At The Puzzlers Club, we are committed to ensuring that all our sales staff act responsibly, are able to understand how to pick up signs of a vulnerable customer, and understand how best to handle all situations with care and respect.

On occasion, sales staff will have conversations with people who will find it difficult to make an informed decision about making a purchase. It may be that they have a diagnosed condition such as dementia, undiagnosed or temporary mental health conditions, learning difficulties, literacy issues or even problems understanding the language.

Normally, in a commercial transaction, there is the assumption that the buyer knows what they want and can make an informed choice about the most appropriate product or service. However, vulnerable consumers can be trusting and believe that a sales representative (whose motivation is to sell) is acting in their best interests in an advisory capacity. These guidelines are designed to support sales staff in dealing with these calls in the correct way, while not discriminating against any respondent who may have a disability.

Identifying Vulnerable Customers

In order to address the needs of vulnerable customers correctly it is important to be able to identify them. Our sales staff are trained to look for risk factors, which can include bereavement, illiteracy, illness, disability or other impairment. In many cases, more than one risk factor is present which increases the customer’s vulnerability.

Our sales staff are alert to the signs that the person they are talking to may not have the capacity, at that moment in time, to make an informed decision about the implications of the agreements that they are making, for instance the purchase of a subscription. This is not a diagnosis of a condition, it is just an extension of our sales staff’s existing skill of listening, identifying needs, and adjusting their approach accordingly.

The Mental Capacity Act says that a person is unable to make a specific decision if they cannot understand information about the decision to be made, cannot retain that information in their mind, cannot use or weigh that information as part of the decision-making process, or cannot communicate their decision.

All sales staff should be alert for signs such as:

  • They ask you to speak up or speak more slowly
    • Can they hear the complete conversation or are they missing important bits?
    • Do they understand what you are saying?
  • They appear confused
    • Do they know what is being discussed?
    • Do they ask unrelated questions?
    • Do they keep wandering off the point in the discussion and talking about irrelevancies or things that don’t make sense?
    • Do they keep repeating themselves?
    • Do they say ‘Yes’ in answer to a question when it is clear they haven’t listened or understood?
    • They take a long time to get to the phone and sound flustered or out of breath, indicating they may have a lack of mobility due to age or illness.
    • They take a long time to answer questions. They say “my son/daughter/wife/husband deals with these things for me”.
    • Where there is a language barrier they are vulnerable as they may not fully understand what is being said to them.
    • They say that they don’t understand figures put to them, a previous phone conversation or recent correspondence.

Practical tips provided to our sales staff when talking to potentially vulnerable customers:

  • Speak clearly and enunciate.
  • Be patient / empathise.
  • Don’t rush them – it could take them some time to answer questions / queries.
  • Don’t assume that you know what the customer needs – it’s easy to rush through if the customer is slow or not able to explain what they need.
  • Clarify understanding at every point posing the question “is there anything you’d like me to explain?”.
  • Offer alternatives to dealing with things by phone – maybe they would prefer to transact the business by post or email.
  • Don’t assume that the person you are talking to can hear everything you are saying – they may have a hearing impairment.
  • Remember that a vulnerable customer can sometimes be forgetful or overly trusting.
  • Give the customer time to explain fully – don’t interrupt or show impatience.
  • Listen for what isn’t being said, not just what is – e.g. absence of understanding, commitment, timing type questions on the part of the person receiving the call should ring alarm bells.
  • Ask if there is a better time to call – e.g. some people will function better in afternoons than mornings.

Before making a sale, please think about the following:

  • Ask yourself honestly whether a ‘yes’ is real agreement or just submission.
  • Please consider whether the customer demonstrates that they have a general understanding of what decision they need to make and why they need to make it. Do they understand the consequences of making, or not making, this decision? Can they understand and process information about the decision? And can they use it to help them make a decision?
  • Be careful to distinguish between verbal cues and agreement e.g. ‘oh yes’ could mean ‘I’m listening’ not ‘I’d like to go ahead’.
  • Ask the following questions: “do you need to discuss this with anyone else” / “would you like me to explain any part of this call again” / “did you want to think about this before making a decision” / “is there anything we can do to help you deal with us”.
  • If they say something that suggests they don’t fully understand what you have said, be prepared to repeat or paraphrase to clarify understanding.
  • Don’t assume that they fully understand all the implications of the offer/agreement. Explicitly and clearly confirm all the important information.
  • Make sure that the respondent is not flustered, agitated, feeling pressured or in an emotional state when they make a decision.

If you are ever in doubt as to the vulnerability of the customer, please remember the following:

  • We never sell to anyone who is vulnerable, aim to end the call politely.
  • If you aren’t sure and want a second opinion, set a call back and ask for your manager to speak to the customer to provide a second opinion.
  • If you think that someone is vulnerable, please record an outcome of Do Not Contact, and feel free to advise them of the Telephone Preference Service so they don’t receive any other calls.
  • You will always get credit for a sensitively handled call – think about how you would want someone to speak to one of your elderly relatives such as a grandparent and use this as a guide.

Best Practice

What our sales staff do when a vulnerable customer is identified:

Once a vulnerable customer has been identified, or the sales staff member reasonably believes that he/she is dealing with a vulnerable customer, they should immediately refer the matter to their manager who must then review the service provided, regardless of whether the customer has been with the Company a long time.

All sales staff are then under a duty to identify those customer’s needs and vulnerabilities each time they speak with them to ensure consistency of service.

A customer’s circumstances can change so be aware of the fact that a customer might be telling you that they now have recent health issues which would warrant handling them as a vulnerable customer, in which case the call should be escalated to a manager.

If a customer is identified as being vulnerable and incapable of making an informed decision, then the customer’s account must be marked as ‘do not call’. Any contact with the customer or future orders must be initiated by the customer themselves and not as a result of an outbound call / mailing.

What to do when the customer alleges their incapacity is life threatening e.g. suicidal

Under no circumstances should the member of staff continue with the conversation if the customer suggests they may be thinking of committing or have committed any kind of self-harm. The case will be immediately passed to the manager who will contact the Police. The business will fully co-operate with any further Police enquiries and offer help to the staff member, if he/she has become distressed by the call.

Remember, all our customers are important to us, and those suffering with any incapacity or vulnerability must be particularly looked after, and treated with the care and respect they deserve.

All members of sales staff, regardless of grade or level, who have any customer contact must read this policy regularly, ensure they understand it fully, and sign at the bottom of this document to confirm this.

The Puzzlers Club has a strict Sales Code of Conduct

In order to protect our customers and the Company, sales staff at The Puzzlers Club must:

  • Get positive verbal agreement for The Puzzlers Club to call them, email them and write to the customer. This should be done on every call so we comply with GDPR.
  • Explain that The Puzzlers Club is an independent company to Prize Magazines, and other than historically allowing Prize Magazines to re-sell our products (and that arrangement has now been terminated), there is no connection between the two companies.
  • We must NEVER tell the customer they owe us money.
  • We must never lie to the customer.
  • We must politely ask for the customer’s Date Of Birth so that we can ensure that we don’t sell them subscriptions that take them beyond the age of 85 without their express permission to do so.
  • We should ask the customer for their email address so that we can communicate with them effectively.
  • We should be comfortable that the customer can afford to purchase their subscription.
  • We must explain that we have a clear cancellation policy, the customer has a right to cancel their order within 14 days of purchase. If they want to cancel the order after that, we should inform them that we will consider each request individually, and that in the event that a refund is made, we will deduct all reasonable costs incurred by the Company.


  • If asked, we must explain that the Company has a customer complaints procedure. The customer can email or write to us at The Puzzlers Club, Cranbrook House, 287 – 291 Banbury Road, Oxford, OX2 7JF and we will respond within 7 working days.
  • We must NEVER sell a subscription that would take a customer to more than a cumulative total of 10 years subscription to any individual magazine.
  • We must not sell any customer more than a total of 5 years subscription to any magazine in any 12 month period.
  • If we are topping up a subscription so that the total subscription is more than 5 years, we must disclose this and make sure the customer expressly wishes for this to be done.
  • We must always be respectful to all customers, never be rude, and never bully them.
  • We must not call any customer more than once in any 3 month period unless we have a new product to sell them which we think is well suited to them, or are calling to inform them that they have won a competition prize.