Proactive engagement drives greater vulnerability assessment and disclosure, MorganAsh finds

23 July 2026

New data from support services provider MorganAsh highlights the importance of proactive engagement when identifying vulnerable customers. The firm's data shows that customers are highly likely to complete vulnerability assessments once they begin the process, while take-up rates are significantly higher when assessments are embedded into key moments in the customer journey.

Analysis of data from the MorganAsh Resilience System (MARS) between 2023 and 2025, across different sectors, has revealed that 99% of customers who started a vulnerability assessment completed it, indicating that customers are comfortable answering questions about their circumstances once they engage with the process.

The data also found that proactive customer vulnerability assessments achieved an average take-up rate of 65% when undertaken during onboarding. This is closely followed by assessments at the review stage, where on average, 60% were taken up.

By comparison, where firms relied on standalone requests for information – separate to normal engagement with the customer – completion rates fell to just 3%.

Take up rates vary greatly depending on multiple factors, such as whether the relationship is new or existing, the lead source and the nature of the business. Where firms embed vulnerability assessments within an existing engagement process during onboarding and review, take-up rates often reach 100%.

Most firms fix on a single engagement process, either digital or human to match their existing process, while allowing the consumer to flex to suit their personal circumstances. Across all MorganAsh clients, just over half of assessments (53%) are completed independently by consumers using a digital link, while 47% are undertaken by an adviser or agent as part of a customer conversation. Comparing the data from digital and human identification reveals little difference, suggesting that the method used does not have a significant impact on the quality of data provided.

The MorganAsh data demonstrates that the majority of customers are willing to discuss potential issues and disclose vulnerabilities than many firms might believe – particularly when the conversation forms part of an existing service interaction.

The findings come as the industry continues to focus on how firms can confidently collect and use customer vulnerability data to deliver better outcomes and meet their regulatory requirements. New guidance from the CII on data privacy for customers in vulnerable circumstances highlights the importance of firms understanding how data protection requirements apply when supporting vulnerable customers. The guidance provides detail on how vulnerable customers’ data should be collected and stored to comply with both GDPR and Consumer Duty.

The CII’s guidance highlights the need for appropriate technology to manage this personal data and exposes the present dilemma – faced by many firms – who are hoping to find a GDPR loophole, that enables them to use existing systems not designed for this purpose.

The MorganAsh data proves that proactively engaging customers about vulnerability, at the right time and with clear explanations of why information is being collected, helps build the trust needed for meaningful disclosure and better provision of support.

Andrew Gething, managing director of MorganAsh said:

“Our data shows that objective, proactive assessment is absolutely key to identifying vulnerable customers, building the robust data required to improve service, deliver better outcomes – and report progress to the regulator. There have long been concerns about collecting this type of data – whether it is due to data protection concerns or fears that customers would be unwilling to disclose. On both counts, the combination of our latest data and fresh guidance from the CII proves that any fears or concerns are unfounded.

“In reality, customers are willing to disclose this information, providing that it is part of an engagement process and that they are fully aware of how it will be used to support better outcomes. By prioritising proactive engagement, it becomes less about assessment take-up rates and more about building trust in the process. There is tremendous value in having these important conversations, but it’s about having it at the right time and with the right technology, processes and infrastructure behind the firm to make sure that the data can be collected and used to support individuals as well as reported on properly.”

MorganAsh is a specialist in Consumer Duty and customer vulnerability. The firm provides its multi-award-winning MorganAsh Resilience System (MARS) to help firms understand and monitor vulnerable customers and deliver good outcomes – as required by Consumer Duty. It is in use across financial services and the utilities sector, enabling businesses to adopt a consistent approach to identifying vulnerable characteristics and generate an objective Resilience Rating – much like a credit score.

The new data privacy guidance is available for download from the CII.

To find out more about MARS or access a free trial, visit: morganash.com/mars or phone: 0330 159 8162.