Improving survivor accessibility

Through consultations with leading UK and US banks, including those partnered with the FAST Survivor Inclusion Initiative and those who have allowed flexibility around accepted identity documentation, we have found positive examples and initiatives which are helping to address the existing barriers faced by survivors. We have taken these examples, alongside practical guidance for financial institutions, to demonstrate what can be done and how other financial institutions can take action.

In order for banks to make progress and promote survivor financial empowerment, it is essential to recognise and understand the barriers facing survivors.

For a re-cap on the nature of existing barriers to survivor financial inclusion, head to the ‘Barriers to survivor inclusion’ module.

To overcome the cycle of misinformation among survivors regarding their eligibility to open a bank account, it is vital that strong relationships and communication channels are created between retail banks and survivor support organisations to streamline the account opening process and ensure that survivors have access to the information they need.

Helpful initiatives include:

• Clear information packs and resources for frontline staff to inform them of the services available, necessary documentation and the account-opening process.
• Offering in-person talks for survivors and frontline staff to attend to explain the services available and answer any questions.
• Electing designated “survivor banking champions” from the survivor support organisation and the bank.

Building trusted relationships with survivor support organisations is key to overcoming documentation barriers. The FAST Survivor Inclusion Initiative helps banks to manage the risks of survivor onboarding with limited identity documentation. They also coordinate partnerships with survivor support organisations, who can verify survivor details and status using available templates provided by FAST. These can be adapted to suit the organisation’s needs.

Outside of the FAST Survivor Inclusion Initiative, other retail banks are also adopting a more inclusive approach to account-opening and alternative documentation. This has helped to ensure that regardless of a prospective customer’s immigration status or documentation, vulnerable customers (including survivors) can still access support.

Below, we have outlined key ways to help overcome documentation barriers.

Nationwide Building Society currently partners with a survivor support organisation in Birmingham. This partnership has been strengthened by having clear templates for accepted identity documents and the referral process.

Banks should clarify key details with the referring survivor support organisation prior to a survivor’s initial appointment, so there are no documentation issues during the survivor’s visit and that the needs of the survivor are met in a trauma-informed way. On referral, information regarding survivor location, language preference, individual needs and documentation should be provided by the referring survivor support organisations.

When partnering with local charities, banks should accept that it may be necessary for survivors to use the address of their supporting charity when they are unable to provide a permanent address. It may also be possible for them to use a ProxyAddress.

In all scenarios, it is important for the employees responsible for the account opening to work closely with financial crime, risk and regulatory teams. This will help to ensure that all parties are supportive of initiatives and understand the steps which are being taken to manage potential risks including account misuse, fraud and customer safeguarding.

It is important for financial institutions to recognise that some survivors will exhibit red flags during the account opening process such as previous fraud, immigration offences or low credit scores due to activity controlled by traffickers. To manage these scenarios, it is important that employees take a trauma-informed approach, prioritising compassion and respect to create a welcoming and supportive environment.

To avoid further risk of re-exploitation or financial difficulty, survivor bank accounts should feature specific protections to trigger an investigation if unusual activity is identified, ensuring survivors remain financially stable and can be supported if safeguarding issues arise.

Relevant survivor account protections include:

• Enhanced monitoring, with a focus on deposits and withdrawals, account closures and suspicious activity, such as the use of credit and cryptocurrency.
• No minimum balance, monthly fees or initial deposit requirements.
• Fee waivers on the accounts.
• Credit score waivers.

Flagging a survivor’s account offers greater account protection by monitoring unusual or suspicious activity. This is important to help manage the risk of financial re-exploitation for survivors who are vulnerable to manipulation. It is also valuable to flag an account in order to enable survivors to receive specialist support and ensure that they are not required to repeat traumatic information. Flagging an account for life can therefore help to accommodate the vulnerabilities of survivors and decrease the risk of re-exploitation.

To create a safe and welcoming space for survivors, we recommend that all customer-facing employees are aware of the essential elements of trauma-informed work, with additional training for specialist teams.

The Trauma-Informed Code of Conduct (TiCC) is designed to enable professionals to work with survivors of modern slavery and human trafficking in any context or environment.

Key focuses include:

• Establishing a relationship of mutual trust with survivors.
• Imparting a sense of calm, security and safety.
• Increasing the confidence of the survivor and minimising the risk of distress.
• Remaining safe during the course of work and avoiding any situation of distress or re-traumatisation.

Employing this Code of Conduct within the financial sector, with focussed training for frontline staff and specialist support teams, can help to prevent survivors from facing negative or distressing experiences when interacting with banks.

In addition to implementing the TiCC, working with the FAST Survivor Inclusion Initiative to formulate clear step-by-step frameworks for survivor account opening, will increase trust and help to create a supportive and positive environment.

Find out more about trauma-informed work and how to develop a trauma-informed training programme within the module “Employee training and protecting vulnerable customers.”

Language barriers can prevent survivors from opening and managing an account. Various approaches have been trialled by banks and provide a range of potential solutions to empower survivors and overcome existing language barriers. These include:

Where possible, trusted in-person interpreters will help survivors to feel most supported and understood, with interpretation through both verbal and non-verbal cues. Banks should not rely on survivors to provide their own translators as this leaves survivors vulnerable to exploitation if they do not have a trusted interpreter.

Having a list of colleagues and the different languages they speak makes account opening inclusive and accessible by ensuring that support remains only a phone call away. This has been successfully rolled out by Nationwide and can also be incorporated with employee volunteering schemes.

Subtitled videos & Easy Read formats are valuable tools to help ensure that key information is as accessible as possible for survivors and other customers with limited English. It is highly recommended that the materials be tested with the intended audience before they are considered finished to ensure usability.

Interpreting and translation services are available to all survivors who are receiving support within the U.K. National Referral Mechanism. These services should be discussed with survivor support organisations to identify how they can be used to facilitate account opening and follow-on support.

Many survivor support organisations provide access to English language classes. Partnering up to deliver a financial-focused class can help to increase awareness of the services available for survivors, as well as covering key banking terminology and providing additional language support.

Providing a simple jargon buster in multiple languages alongside basic banking guides will help survivors to gain a better understanding of different products and services. Using simple and frequently used terminologies will allow survivors to understand what banks offer.

Offering translatable or subtitled services within mobile banking apps will ensure survivors can access their accounts from anywhere in an efficient and streamlined way. Banks should allow customers to choose a language when signing into mobile banking to ensure accessibility for all.

Giving survivors the choice to access and manage their finances as they wish is a key to improving inclusion and promoting financial independence. Enabling suitable digital services for survivors can overcome physical accessibility issues such as disabilities, the cost of transport, difficulties navigating public transport and fear of travelling to an unknown place.

Facilitating access to online banking can help to overcome many of the issues related to physical accessibility and gives survivors the freedom to manage their money with greater flexibility. Banks should provide clear information on how to open an account online for survivors and survivor support organisations. This should also be supported with online financial education resources.

At Nationwide, customers have access to a range of digital demos, which are short virtual sessions designed to provide a self-serve approach to internet banking. This helps to make information accessible for survivors wanting to utilise their accounts independently, whilst also accommodating survivors who are not comfortable attending the branch in person.

Internet banking plays a key role in promoting all-around survivor financial empowerment and facilitating round-the-clock access for survivors to manage their money without physical barriers. Banks should address existing barriers, namely data poverty and digital literacy skills.

A number of positive examples exist in these areas and we recommend exploring the following:

• Support access to the U.K. National Databank.
• Collaborate with digital inclusion initiatives such as the Digital Poverty Alliance.
• Provide data-related rewards when a survivor opens an account. For example, in the same way that students might receive a 1-year Railcard, survivors could receive a monthly data bundle.
• Make key financial literacy guidance across online banking apps available offline (accessible without data).
• Expand and improve in-branch wi-fi access and access to tablets or computers across all banks.
• Provide drop-in sessions (and virtual classes) to support customers with basic digital literacy skills.
• Equip frontline colleagues with the skills and resources to actively promote digital inclusion.

Facilitating access to online banking can help to overcome many of the issues related to physical accessibility and gives survivors the freedom to manage their money with greater flexibility. Banks need to ensure that survivors and survivor support organisations are provided with clear information on how to open an account online. This should also be supported with online financial education resources.

The National Databank was established by Virgin, O2 and Good Things Foundation, to tackle data poverty across communities. Through partnerships with major mobile phone networks, free mobile sims and data are provided to members of the community who need it most. This helps to tackle the far-reaching negative impacts of data poverty and the inequalities that limited internet access can bring.

At Nationwide, customers have access to a range of digital demos, which are short virtual sessions designed to provide a self-serve approach to internet banking. This helps to make information accessible for survivors wanting to utilise their accounts independently, whilst also accommodating survivors who are not comfortable attending the branch in person.

1. Working closely with financial crime, risk and regulatory teams can ensure that they are supportive of initiatives and understand the steps which are being taken to manage potential risks.
2. Creating and sharing a clear information pack outlining the products available to survivors, necessary documentation and what to expect when opening an account, can ensure information is accessible for survivors and survivor support organisations.
3. Consider providing in-person talks for survivors and frontline staff to explain the financial services available and answer any questions.
4. Consider flagging survivor accounts for the life of the account and provide specific account protections such as enhanced monitoring and fee waivers, to protect survivors from re-exploitation and risk.
5. Ensuring that all customer-facing staff (at a minimum) have undertaken trauma-informed training can help to provide a safe space for survivors.
6. Identifying and training specific employees to become “Survivor Banking Champions” will allow survivors and survivor support organisations to always have a clear and reliable point of contact with the bank.
7. Providing greater accessibility by implementing measures to overcome language barriers, such as using external translation services or offering subtitled basic banking videos with multiple language options.