Vulnerability vs Disability: Mind the Gap

In this episode of Accessible Finance, host Prerna Goel speaks with Kathryn Townsend — Head of Customer Vulnerability and Accessibility at Nationwide Building Society and founder of the Deaf Inclusion Consortium. She was previously the UK Government Disability & Access Ambassador for banking.

Together they explore why disability inclusion still lags behind vulnerability frameworks, how digital transformation risks leaving disabled customers behind, and what practical steps banks and fintechs can take to embed accessibility from the start. Kathryn also shares her experience leading industry coalitions, collaborating with Project Nemo on learning disability research, and pushing organisations beyond compliance to truly inclusive design.

If you want to understand what it takes to make accessibility a default in financial services, this conversation is full of insights, challenges, and solutions.

Transcript

Prerna

Hello and welcome to Accessible Finance, the podcast from Project Nemo, where we explore what it really takes to build a financial system that works for everyone. I'm your host, Prerna Goyal at Project Nemo. Our mission is simple but urgent to make disability inclusion a default, not an afterthought. We are here to go beyond the buzzwords and talk about the systems, policies, products and people that are reshaping financial services from the inside out.

And few people embody that mission more than today's guest. I'm absolutely thrilled to be joined by Kathryn Townsend, one of the most respected and effective voices driving accessibility in UK banking. Kathryn is the head of customer vulnerability and accessibility at Nationwide Building Society, a UK government Disability and access ambassador for the banking sector and the founder of the Deaf Inclusion Consortium, a pioneering coalition of over 30 organisations working to address the systemic exclusion of deaf and hard of hearing people in financial services.

She is also a close collaborator of Project Nemo, helping us launch a report on adults with learning disabilities who face daily barriers in accessing and managing money, whether it's embedded in collusive design and legacy systems, advocating for policy reform or amplifying the voices of people often left out of the conversation, Kathryn has led with empathy, urgency and strategic clarity.

Kathryn, welcome to Accessible Finance. It's such a pleasure to have you here. Thank you so much. It's a pleasure to be here. So to get started, when I was doing research before this podcast and I was looking at your bio, you've worked with government across the banking sector and with non not-for-profit sector. How do you describe the work you do today? And and what was it that first sparked your commitment to accessibility and inclusion? 

Kathryn

Well, I'll start with the last question first, if I may. So, I've worked in financial services for over 15 years. And when I first started at Barclays, where I was for 12 years before nationwide, I was in the branch design team, you know, there was a really strong commitment to physical inclusive design in the physical space.

It was really important that every branch that we refurbished or acquired, it was left more accessible than we found it. However, we hadn't necessarily, as an industry thought around the access needs in other channels, you know, which is where people were doing their everyday banking nowadays. So there was a need and an urgency to kind of put that into telephony channels.

Digital accessibility and on all parts of the organisation, end to end. So there was a really strong focus on accessibility there, and it was brilliant to be part of a lot of pioneering initiatives around inclusive, debit cards, credit cards, talking ATMs, services for deaf people. However, then in the, in parallel, there was a strong regulatory push from the Financial Conduct Authority, the FCA, which is the UK's regulator, to look at more, around vulnerable customers.

Now, it's really important that this audience listening if you are disabled or a disability ally, that you don't think that we all think about vulnerability equally, or disability or disability equalling vulnerability. The important thing there is that if banks and building societies and financial services providers fail to make services accessible, they make the consumer vulnerable. So it's a little bit of a shift because the other side, the vulnerabilities that due to your personal circumstances like hospitalisation, domestic abuse, homelessness, we need to make your services inclusive and fair.

But when it comes to disability, it's it's the banks and financial services providers that can create issues. If we don't address the barriers. And we need to be proactive in recognising the barriers that need to be removed. So it's just my absolute pleasure to work in this space. You know, financial services is so important. It cuts through all aspects of life, from cradle to grave.

And we need a functioning banking system and financial services system that works for everybody. And and that's what I'm trying to do through, through nationwide, and through also my government disability role. So it's my, you know, mandate to really drive better outcomes for vulnerable and disabled people. Through my day job and across the industry where we can shine a light on best practice to help others get there quicker.

And if we can, if we can do that collaboratively, you know, that's brilliant. You know, there's so much appetite for banks to work a bit differently and share best practice around vulnerability and disability inclusion, which is brilliant because in a lot of ways, obviously banks and quite rightly or, you know, very protective of innovation and the strong anti-competition laws.

But when it comes to vulnerability, the regulator's been very clear that they are happy to see collaboration to drive better outcomes for consumers. 

Prerna
So, Kathryn, thank you for for sharing that. And thank you for bringing out a very important point, which is around the difference between vulnerability and disability. And my question next question is actually related to to that point, having been in the banking industry for almost 25 years now, I have seen that there is a decent level of understanding and work happening from the perspective of vulnerability.

And obviously we have lots of regulations which also mandate that we do a good job of understanding who are vulnerable. Customers are how we treat them, how to service them, what kind of products and services we are offering them. But the same doesn't seem to translate to the area of disability. Not to the same level of understanding.

And obviously Project Nemo has highlighted how big the gap is. Can you help me understand from your perspective and from your experience why there is that divide, or why there is that difference? And I do appreciate the difference and, and all of that, but it's they are so closely related. And you would think the intent of the regulation is broader than just vulnerability.

It's about all customers. So why do you think there is that gap? 

Kathryn
That's interesting because I guess I kind of see the opposite. I see how much financial services still needs to do. And that's why, you know, the work of the ambassador Program or Project Nemo. And everybody who's driving change in this space is so important. But actually, when you look at the vulnerability guidance, the most mature areas are those of disability inclusion because we've had the yeah, you know, the Disability Discrimination Act and, you know, the Equality Act 2010 out for decades.

And so there is, I think, more advanced understanding of people's needs in that area because of the law, but also because disabled people generally know what they need. They know that they need the font bigger, they need a non, digital option, whatever it might be. People know their needs and they can advocate for them some in some other ways, or financial services and vulnerability.

It's not quite as clear about what the solution might be. And people need to sort of be driven by, emerging innovation. I'll give you an example. So firms are now required to have systems in databases that can record people's support needs so that firms can meet them better. It's the regulator refers to this is like tell us once.

And, what's really interesting is within those systems, they need to kind of consider all relevant components of vulnerability and disability. But we see a much, much stronger maturity of support needs around accessibility and disability than we do for some of the circumstances that are a lot more, there are a lot more emerging. And so you can record things like, please give me large print, please, in face to face encounters, look at me when speaking because I need to lip read.

Please, let's go to a quiet space because I can't, you know, I need a quiet area when it comes to disability, I think things are a little bit more binary around. This is the things that the firm can offer, and this is the thing that consumer needs. And you can come together with some of the areas of vulnerability, consideration for people with problematic gambling, for example, or or domestic abuse, other circumstances.

It's much more complex, and it's harder to prescribe the exact thing that people might need consistently. I know it's quite complicated for people to maybe get their their heads around, but but I actually think that, to your point, accessibility is quite advanced in financial services. And when you compare it to other industries, retail, you know, travel, we're actually much further ahead because of the regulation ourselves.

That's not to say we don't need to do more, but compared to other industries, financial services and then essential services providers like energy as well, who are closely regulated, are also a bit further ahead than those non-regulated areas. But but of course, we need to do more. 

Prerna
Okay, that's an interesting point. So then why do we keep getting, whenever we do research, whenever we talk to people from the disabled community, whenever we look at data, it keeps telling us that as we are moving more and more and more and more digital, we are leaving people from the disabled community behind.

So there seems to be a bit of a disconnect in what the data is telling us and what. And I understand where you're coming from from a regulatory perspective. So where do you think we are? Where is the gap then?

Kathryn
I think that we are not great at putting the requirements and user needs in right at the beginning.

It's still a little bit too much of an afterthought or, you know, we're not using lived experience as much as we can. We're not making it into the product design process. So we might think about them, but it comes too late. And so there's this kind of like, oh, well, we'll fix it later or we'll come back to that.

Or, you know, we're not necessarily making sure and mandating that we get things right first time and recognising that, you know, we shouldn't be going live with a product or service unless we're absolutely clear that it's fully accessible. It meets digital accessibility guidelines. It's a fully accessible physical environment. Now, there's a few things to consider in that we don't live in a bubble.

So the actual ecosystem in which we set the technological ecosystem is changing all the time and advancing all the time. So there are new and new ways to resolve historical barriers. We might go live with something which tomorrow could be more accessible because of new innovation or technology, if that makes sense. So, you know, I or, new accessible solutions are evolving all the time.

So it's about listening and being aware of those solutions to continually review your products and services, and make sure they're not causing harm or barriers. 

Prerna
Yeah. No, I think that makes sense. So, just moving to another, part of your, role, which is the deaf, inclusion Consortium, which you founded in 2022. Tell us a little bit more about that.

What prompted you to start it? What was the intent and what kind of impact has has it had so far? 
Kathryn
So the Government Disability Ambassador program is a voluntary program, for business leaders driven by the, it's managed by the Cabinet Office in the UK government. And their mandate is to improve the lives of disabled people relevant to your sector, using your skills, knowledge, experience and connections.

So the brief is very broad. There's a I'm the banking ambassador, but there's an insurance, buses, education, retail, tourism. There's 20 of us. So when I came into post, I it was up to me really to decide the scope of what I wanted to do. And I spoke to my peers across financial services, and I looked at some of the things that would come through my inbox around issues that were faced.

And I was very, very aware around the needs and issues of deaf people. There are 18 million people in the UK who have hearing loss or a British Sign Language users, you know, recognising the two communities. You've got the deaf community with the capital D, who are those who are generally deaf from birth and identify as being culturally deaf.

That's a smaller volume, but they've got higher, or more complex needs. Then you've got the larger volume of 18 million people who may have age related hearing loss or hearing loss of other types. But actually, as a spectrum, it's really, really, really important that we address these needs. And I wanted to focus on that because of the significant prevalence, but also because I feel that the solutions exist today.

There are lots of areas where we still need to figure out what solutions are. But for this issue, we just need a needed, a concerted focus on that topic. And so I hosted a roundtable a couple of years ago, bringing a few passionate firms together and people with lived experience, and we agreed this was something that really needed focus.

We worked with the Lending Standards Board, the LSB, who produced an Insight report in 2023 to give a state of the nation on disability and deaf inclusion in banking. And then since then, I've been chairing a monthly industry group that's now at around 40 banks, building societies, fintechs, insurance providers. And we come together every month to talk about the issues, share best practice, look at the insights, and then report annually on our progress.

And it's it's not rocket science. It's it's a really simple method. But by by by being absolutely laser focussed on the needs of the deaf community, we've really seen the difference that that can make. And the data is showing that it is driving change, which is which is pretty amazing. 

Prerna
So what kind of tangible changes you've seen across the industry at the back office?

Kathryn

So with regards to deaf inclusion, we we have solutions about that things like video relay servicing and access to instant British Sign Language interpretation. Historically, it could take 2 to 3 weeks to book a face to face interpreter because of the shortage of interpreters and the challenges around that. So one one thing was around providing instant access using everyday technology like I can.

So your own smart device, whether that's in a branch environment, or in a telephony environment, when you call into the contact centre. Now, what we'd seen was a few years ago, it was the big banks, the big high street firms had invested and launched that technology, but the smaller firms hadn't. And now we're really seeing the smaller firms understanding that.

And and coming on board by learning from what others have done and and understanding that best practice. But what we're seeing this that the other firms are continuing to push the envelope. So for example, at nationwide side, we recently launched a brilliant service called sign Lee which is a digital solution to turn a website into British Sign Language using human translators.

You get a little pop up, come on the screen, and it translates that content into BSL. And a lot of people listening to this might think, well, you're talking about deaf people. They can read why? Why do I need to translate a website? But what a lot of people don't understand or appreciate is that British Sign Language users have a first language of sign, not English.

It's completely different sentence structure and syntax. The words and sentences are, you know, in a different form and order. So it's like giving someone a different language if you give them a website in English. So it's about driving accessibility in all of your channels and all of your content. And, and so we're seeing greater adoption of things like, those services.

But also we're looking at how firms are rolling out training, deaf awareness training, or using lived experts in the development of their products or services, or creating staff network groups for deaf colleagues. 

Prerna
Oh yeah, I hadn't like I think that's that's a really insightful, point. I didn't even just, you know, before you told me that. And it makes perfect sense that if you have if you have, if you're born deaf and if you're only learning British Sign Language and that's your first language, and yeah, it makes perfect sense.

But, actually, finally, a colleague and a colleague of mine recently from A small Start-Up, reached out to me because of my involvement with Project Timor. And they have, recently onboarded a customer who is deaf. And she's like, I have no idea what to do. How to make sure that we service him effectively. So if there are smaller companies out there, fintechs, who want to do the right thing but don't know where to start, what are some of the things they can do which are easy to do and get started on this journey?

Kathryn

So the first thing that they should do is go to signing banks.uk, which is a brilliant resource, and it's got two purposes. One is a front door for deaf consumers to find out around accessible services to help them. And the other front door is for banks, fintechs and financial services providers to see best practice. To get access to booking lift, Experian apps or training.

It's it's a brilliant resource that's sponsored by nationwide to help people make change. So they should do that. But also, I guess we should do we should, encourage firms to do an audit like a gap analysis to think across your channels that you offer. So whether that's branch digital telephony webchat, how would somebody who cannot hear or cannot see or cannot move or You don't you don't have to make it sort of more complicated than that at the first past. Just think, have I got channels that could work for people who can't do that, one of those things due to an impairment. So you should start by performing a gap analysis, and then you can work on launching services to make sure, that people can access them.

And, you know, this isn't a nice to have. This is a legal requirement. And under the Equality Act and and solutions do exist. And so it's really important to be aware of where the gaps could be occurring. 

Prerna
Amazing. And make sure she listens to this podcast episode. So just coming to your collaboration with Project team, the amazing work we did, in terms of the learning disability and the research that came out of it, talk to me a little bit about your experience through that, how you think, working with project Nivo will help the industry and, and some of the insights, you've gathered to that experience, you know, working with Project Nemo,

Kathryn

with Jo and Kris has been the absolute highlight of my time as I'm banking ambassador. I came across Jo and Kris last year, heard about Project Nemo and obviously its broader remit of, excuse me, remit of driving disability inclusion in fintech. But what happened was last October in 2024, obviously Jo had been really, a trailblazer in getting disability inclusion as a category, the pay 360 awards.

And which nationwide won that award. And so, after sort of sitting that down at that event together and just saying, wow, you know, we we've really got a shared passion on disability inclusion. We should get together and look at what we could do. So in later October last year, we sat down and just quickly realised that we both had a strong passion to amplify the needs of people with a learning disability, and that we wanted to come together and do something to drive change in that area, put a spotlight on this community who do not get enough advocacy, and there's not enough traction in financial services.

They are being left, left behind, you know, to your earlier point. And within two months, we'd arranged this brilliant roundtable, which was hosted at Nationwide's offices, in offices in London, and we had over 80 people from banks, fintechs, regulators, charities, families with lived experience coming together to say what were the challenges that they perceived across different lenses. And and what did we think was needed to drive change?

And off the back of that, we've spun up a working group, that meet every Wednesday, you know, with Jo and Kris and some other parents of people with with lived experience and we've come together to set out these sort of 4 or 5 workstreams and workstream one was all around identifying new research so that we could publicly share something that gave people the answers and the insights.

I've I've what this usage group needed, because that was one of the challenges that we identified at the roundtable. And so nationwide, I'd sponsored the production of a report that was new primary research, interviewing over 300 people with a learning disability and their supported family members and carers, to understand what their barriers and needs were when it came to everyday banking and to independent access to spend money to live independently.

And that's been absolutely wonderful to be part of. And the report is obviously available on the Project Nemo website. And we launched that on the 19th of June this year alongside giving updates on the other workstreams around legal and regulatory consideration, existing innovations and new innovations. Well, what we've achieved in six months is mind blowing, but it feels like there's been a real zeitgeisty with people wanting to drive change.

It's sort of felt like it's been the right people, the right time to drive this conversation, because everybody we've spoken to recognises the urgency, recognises the need and is is keen to lean into this issue which has been brilliant. 

Prerna
Awesome. Yeah. And I had the pleasure of attending the, the, the event where we, launched the report and gave updates on various workstreams that was absolutely amazing to see everything come together.

Having been part of the team from early days when we were still trying to figure out what project team I should do to to that event, it it felt like such a big achievement. So I thank you for firstly for your support on that. So just going back to one point we made and I think this was quite interesting when we were looking at some of the output of the report as well as our industry is obviously very highly regulated and is very motivated by making sure we manage our compliance with regulations.

We manage our risk. So a lot of the work that happens, unless it's commercially, driven or obviously commercially driven, a lot of the work is very motivated to making sure we meet requirements of various regulations and risk, requirements. And historically, a lot of the work and the vulnerability space, accessibility space has been viewed very much from a compliance lens.

So what do you think needs to change there? Or do you firstly agree that that work has been done from a compliance lens? And if so, how do we get people to move away from just doing what is absolutely required from a compliance perspective to really building inclusive products? As you mentioned, that one of the challenges is it's an afterthought.

Kathryn

It's not being taught as how you fundamentally build your products. And so I think that compliance and regulation has helped to drive this because it's a competitive and complex and busy landscape. Technology, as we've said, is changing all the time. People have lots of different priorities, so regulation and clear expectations is sometimes needed to help drive, that prioritisation, obviously, like I said earlier, when it comes to disability inclusion, the law already existed.

So we kind of didn't need the disability regulation as much. Although vulnerability is more broad and covers characteristics that are not covered by the Equality Act. So that's why that vulnerability guidance is really key. But but the regulation certainly has helped. I think that if you if you have an example of a service that is breaking down barriers and you get that in front of the people who need it and you, you hear that feedback through, let's say, your product lifecycle design process.

And, you know, you're you might do some focus groups and you're sharing that service with them to test it. Having that feedback about the difference that an inclusive product or service can make to their lives for me, can't fail but touch you and help you see that this is this is crucial. This isn't about, you know, nice to have features.

This is about true inclusion and accessibility. And, you know, I appreciate that. Not everybody has my mindset. And, you know, and other people may be more business case driven. But ultimately these are also your customers. So it's harder to track the negative impact of exclusion because it's not always clear. And people might point to the lack of complaints received.

But I would say to them, disabled people are so discriminated on a daily basis that it becomes habitual ized. And unfortunately, disabled people don't have the energy to fight the battle with every firm where they face challenges. So just because you don't have the complaints data, if you know and you've done your gap analysis and you can see that it's also possible that somebody could be excluded, then you are certainly losing customers.

You're certainly causing a poor experience. And so that's not good for your business case either. So ultimately, whether you come at it from the passion driven perspective of wanting to do the right thing or you're coming at it through the hard nosed commercial lens, this is win win. This is good to do, and it's the right thing to do, and it's good for business.

Prerna

Yeah. And I think we have seen time and again when you make things more inclusive, more accessible, it benefits everybody. Right? It's not just for those few for you know, where it's obvious the need exists. So, coming to your, role at nationwide. Nationwide is obviously leading the way in on many fronts in this area. You talked about few examples.

What does it take to get a big organisation like nationwide behind, this type of, topic? And what can others learn from that? 

Kathryn
Nationwide strives to be driving banking that's fairer, more rewarding and for the good of society. That's our complete business strategy. But if you look at that through the lens of disability inclusion, you can understand how that applies at every layer.

We want to be fair. We want to be more accessible, we want to be more inclusive, and we want to be a beacon to other firms to help show how disability inclusion or vulnerability inclusion can be done right. You know, of course we're on a journey. All funds are on a journey, but we are striving to do more, but also to help help show others how things can be done.

So we do try to be, very open in our and collaborative in our approach from the, you know, the sponsorship of the report, which is obviously available to everybody, but also to another example, at the other end of the scale, we launched a wonderful tool, last year called speakeasy, which is a physical set of cards in our branches, which are rolled out to all of our 605 UK branches last year.

And it was created with the British Institute of Learning Disabilities and the Stroke Association. And it's a set of cards with icons and simple sentences and simple phrases to help people, and there's estimated to be 5 million people in the UK who struggle to communicate, whether that's through motor neurone disease, Parkinson's, autism or anything to communicate in a face to face encounter.

So you can grab these cards in the banking hall and show them to the colleague and help facilitate a conversation. In a face to face environment. But we don't want to stop there. We don't want these just to be for, our colleagues. These are things that can be applied in other banks or other retail, or other customer services settings.

So we are now working to actually consider how we can create a white labelled version of these cards to open out to everybody. So I think that when you help others, they can get there quicker. And also there's there's learnings and best practice that can be shared across financial services. And we do that through the UK Finance Vulnerability Committee and through all the innovation and a best practice sharing that I've just described.

Prerna

That's amazing. I really hope that, some of the work we have done in Project Nemo can also start creating more such collaborative, examples. And with nationwide leading the way, I think, I think there is an opportunity for our industry to really make a difference in this space. I am conscious that this is a topic we can talk about for hours and hours.

So before we close it out, I have one final question for you, which is if you could change us, one thing about how our sector approaches disability inclusion, what would that be and why? 

Kathryn
Bringing people with lived experience into the conversation. You know, bring it before you even start on a journey of what you might need to fix.

Just invite people in and invite in your customers with different needs, and and hear from them about what's working, what's not working. And it will drive greater. Engage and understanding than you can imagine. 

Prerna
That's amazing. We have heard this a lot in our journey as well. And I think, Kris, our co-founder, talks about this all the time that it's, everybody is talking on behalf of us, and for us and designing products for us, but never really engaging with us to be able to provide real life experience that will help design truly innovative products.

Listen, Kathryn, thank you so much for taking this time. This has been an amazing conversation. And some really insightful points have come out, and my understanding has, changed as well in terms of, you know, how I perceived, differences between vulnerability and disability, where potentially there is, more progress than we, we expect and, and where there is more work to be done.

So thank you so much for taking this time. And, I will share our learning disability report as part of this podcast. And if there are any other links that, we can share, I'll include them as well as part of the launch of this podcast. So thank you so much. 

Kathryn
Thank you, thank you.