Vulnerability Framework

AFSA Vulnerability Framework 2022-25

AFSA plays a vital role in supporting people experiencing vulnerability with many people who access our services already facing significant financial stress.

How we identify and respond to social and regulatory harms is outlined in AFSA’s Vulnerability Framework.

Our vulnerability framework prioritises and supports people experiencing vulnerability in our system, setting out a plan to target our efforts across 6 focus areas over the next 3 years. 

We want people who use our services to receive the information that’s right for their situation. Being flexible and providing extra support by providing simple information and intuitive systems will ensure we do not create additional stress for people experiencing vulnerability. 

We will work with clients, other government agencies, professional advisors and insolvency practitioners to achieve the right balance of support and service to meet community expectations.

A Message from Our Chief Executive

The Australian Financial Security Authority (AFSA) plays a vital role in supporting people experiencing vulnerability.

Many people who access our services are already in financial distress, making their risk of vulnerability higher. Natural disasters, a global pandemic, and other external factors like low literacy levels, mental health conditions and domestic violence have substantially increased this risk.

While these people are not exempt from our normal processes, we need to offer them extra guidance and assistance to navigate our systems. We must make sure our processes do not create harm, increase barriers, or cause unnecessary stress.

This Vulnerability Framework was developed to ensure that people who use our services receive the right information, at the right time, with the right level of support to reflect their situation. Being flexible and providing extra support through simple information and intuitive systems will ensure we do not create additional stress on people experiencing vulnerability.

I am excited to deliver this evolving piece of work that will deliver world-class government services and agile insolvency and personal property securities systems that are truly supportive of those in need.

Tim Beresford

Chief Executive, Inspector-General in Bankruptcy and Registrar of Personal Property Securities

Our Intent

Our vulnerability framework aligns with and complements existing initiatives already underway across AFSA and the Australian Government.

Our new Client Service Charter will provide people-centred, empathetic and personalised service to all our clients. Our work to support vulnerable clients will draw on these enduring values and principles. Our Capability Framework identifies an empathetic service culture as a key capability required across AFSA, ensuring we keep people at the heart of all we do. We are committed to protecting and supporting our people: both our staff and those that use our services.

Our vulnerability framework identifies, prioritises and supports people experiencing vulnerability in our system.

It sets out a plan to help us target our efforts over the next 3 years.

• In the first year, we will prioritise service – laying the right foundations to deliver the framework. We need to identify people who may be experiencing vulnerability so we can provide a compassionate and tailored service based on individual needs and circumstances.
• In the second year, we will prioritise information – supporting informed decision making by providing simple, relevant information and linking people with appropriate support
• In the third year, we will prioritise systems – delivering client-friendly processes through online and offline channels and having a holistic view of our clients.
• Looking beyond the next 3 years, we will use smarter technology, data and analytics to drive further strategic change.

The change starts now.

Although information and systems sit in the second and third year, it’s important to note that work will commence now; it will just take longer to implement and embed.

Understanding Vulnerability

Defining vulnerability

Using identifiers that focus on traditional cohorts or demographics alone are far too simplistic to identify those who need extra support.

Each client is unique.

We need to see people as individuals with their own circumstances, challenges, goals and needs. By categorising people into stereotyped ‘vulnerable groups’, we risk missing those who need additional support and over-servicing those who do not.

Anyone can find themselves experiencing vulnerability.

It is not a status, nor a label, and it does not define a person. It’s not only our debtors that can experience vulnerability, but also their partners, families, creditors, and clients of the PPSR.

Vulnerability is a dynamic, complex and multi-faceted concept.

It can be a part of someone’s life in different ways. It can be temporary, sporadic or permanent. Someone may not experience vulnerability all the time, and anyone can become vulnerable at any time. We recognise that vulnerability is rarely caused by one thing – someone’s demographics, personality, support networks, history, health, life events, personal situation and external circumstances can all impact how they experience vulnerability.

Financial vulnerability is a key focus.

AFSA’s business is finance. Based on the assumption that all clients accessing our insolvency services are seeking relief from unmanageable debt or seeking to recover money owed – our primary focus is on financial vulnerability. There are strong links between financial distress and mental health concerns. Financial abuse and coercive control – these will be supplementary focus areas.

Identifying vulnerability

Vulnerability isn’t always easy to identify.

Sometimes people will self-disclose or display obvious signs such as emotional outbursts, erratic behaviour, or pleas for support. More often, we need to piece the situation together by picking up on subtle hints. Our staff rely on soft skills such as active listening to understand a person’s circumstances.

Self-identification is our main method for identifying people who need extra support.

For AFSA self-identification is even more difficult, as people generally access our services unwillingly or out of necessity. For many people, they may not want to identify their vulnerabilities for fear of judgement, stigma or perceived repercussions. And for some people it can be difficult to acknowledge or recognise that they are vulnerable.

We need a safe environment where self-disclosure is encouraged. People needing extra help or more tailored support shouldn’t feel alienated or fall through the cracks. We need to ensure our culture is one of support; self-identification should not be treated with suspicion, and requests for extra support should not be ignored.

Our Focus Areas

Our vulnerability framework focuses on delivering world-class services to all our clients; and providing extra support to those that need it.

We want clients to have access to the right information, at the right time, with the right level of support to reflect their situation, via the right channel for them.

Our 6 focus areas will help us achieve this vision over next 3 years.

Focus area 1: Support our staff to support our clients

Staff are at the heart of our interactions with clients.

We know that staff are often put in difficult situations. Work environment demands and pressure to meet targets for call wait times can inhibit our employee’s ability to fully investigate a client’s circumstances and provide holistic service. This, combined with challenging conversations with frustrated or vulnerable clients, can lead to staff feeling drained, powerless, distressed and overwhelmed. Supporting the mental health and wellbeing of our staff is a priority.

The mental health of our clients is also a priority.

Financial distress – often coupled with other factors such as mental illness, social isolation, family violence, job loss and illness – can mean our clients often feel emotional, helpless, frustrated, scared and/or embarrassed. This is true of debtors and smaller creditors. We must provide a service where clients feel heard, supported and safe, while also delivering fair and equitable outcomes to all parties involved. We need to remember we are dealing with people, taking a phone first approach where appropriate, and following up if we have any concerns to ensure our response is timely.

This doesn’t mean our staff have to take on the role of a counsellor or social worker. It’s about displaying compassion and using soft skills to have respectful conversations, and then referring clients to the right external services with the relevant professional expertise.

A culture of empathy is central.

Some AFSA staff may identify as technical operators or specialists rather than service providers. To deliver on our vulnerability framework and to build trust in our brand and the services we deliver, our staff must connect with our purpose and be able to empathise with those they interact with. It is through a strong service culture and drawing on trauma-informed approaches that we can create a safe space for people experiencing vulnerability and prevent our actions from creating further harms.

We will provide compassionate, helpful and tailored services. This includes:

• being kind and patient when communicating, using a respectful tone and simplified language
• treating people with dignity and genuine care
• challenging our biases and refraining from being judgemental
• being honest, transparent and true to our word, ensuring we don’t over promise and under deliver
• responding with empathy, recognising and acknowledging people’s emotions and feelings
• asking people how they prefer to communicate and interact with us including any adjustments or special considerations they require
• asking people after providing information if they have understood, and repeating (or adjusting communication style) if necessary
• considering what cultural sensitivities and opportunities might apply
• respecting the lived experience of our clients
• empowering people to make their own choices based on their preferences, within the parameters of legislation
• speaking slowly and clearly for people who might have difficulty understanding
• listening actively to ensure we understand what is being said – not jumping to conclusions or interrupting
• respecting someone’s decision if they don’t need extra assistance
• creating a safe space for people to share information
• referring people to appropriate support services based on their individual circumstances
• ensuring privacy and protection of personal information
• reporting cases to authorities where there are safety concerns
• having a holistic view of clients, taking into consideration their broader situation and previous interactions.

We will create flexibility around how people meet their obligations.

While we are committed to detecting and addressing non-compliance, we need to remember that most of our clients want to do the right thing. We should not treat vulnerability with scepticism. For various reasons, often barriers out of their control, some people struggle to comply, despite their best intentions. People experiencing vulnerability still need to meet their obligations, such as providing documents and reporting on income. But we need to be flexible, where appropriate, to support people to comply. This means using our judgement to make exceptions, on a case-by-case basis, working within the parameters of legislation to help people meet their obligations.

Sometimes this could be as simple as explaining to people why we need certain documents or information, which could help reduce client frustration and improve cooperation. By assisting and supporting debtors to comply, we can help deliver fair outcomes for other stakeholders, such as smaller creditors, who can be equally vulnerable.

Where to next?

Our staff must be equipped with the right training, tools and guidance to have the confidence to deliver a world-class service to our clients. Our Capability Framework is already being implemented across AFSA, and has a core focus on building soft skills to foster an empathetic service culture. But we need a more considered approach to embed training and reinforce the principles from our Client Service Charter into our day-to-day jobs.

We also already have various guidance materials, outlining how to respond to specific circumstances, such as suicide threats. But we need a clearer plan to empower and enable staff to exercise judgement in individual circumstances. Staff need clarity about where flexibility or discretion can be applied.

Importantly, staff need to feel supported by their managers and senior leaders to take their time on calls with vulnerable clients who need extra support.

At the same time staff need to feel supported to end calls with clients who are being abusive, aggressive or disrespectful.

Focus area 2: Use data to drive outcomes

We need to be able to identify people experiencing vulnerability.

Offering compassionate and tailored service relies on knowing and understanding someone’s individual needs and circumstances.

We need to create a safe space.

This includes providing various opportunities and different formats for people to share their stories throughout their journey. For example, offering a combination of questions on forms as well as conversations that allow people to open up about their vulnerabilities. It can take time to build trust as people may be hesitant to disclose their vulnerabilities in the first interaction or form.

Where to next?

We will tap into multiple sources to help us build the best picture of someone’s circumstances, for example:

• data collected on forms which is self-reported (e.g. demographics, cause of bankruptcy)
• inferences from other contacts and events (e.g. if someone reports a change in personal circumstances such as job loss or inheritance; or repeated attempts at filling out and submitting form without completing or succeeding)
• conversations where someone self-discloses vulnerability
• conversations where our staff pick up possible signs of vulnerability (e.g. someone becoming upset, confused or agitated, someone experiencing language barriers, someone constantly checking with a third party, tone of voice).

Once a method for identifying vulnerability has been established, we can regularly report on vulnerability statistics and use insights to improve our services.

Also, to deliver our vulnerability framework in the next 3 years, we need to better understand how we can meet the needs of people experiencing vulnerability. We will conduct client research and seek feedback to drive continuous service improvements.

Focus area 3: Support informed decision making

Providing helpful information supports our clients to make informed decisions.

As a government agency, we can tend to provide information that is complex, technical, long and text-heavy. Our clients may struggle to understand our website content, forms, correspondence and phone conversations. Language barriers, low literacy levels and disability can compound these difficulties.

Confusing information can lead to non-compliance.

Investing time early to ensure people understand our information will save us time later. Providing simple information will help people understand our processes and their obligations. This prevents confusion that could lead to non-compliance, errors in reporting and client frustration.

Boosting public awareness of the PPSR is crucial.

Raising the profile of searching the PPSR will help prevent vulnerable clients from purchasing a car that is written off, stolen, or has finance owing.

Registering on the PPSR will help protect vulnerable small business clients, giving them additional rights if they have a secured interest over goods in the event their customer becomes insolvent.

Our information will be simple, relevant, accessible and inclusive. This includes:

• providing clear and concise information and instructions in plain English
• avoiding complex language, long words and sentences
• avoiding government, legal or financial jargon
• ensuring all information is accurate and up to date
• explaining complicated or legal terms in simple words
• offering information in various formats, such as text, images, infographics and videos, to cater for different preferences
• providing information at the time it is relevant throughout a person’s journey, rather than all at once
• offering personalised tools and information targeted to a person’s individual circumstances
• approaching communications with a compassionate, non-threatening tone
• making content easy to read, using white space, headings, icons/symbols, clear fonts and other design and formatting techniques to reduce cognitive overload
• making sure information is easy to find on our website
• ensuring all websites and systems are compliant with accessibility guidelines
• improving search engine rankings to help people find our website
• ensuring all information is regularly reviewed and updated based on client and staff feedback
• using gender-neutral language and inclusive pronouns (or avoiding pronouns where possible)
• clearly promoting our existing Translating and Interpreting Service (TIS National) and the National Relay Service
• using behavioural insights to better design our information.

Where to next?

We will prioritise ensuring our information is plain English and consistent across the agency – including our websites, correspondence and phone guides.

The AFSA website has recently been restructured to make the pathways for clients more intuitive. While improved navigation will deliver a better client experience, the content must be simplified and streamlined. This needs to be done in conjunction with creating consistent, simplified correspondence and updating phone guides to reflect changes to website information.

After this initial content review and refresh, we will focus on:

• providing important information in other languages
• developing simple resources that can be provided at community centres and other places that people experiencing vulnerability may This will help people who may want to discreetly get information, for example people who may feel shame or stigma around bankruptcy or people experiencing family violence
• using behavioural insights and nudges to tweak the language and design of our correspondence, communications and other written material to encourage voluntary compliance, including techniques such as SMS reminders
• looking at the functionality of the AFSA website to support different vulnerable clients (e.g. creating personalised tools to support informed decision making and helping victims of family violence stay safe online by implementing a ‘Quick Exit’ button).

Focus area 4: Collaborate across sectors to provide support

People experiencing vulnerability are at risk of receiving poor advice or being taken advantage of.

Factors such as disability, incarceration or language barriers can leave clients vulnerable to relying on someone to interact with us on their behalf. Some of our clients are socially isolated or may not know where to go for help, so may struggle through our processes alone or end up turning to untrustworthy or expensive advisors. And sometimes, well-meaning third-party advisors might not fully understand insolvency or the PPSR themselves, leading to unintentional poor advice.

AFSA is committed to ensuring people receive the right information, at the right time, from the right people, to make informed financial decisions. This includes:

• linking people in financial difficulty with free financial counsellors and practitioners
• referring debtors, creditors and clients of the PPSR to trusted third parties, including interpreters and translators
• connecting people with other relevant support services, based on their individual circumstances – such as mental health support services, gambling support, family violence support, legal and financial services, or other government services
• connecting people through warm referrals where possible.

Partnering with external stakeholders can deliver holistic and cohesive support.

People often have complex and intertwined factors impacting their lives – financial, health, safety and psychological concerns do not affect people separately. Better connecting with corporate and not-for-profit organisations can provide joined up support for people experiencing vulnerability.

We are committed to building financial capability in the community.

Referring people to the right resources and services to develop their financial literacy skills will help them make informed financial decisions.

Providing more support to people after they enter our systems can help reduce repeat insolvency and drive public confidence in the personal insolvency and personal property securities systems.

Where to next?

While we already connect our clients with trustworthy advisors, support services and resources, we need a more considered, coordinated and consistent approach. We will strengthen our referral model, existing relationships with external stakeholders, and build and expand on these partnerships with a vulnerability lens. We will also pilot a financial literacy program for people after they have become bankrupt to help build money management skills.

Focus area 5: Provide streamlined processes and inclusive channels

People accessing AFSA’s services are often stressed and overwhelmed.

This includes people struggling to pay their debts, people struggling to recover debts owed, and people struggling to search or register on the PPSR. This can lead to difficulties processing information, difficulty planning and avoiding tasks. We will deliver streamlined, simplified, human-centred processes to reduce the cognitive overload and minimise the administrative burden on clients.

This includes:

• only seeking the information we need
• not asking questions more than once
• breaking complex processes down into smaller steps
• setting expectations upfront about next steps
• having a consistent approach across AFSA.

We are shifting to modernise and digitise our services.

While we are committed to a digital first approach, we must also ensure our services are accessible for all.

We know that some people struggle to interact online due to low digital literacy, reluctance to use technology or concerns around data privacy. Designing client-friendly services and offering additional support will help people feel more confident.

We must offer accessible offline options for people to interact with us.

We know that some people want to exclusively interact online – including people experiencing vulnerability who may prefer online as their channel of choice. Processes and systems that are easy to navigate will help empower our clients to self-serve.

And we know that sometimes people want to swap between channels, according to how they’re feeling at the time or what the task is – this experience needs to be seamless.

We will deliver an intuitive online client experience. This includes:

• having pre-filled information where possible
• having the ability to auto-save progress and complete later
• providing a tracker to show progress through a process
• ensuring all websites, systems and forms have an intuitive navigation, design and layout
• ensuring forms cannot be submitted unless the required information in the correct format is entered
• offering additional support for people who struggle to interact online
• ensuring safety-by-design in our online services.

We will deliver an accessible offline experience.

We must cater to people who don’t have access to a computer, printer, scanner, photocopier, phone, email account or internet. This includes:

• being able to access and submit paper forms in a timely manner
• being able to update details or provide information/documents through an alternative channel
• ensuring there are alternative pathways for people to prove their identity if they have difficulty providing traditional identification documents
• offering additional support for people who need it.

Where to next?

We are already redesigning our services, focusing on improving the client experience both online and offline. A new system will deliver these services, creating a coordinated experience for clients and staff across channels. The project considers this vulnerability framework during the design, development and implementation, to ensure the new system meets the needs of our diverse clients.

Once the system and the service delivery model are implemented, we will establish a continuous review and iteration cycle. This will include incorporating behavioural insights to improve interactions and exploring enhancements, to offer various channels for engagement.

Focus area 6: Have a holistic view of clients

Siloed teams and systems that aren’t integrated leads to a frustrating client experience.

Without connectivity across AFSA, we can create and exacerbate harms by asking someone to explain their circumstances multiple times to multiple people. We need a tell-us-once approach. While it’s not always practical or possible to have a single point of contact, it shouldn’t stop us from having a single view of the client. This will allow us to better understand someone’s situation and circumstances, previous interactions, and possible vulnerabilities so we can provide the support they need.

Where to next?

A project is already underway to deliver a new case management system which will be the ‘one source of truth’ for all client interactions with AFSA. The new system must have the ability to flag any previously disclosed vulnerabilities.

We should also be able to use the system to identify possible vulnerabilities, based on the data collected about a client and flag them, so we can proactively tailor services where clients do not actively disclose vulnerability.

Beyond the Next Three Years: Smarter Data and Strategic Partnerships

Smarter technology, data and analytics will better identify and serve people in need.

Using technology to scan forms for key words such as ‘suicidal’ or ‘homeless’ or ‘abusive relationship’ could help us identify people who need customised support or urgent attention. Identified clients could be fast-tracked to a priority queue with a specifically trained service officer to provide tailored help.

Linking with other government agencies will help build public confidence in our systems.

Normal data sharing agreements such as with the ATO and Services Australia, and integration with other government services such as MyGov, are critical to the delivery of people-centered services. Data sharing will improve the client experience by reducing their burden. It will also ensure the information we receive is accurate, helping AFSA achieve fair and equitable outcomes. People interacting with government don’t usually differentiate between agencies and teams.

They often expect government – especially Commonwealth departments – to share data.

It’s not just government agencies that we can partner with.

In the longer term, AFSA could develop strategic partnerships with community organisations, financial counsellors and social workers to provide holistic and cohesive support to people with more complex circumstances.