Consumer Duty & Vulnerability Detection
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.
Talk to us about Consumer Duty compliance
Available to FCA-regulated firms. Structured for procurement, compliance and technology teams.