John Fairhurst and Robert Skinner, Board Directors of the Money Advice Liaison Group (MALG), have been leading on the development of our strategy for Data Protection and Vulnerability with specific reference to the reforms to the Debt & Mental Health Evidence Forms (originally developed by MALG and now hosted on the MALG website) and are seeking partners to help fund the project.
Appropriately recording and sharing information about vulnerable clients is an area in which both money/debt advisers and creditors can struggle to find the right balance between their regulatory obligations and the needs of their clients/customers. There isn’t, as far as MALG’s Board can establish, any comprehensive guidance either currently available or in development which specifically covers the needs of over-indebted consumers.
Although MALG has previously issued some briefing notes on this important topic they are now out of date and so have been withdrawn from our website. We are very conscious of the lack of guidance in this area and so recently commissioned Chris Fitch of the Money Advice Trust and Robert Bell to conduct a scoping review to establish the work needed to bring our guidance up to date and account for the Data Protection Act (2018), General Data Protection Regulation guidance (2018), European Data Protection Board guidance and Information Commissioners Office guidance.
We are now in a position to understand the work required to produce guidance in this complex area and would like to commission the work required to produce a comprehensive briefing note on data protection and vulnerability. Our intention is to produce this alongside reforms to the Debt & Mental Health Evidence Form (on which there has been encouraging progress which we will be able to report on shortly). This is a significant piece of work but one which we believe will be extremely valuable to those working with over-indebted consumers (and indeed an area highlighted in the recent FCA guidance consultation on the fair treatment of vulnerable customers.
As you may be aware, MALG has very limited resources. Although we are very happy to co-ordinate the development, launch and publication of this guidance we will need external sponsorship in order to commission the work required to bring this about. We are therefore seeking partners to help us fund the project. The overall cost is estimated at £20,000.
We are now looking for expressions of interest from organisations who might be willing to contribute to our costs. Given the lack of current guidance we are keen to begin work as soon as possible and have taken the view that a consortia of funders is likely to provide a quicker route to funding than finding a single sponsor willing to pay the full cost (although we would be delighted if someone was willing to do so!) We have already had expressions of interest from two organisations.