From consultation to inclusive design – the power of lived experience

by Martin Coppack, Director, Fair By Design Campaign

As an ex-regulator, I have spent many years ‘consulting’ with external organisations. I have also spent many years being consulted as a consumer representative. As the Payment Systems Regulator (PSR) consults on its new strategy it is a great time to take a step back and ask what we mean when we talk about ‘consulting’? 

What I have learnt is that the way a consultation is ‘done’ can make the difference between tough, difficult issues being acted upon, or being placed into the ‘too hard to do’ box.

I am very excited about the PSR’s consultation because payments have never been so relevant to people’s lives. The PSR now has an opportunity to ensure that the lives and views of people who are not usually seen or heard by regulators are captured and considered. Now an opportunity exists to prioritise the needs of people for whom competition theories aren’t working and for whom the market doesn’t work well – and for those where that familiar adage, ‘empowered consumers driving the market’ simply doesn’t ring true.

We still live in a country where poor people pay more for everyday essentials like financial services and energy. And how they pay is a key factor. For many, direct debits simply don’t reflect the world they live in. Not everyone has a steady income throughout the month. If you’re on a zero hours contract direct debits can actually be dangerous to your financial health because not everyone can guarantee the same amount of money is going to be available at the same time each month. Many people need to have much more flexibility in how they pay their bills and need the ability to ‘request to pay’ – to help smooth out their irregular incomes.

Otherwise they cannot use direct debits due to the penalties imposed. In turn, they will often pay more for the exact same product.

And for many cash remains a lifeline, but they are charged extra for using it due to, for example, a lack of access to free-to-use cash machines. When 1 in 7 of us relies on cash and over one million people in the UK don’t have a bank account, this is simply not fair. People need to be able to easily access and use cash – and not to be penalised for doing so.

These are just a couple of examples where the market has been designed around a one dimensional consumer – one that reflects the lives of those who work in financial services and in regulation.

My challenge to the PSR is to consult and design your strategy inclusively. We can all over rely on tools like social media and liaising with consumer representatives like me, rather than speaking to the real experts. I encourage you to go further and to actively spend time with people who are not like you, and not like me. 

When making difficult decisions about your priorities it is vital that your decision-makers truly understand what would make the biggest impact on the lives of people you don’t regularly come into contact with.

What are financial services like for the one in five people in the UK living in poverty? Do they work well? What are the problems and what do the best solutions look like – to them – even if the best solutions mean working and joining-up with other regulators and in partnership with government. People’s lives are messy and rarely fit into the neat boxes that match individual regulators’ remits. But by starting with people ‘where they are’ and co-designing the solutions with them, the best solutions can be found. This is inclusive design at its best.

And my offer to you, from Fair By Design, is that we can help you do this along with our partners at Toynbee Hall. We can help your decision-makers engage directly with people living in poverty to see what it is like to be in their shoes – to truly understand the impact of your decisions and what you need to prioritise.

We all have a part to play to design polices that work for everyone.

Let’s work together.

About Fair By Design

Fair By Design is dedicated to ending the poverty premium: the extra costs people on low incomes pay for everyday products and services like energy, credit, and insurance. We are made up of a Campaign and a Venture Fund. Our Campaign collaborates with businesses, regulators, and policymakers, to design out the poverty premium. The Venture Fund provides capital to help grow innovative ventures that are developing products to make markets fairer. To read more about our work on inclusive design in essential services and our work with experts by experience visit fairbydesign.com.

We want to hear your thoughts on the topics raised here, so please do send us an email at psrstrategy@psr.org.uk or join the discussion here.