Vulnerable Residents Policy
Vulnerable Residents Policy J U N E 2 0 2 6
Page | 1 Contents Contents ................................................................................................. 1 Overview ................................................................................................. 2 Regulatory Alignment & Purpose ..................................................................... 3 Scope ..................................................................................................... 3 Definition of Vulnerability ............................................................................ 3 Identification of Vulnerability ........................................................................ 4 Reporting Vulnerabilities ........................................................................... 4 Vulnerability Categorisation .......................................................................... 5 High Risk (Priority Services) ........................................................................ 5 Medium Risk .......................................................................................... 5 Low Risk ............................................................................................... 6 Priority Services Support .............................................................................. 6 Customer Support & Communication ................................................................ 6 Customer Care Advisers ............................................................................. 6 Additional Support ................................................................................... 7 Payment Difficulty & Additional Support ........................................................... 7 Information, Advice & Signposting ................................................................ 8 Third-Party Working & Information Sharing ........................................................ 8 Monitoring, Reporting & Continuous Improvement ................................................ 9 Review & Governance ................................................................................. 9 Document Owner Version Date Author Changes Head of Business Operations 0.1 June 2026 K. Baker, S. Hoddle First Draft
Page | 2 Overview At Data Energy, we are committed to treating all customers fairly, with dignity and respect. We recognise that some individuals and households may be in a vulnerable situation due to personal characteristics, health conditions, age, financial challenges, communication barriers, or other circumstances that make it significantly harder for them to engage with energy services and protect their interests. As a specialist metering and billing provider, we aim to deliver our services in a way that supports fair consumer outcomes and aligns with the expectations of the Heat Network Market Framework Regulations (HNMFR). We understand that vulnerability can be temporary or long-term, visible or hidden, and may affect a resident’s ability to: • access information; • understand communications; • manage payments; • report issues; • engage with customer service processes; or • maintain safe and reliable access to heating and hot water We aim to identify and support vulnerable customers proactively and consistently, ensuring that these customers can access the information, service and assistance they need without undue stress or detriment to their wellbeing. Where Data Energy is acting on behalf of a heat supplier, operator, managing agent or landlord, we will carry out our metering, billing, customer service and debt management activities in a manner intended to support the authorised party’s obligations relating to vulnerable consumers. In doing so, we will: • recognise a broad and dynamic definition of vulnerability; • make it easy for customers to self-identify or disclose support needs; • provide clear, empathetic and accessible customer communications; • support the maintenance and administration of Priority Services information; • identify potential indicators of vulnerability during day-to-day interactions; • tailor our approach where vulnerability is identified; • support fair and affordable approaches to payment difficulty; • escalate safeguarding or welfare concerns appropriately; • support clients with compliance-related information and reporting where applicable; and • continually review and improve our processes and training. This policy sits alongside our Debt Management Policy, Residents Complaint Policy, and Customer Service & Communications Policy processes and all applicable Ofgem authorisation conditions and guidance, ensuring that Data Energy meets or exceeds regulatory expectations in the support we offer customers in vulnerable situations.
Page | 3 Regulatory Alignment & Purpose Data Energy is not ordinarily the authorised heat supplier or operator responsible for compliance with the Heat Network Market Framework Regulations. Ultimate responsibility for compliance with applicable Authorisation Conditions remains with the authorised person. This policy sets out the standards, controls and processes Data Energy applies when delivering metering, billing, customer service and related support activities on behalf of clients operating regulated heat networks. The purpose of this policy is to: • support clients in meeting their regulatory obligations; • ensure Data Energy’s services align with relevant regulatory expectations; • demonstrate operational competency and governance maturity; • promote fair resident outcomes; and • provide a consistent framework for identifying and supporting vulnerable residents. Scope This policy applies to: • all customer accounts managed by Data Energy; • all forms of billing (credit and pre-payment); • all Data Energy employees involved in customer service, billing, debt management, and technical support; and • third parties acting on behalf of Data Energy where applicable. Definition of Vulnerability Data Energy recognises that a vulnerable situation may arise where the personal circumstances and characteristics of a person create a situation where they are: • significantly less able than a typical person to protect or represent their interests; and/or • significantly more likely than a typical person to suffer detriment, or where that detriment is likely to be more substantial. Vulnerability may be permanent, temporary, sudden or fluctuating. Examples of vulnerability may include, but are not limited to: • physical disability or mobility impairment; • visual or hearing impairment; • chronic illness or medical dependency on heating or hot water; • mental health conditions; • cognitive impairment or learning difficulties; • age-related vulnerability; • bereavement; • financial hardship;
Page | 4 • language or communication barriers; • digital exclusion; • domestic abuse; • social isolation; • temporary illness or injury; • households with very young children; or • any circumstance that may impact a resident’s ability to engage effectively with services. Data Energy recognises that residents may not always disclose vulnerabilities directly and that staff should remain mindful of indicators that additional support may be required. Identification of Vulnerability Data Energy aims to identify vulnerability proactively and sensitively during interactions with residents. Potential indicators of vulnerability may arise through: • customer service interactions; • billing and payment discussions; • repeated missed payments; • complaints; • debt management activity; • reports from managing agents or landlords; • third-party contact; • communication difficulties; or • welfare concerns identified by staff. Residents may also self-identify or request support directly. Reporting Vulnerabilities Data Energy are committed to making reporting a vulnerability as easy as possible. We allow residents to report over the phone, via our ticket system or via live chat, and we store this information against their profile. Data Energy provide an online Vulnerability Declaration form to allow residents to notify us of support needs, communication requirements or changes in circumstances. These declarations are intended to make it easier for residents to proactively request support and help ensure relevant information can be considered during service delivery, billing support and customer interactions. Where vulnerability declarations are submitted, the information provided should be reviewed appropriately and recorded or shared with the heat supplier or their appointed Managing Agent. Upon receipt of this information, Data Energy will: • Record the resident’s vulnerability status on their heat account; • Add any specific support requirements;
Page | 5 • Where relevant, override all disconnection protocols (credit and pre-payment), ensuring the resident is protected. If a Heat Supplier or appointed Managing Agent is made aware of a vulnerability at an address Data Energy manage, they should report this to us so that records can be updated accordingly and the correct support provided. The Heat Supplier or appointed Managing Agent should review the shared vulnerability information regularly to ensure records are as up to date as possible. Vulnerability Categorisation To help ensure residents receive an appropriate level of support, Data Energy operate a tiered vulnerability approach. This approach is intended to support consistent decision-making, prioritisation and escalation, while recognising that vulnerability can change over time and should always be considered on a case-by-case basis. Residents identified as High Risk are likely to require enhanced support, prioritisation or escalation due to circumstances that could place them at significant risk if heating, hot water or communication support is interrupted. High Risk (Priority Services) • Occupant age o Over 70 o Under 5 • Long-term illness / medical condition • Disability (physical or cognitive) • Severe mental health condition • Severe sensory impairment Customers classified as High Risk will be added as Priority Service Residents and will automatically be exempt from suspension action on both our prepayment and credit billing services. They will have a priority marker added to their account so any Authorised Clients accessing the portal will be able to easily distinguish them as requiring priority services. It is up to the Heat Supplier or their appointed Third Party to ensure that communications and support during both planned and unplanned outages are provided to residents classed as Priority Service Residents. Medium Risk • Pregnancy • Financial vulnerability • Temporary illness/injury Customers classified as Medium Risk will be assessed by our fully trained Customer Care Advisers to understand if their circumstances require priority services and account amendments will be made accordingly, if they do need to be exempt from suspension action on both our prepayment and credit billing services. If this is the case, they will have a priority marker added to their account so any Authorised Clients accessing the portal will be able to easily distinguish them as requiring priority services.
Page | 6 Low Risk • Language preference only • Mild financial pressure • Early-stage pregnancy (no other risk factors) Customer classified as Low Risk will have a vulnerability marker added to their account to ensure their circumstances are always taken into account when interacting with them. Priority Services Support Data Energy will support the maintenance or administration of Priority Services Register on behalf of clients. Priority Services support includes: • recording support requirements; • vulnerability markers; • nominee or third-party contact arrangements; and • additional account support requirements. Where Priority Services information is held, Data Energy will: • handle information sensitively and in accordance with applicable data protection requirements; • take reasonable steps to keep records accurate and up to date; • review records periodically where appropriate; • use information only for legitimate operational and support purposes; and • provide secure access to the PSR via our Client Portal. Customer Support & Communication We have a dedicated operational arm of the business who are responsible for all customer solutions. The Head of Customer Solutions is appointed to oversee all aspects of our interaction with customers and improvements to these services as required. Having a unified approach to Customer Solutions allows us to deliver meaningful change to customers whilst maintaining regulatory compliance. Customer Care Advisers Our team of Customer Care Advisers are all trained to handle communications from all customers, ensuring their needs are supported throughout the duration of their interactions with us. We have clear routes to escalation including a comprehensive complaints and escalation policy and an independent escalation resolution specialist. All Data Energy staff interacting with customer information must: • Treat vulnerability reports with sensitivity and urgency; • Ensure accurate and timely updates to the resident’s account; • Follow all protocols related to disconnection prevention; • Communicate appropriately and respectfully with vulnerable residents; • Maintain confidentiality and comply with all data protection regulations.
Page | 7 Additional Support Where vulnerability is identified, reasonable adjustments may include: • Adding a nominated person/third party to their account • Setting a memorable word or password for added security; • Contact preferences for billing and other communication o Phone o Text o Email o Post • Large print and or Braile communications • Billing and engagement support o Explanation of bills clearly signposted and available online with invitations to contact our team if required for additional support. o Easy access to information surrounding repayments and invitations to contact to our team if repayments are causing problems. • Language preferences (where available) • Other support where applicable o Customers will be able to suggest or request any additional support they may feel is appropriate for their circumstances. Payment Difficulty & Additional Support Data Energy recognises that vulnerability and financial difficulty are often linked. Where acting on behalf of a heat supplier or managing debt-related processes, we aim to support fair and proportionate approaches to residents experiencing payment difficulties. This may include: • signposting residents to support services or independent advice; • supporting affordable repayment discussions; • allowing reasonable time for engagement; • identifying potential vulnerability before escalation activity; • supporting clients with information relevant to vulnerability considerations; and • avoiding unnecessarily aggressive or inappropriate communication. Where vulnerability is known or suspected, staff should consider whether escalation activity remains appropriate and proportionate in the circumstances. Data Energy does not independently authorise legal enforcement or disconnection activity unless specifically authorised contractually to do so. Ultimate responsibility for decisions relating to disconnection, enforcement and regulatory compliance remains with the authorised heat supplier or responsible party. Concerns should be escalated appropriately regarding residents that we understand to have high risk vulnerabilities before further action is progressed.
Page | 8 Information, Advice & Signposting Data Energy aims to make it easy for residents to access helpful information, support resources and relevant third-party guidance. Where appropriate, our billing communications, customer correspondence and customer interactions may include signposting to relevant support services and resources, including: • independent debt advice services; • energy efficiency and energy-saving guidance; • Ombudsman contact details; • heat supplier or managing agent contact details; • relevant regulatory or consumer advice information. Data Energy maintains a Residents Hub webpage containing: • news and service updates; • FAQs; • guidance documents; • helpful resources; and • other information intended to support residents connected to heat networks. This information is available regardless of whether a resident has registered for online account access. We also provide a customer portal where residents can access account information, correspondence, billing information and other relevant account services 24 hours a day, subject to service availability. More information on this is available in our Resident Debt Management Policy. Third-Party Working & Information Sharing Data Energy may work alongside: • heat suppliers; • heat network operators; • managing agents; • landlords; • maintenance providers; • the Energy Ombudsman; • Ofgem in their capacity as industry regulator; • debt escalation specialists; • metering contractors; and • other service providers. Where third parties are involved in service delivery, Data Energy remains responsible for ensuring that its own activities are delivered in accordance with this policy. Where contractually agreed, relevant vulnerability-related information may be shared with authorised parties or operational partners where: • necessary for service delivery;
Page | 9 • necessary to protect resident welfare; • required operationally; • contractually permitted; and • compliant with applicable data protection requirements. As part of our contractual agreement with any third parties, Data Energy will ensure that appropriate GDPR, data processing and sharing clauses are in place. Monitoring, Reporting & Continuous Improvement Data Energy aims to continually improve its approach to vulnerability support. This may include: • reviewing customer feedback; • monitoring complaints and escalations; • reviewing support outcomes; • identifying trends relating to vulnerability or debt; • reviewing operational processes; • improving staff guidance and training; and • supporting clients with relevant reporting information where applicable. Where vulnerability-related information is maintained on behalf of clients, Data Energy may support the provision of operational or reporting information relevant to regulatory reporting requirements. Review & Governance This policy will be reviewed periodically to ensure it remains aligned with: • evolving regulatory expectations; • industry guidance; • operational practices; • contractual obligations; and • lessons learned through service delivery. The policy owner is responsible for ensuring the policy remains current and that relevant operational teams are made aware of any material updates. Data Energy is committed to embedding fair treatment, accessibility and resident-focused service delivery throughout its operations and client support activities.