Consumer Duty & vulnerability detection
Updated October 2026
EchoDepth deployed across a major UK insurer's recorded customer interactions to surface emotional signal indicators consistent with financial vulnerability - supporting FCA Consumer Duty obligations at scale.
The challenge
The insurer's contact centre processes thousands of customer interactions weekly. FCA Consumer Duty (July 2023) requires firms to identify and proactively support vulnerable customers - but traditional QA sampling catches only a fraction of interactions, and self-reported vulnerability disclosures are systematically suppressed by social desirability.
The EchoDepth deployment
EchoDepth was deployed across recorded customer service interactions, processing facial Action Unit data across 44 FACS-grounded markers. The system flagged emotional signal patterns consistent with cognitive overload, financial anxiety, and decision-making distress - producing a vulnerability probability score per interaction.
Data processing was conducted by Logic Software Ltd (ISO 9001, Cyber Essentials Plus) on Microsoft Azure UK Cloud, with a full GDPR-compliant DPA and DPIA in place.
Outcomes
- •Vulnerability signal detection rate significantly above standard QA sampling
- •GDPR-compliant processing framework established for ongoing deployment
- •Consumer Duty evidencing framework produced for regulatory review
- •Zero false-positive rate on follow-up case review
Available under NDA to qualified prospects. Request access below.
How can insurers detect vulnerable customers at scale under FCA Consumer Duty?
By analysing recorded customer interactions directly, rather than relying on QA sampling or customers disclosing vulnerability themselves. The insurer's contact centre processes thousands of customer interactions weekly, and FCA Consumer Duty (July 2023) requires firms to identify and proactively support vulnerable customers, but traditional QA sampling catches only a fraction of interactions. In this deployment at a major UK insurer, EchoDepth read facial action unit data across 44 FACS-grounded markers and flagged patterns consistent with cognitive overload, financial anxiety and decision-making distress, giving each interaction a vulnerability probability score. Processing ran on Microsoft Azure UK Cloud under a GDPR-compliant DPA and DPIA, and was conducted by Logic Software Ltd (ISO 9001, Cyber Essentials Plus). Outcomes included a vulnerability signal detection rate significantly above standard QA sampling, a GDPR-compliant processing framework established for ongoing deployment, a Consumer Duty evidencing framework produced for regulatory review and zero false-positive rate on follow-up case review.
Talk to us about Consumer Duty compliance
Available to FCA-regulated firms. Structured for procurement, compliance and technology teams.