one for marketing teams. Each version is built around the rules that apply to you.

What this service does

Most policies on vulnerable circumstances are out of date. Some say all the right things but do not match what the team actually does.

This service fixes that. You get one piece of work for one flat fee. You pick what you need:

  • Review — we read your current policy and tell you what to change.

  • Update — we refresh your policy against the current rules.

  • New policy — we write a new policy from scratch.

A senior person leads the work. You sign the policy off through your own process — board, trustees, or another route.

We do not call this a "vulnerable persons" policy. Vulnerability sits in the situation, not the person. So we write about "people in vulnerable circumstances". The policy uses those words throughout.

Contact us

1. Email us at hello@vulnerabilitymanagers.com with a message about how we can help.

2. Free call. We’ll arrange a 30 minute video call to clarify the details for the support you want.

3. Written proposal. Sent to you within 5 working days, including a project outline and exact price.

8,400+ professionals trained

2,100+ organisations supported

33 countries reached

Working since 2012

Three versions — pick the one for you

Different sectors follow different rulebooks. We build three versions of this service so the policy lines up with the rules that apply to your team. The price is the same for each. The contents differ.

Charity & Fundraising

For charities, NGOs, in-house fundraisers and agencies who fundraise, including third-party fundraisers and trustees of fundraising charities.

Lead rulebook

Code of Fundraising Practice 2025 (in force since 1 November 2025) — sections 1 and 5.

Also based on

  • Fundraising Regulator guidance on donors in vulnerable circumstances

  • Code rules 1.3.7 to 1.3.10 (now rule 5.2.3 in the 2025 Code)

  • Charity Commission CC3 (trustee guide) and CC3a (safeguarding)

  • Charity Governance Code 2025

  • CIOF guidance on Treating Donors Fairly

  • Charities (Protection and Social Investment) Act 2016 — reporting requirements

Financial Services

For FCA-regulated firms — banks, lenders, insurers, payment firms and others that want to meet the FCA's standard as best practice.

Lead rulebook

FCA Finalised Guidance FG21/1 — Fair treatment of vulnerable customers. The FCA's March 2025 review confirmed it still applies.

Also based on

  • FCA Consumer Duty (PS22/9) — the four outcomes and the cross-cutting rules

  • The FCA's four drivers of vulnerability (health, life events, resilience, capability)

  • SM&CR — senior manager accountability for fair treatment

  • BS 18477 / ISO 22458 — inclusive service standards

  • FCA Financial Lives Survey — current vulnerability data

Working across more than one of these?

Charities that take payments under the FCA's rules sit in two areas. Agencies running fundraising and commercial marketing sit in two camps. On the scope call we blend the versions you need. There is no extra charge for that — it is part of the flat fee.

Two underlying laws apply to every version. The Equality Act 2010 covers the duty to think ahead about disabled people's needs. The Mental Capacity Act 2005 covers the five rules on capacity to make a decision. The Care Act 2014 also sits underneath for charities and any organisation with safeguarding duties.

Marketing & Direct Marketing

For marketing teams, agencies, direct marketers and data leads running direct marketing, telemarketing, email marketing, paid social or digital marketing.

Lead rulebook

DMA Vulnerable consumers Internal policy framework (2022)— the direct marketing reference for the UK. Vulnerability Managers contributed to it.

Also based on

  • DMA Code of Practice

  • DMA Multichannel Guidance for Consumers in Vulnerable Circumstances (2021)

  • ICO direct marketing guidance

  • PECR 2003 — the rules on electronic marketing

  • UK GDPR and Data Protection Act 2018

  • ASA CAP Code — advertising rules

  • Data (Use and Access) Act — for charities using soft opt-in

What is in every version

Whichever version you pick, the work itself is the same.

A 45-minute scope call.

We agree what you need — a review, an update, or a new policy. We confirm which version to write. We agree which other rules to factor in.

A document review.

We read your current policy and the policies linked to it — safeguarding, reasonable adjustments, equality and inclusion. We check they line up.

One working draft.

We write the policy in two parts. Part 1 is the policy itself. Part 2 is the process — what the team does day to day. Plain English. Clear about what your team offers and what it does not.

One round of changes.

You send us your team's feedback. We work it into a second draft.

A 45-minute handover call.

We walk through the second draft with your policy owner. We explain why each part is there. We tell you what to watch for at your next review.

A six-step process map.

One page. Six steps for staff: pause, listen, ask, adjust, signpost, record.

A list of sources.

A short note of every rule and piece of guidance we used. Drop it in as an appendix.

Optional add-on — accessibility review

Most policies look fine to the policy team and fail the people the policy is for. The accessibility review fixes that.

We review readability, plain English, layout and formatting, alternative formats, contrast and policy template designs. We can also adapt language to improve inclusion as well as support access with assistive technologies (screen readers are an example of this).

For fundraising organisations, this also helps you meet a Fundraising Regulator expectation. The Regulator says fundraising communication should be "accessible and inclusive", with anticipatory adjustments where reasonable.

Pricing

One flat fee. One optional add-on. Discounts are available for smaller organisations, groups and different formats. Contact us for more details. All prices exclude VAT.

Policy service — any version

£3,850

Accessibility review (optional)

£1,250

Policy and accessibility review

£5,100

Contact us

1. Email us at hello@vulnerabilitymanagers.com with a message about how we can help.

2. Free call. We’ll arrange a 30 minute video call to clarify the details for the support you want.

3. Written proposal. Sent to you within 5 working days, including a project outline and exact price.