Attention utility providers: Why you have a special obligation to combat family violence

Family violence is one the most pressing social problems on the national agenda. Reported rates in our communities are unacceptably high and on the rise.

While all businesses have a responsibility to play their part to address the crisis (e.g. by fostering gender equality in the workplace and providing appropriate leave provisions), the responsibility is not shared equally. 

Household utility providers like household energy and water providers have special obligations – legally and as part of upholding their social license – to play a more active and specific role in combatting family violence. This stems from three factors:

1. They provide joint account facilities and online service platforms, which can function as vehicles for perpetrators of family violence to cause harm
2. They provide an essential service to hundreds of thousands of customers – community members cannot simply opt-out of powering their house or receiving clean drinking water
3. They are required under state and territory regulation to meet minimum standards for protecting customers affected by family violence, with breaches resulting in significant financial and reputational penalties. The precedent set by regulators in recent times is clear – minimum regulated protections apply to all customers, not just those who have made their provider aware of their experience of family violence.

In this article, we explore how utility businesses can approach this issue, along with insights to help you assess risks and opportunities in your current practices. Our thinking is informed by the voices of victim-survivors, our recent work with utility providers to review their approach to protecting customers experiencing family violence, and our deep expertise working with federal, state and local governments in the area of family violence policy and prevention and response capability.

Utility providers with mature approaches to protecting customers experiencing family violence excel in four areas of practice. The areas of practice reflect the voices of utility consumers with lived experience of family violence, the operational contexts of utility providers and the regulatory environment. They are:

1. Product and service structure: They incorporate user safety into the design of products, services, systems and processes
2. Customer interactions: They are set-up to effectively recognise, respond, record and refer customers experiencing family violence at all customer touchpoints in their service model
3. Financial supports: They increase the utilisation of government supports a by customers experiencing family violence by removing barriers to access
4. Monitoring harm: They track indicators of family violence and raise unusual matters when they are identified

In the following sections, we provide an overview of each area, along with some questions to help you assess your own capability in each domain. 

A utility provider’s products, services, systems, and processes – originally designed on the basis that customers enjoy healthy relationships – can inadvertently harm customers experiencing family violence. Providers are often not aware of where customer safety risks are located – because of this, they can’t ‘design-in’ user safety to their business model. There are six areas of heightened customer safety risk  

1. Identify verification processes that rely on basic personal information only and/or are not applied outside the contact centre (e.g. in field-based interactions)
2. Online portals that have more relaxed registration processes or levels of supervision than the utility service account they relate to, but contain similar information (e.g. access to personal information)
3. Account passwords or security flags that are susceptible to being missed by customer agents, e.g. because they are not prominent on backend systems during service interactions and/or unintentionally archived (e.g. when a customer changes address)
4. Policies and processes that make it difficult for customers experiencing family violence to either remove themselves or someone else from a joint account facility quickly and cleanly
5. System rules that update customer information across multiple service accounts automatically without the knowledge of the customer or provider, e.g. mailing address changes
6. Field agents (in-house and subcontractors) that are not easily identified, interact with customers without notice (e.g. to access a sewage spill) and not supervised by the customer-centre (e.g. because work orders are allocated on different systems). 

Beyond product and service design, utility businesses also need to consider what they will do when they become aware (or have reasons to suspect) that a customer is experiencing family violence during direct service interactions. Leading organisations perform four actions to support customers experiencing family violence in service interactions. Together they represent the 4R Framework:

• Recognise the customer is experiencing family violence, either through disclosure or observable indicators prompting relevant safety questions
• Respond with empathy and consideration for the range of supports available and current service context, staying within the boundaries of the staff member’s role and the organisation’s remit.
• Record the family violence vulnerability on internal systems, with the customer’s informed consent, to enable extra support to be provided in future interactions and prevent repeated disclosures.
• Refer the customer internally to more specialist teams or externally to support agencies (via a “warm referral”), if their needs exceed what can be provided in the current service context.

A framework is only as good as its practical application. There are four considerations for applying the 4R Framework successfully in your organsiation: 

1. Providers must be set up to execute the 4R Framework across all customer touchpoints where a disclosure of family violence is possible – not just in the contact centre. These touchpoints could involve field agents, debt collectors, community engagement officers and/or service centre staff.   
2. Escalating every case to a specialist team – even when frontline staff can handle the relevant service request – can exacerbate harm. Often the best outcome for the customer is to resolve their request as quickly as possible before offering extra support. This will be harder if frontline staff are only rewarded for speed or lack permissions to apply extra support.
3. Providers need to be mindful about the way they offer and frame available family violence support. Choice is paramount, and the customer must be offered the option of additional support with a clear explanation of what that means in practical terms. Using terms like “family violence flag” or “security flag” can feel stigmatising. Instead, framing support positively, as extra care positions the support as ‘part of the service’, something anyone might need.
4. A record that identifies a customer as receiving extra care (e.g. a ‘family violence flag’) is a positive thing because it enables the provider to provide extra care now and into the future. Providers should track the number of these flags and treat increases as a sign of their approach working.

There is an established link between family violence and financial hardship. Around 60 per cent of women leaving abuse report serious cash flow problems, including being unable to pay electricity, gas, or phone bills on time. Utility providers have their own financial challenges: providers are experiencing rising levels of household debt as consumers struggle under the weight of increasing living costs and the Government winds back COVID-19 support.

These competing forces create a challenge for utility businesses trying to provide financial support to customers experiencing family violence while also managing their own financial sustainability, especially in a climate where financial counsellors and consumer advocates are questioning traditional debt recovery methods that simply kick the problem down the road.

While there is no easy solution, some of the most helpful financial supports for a customer experiencing family violence are those that reduce their financial liability and ease the impact of economic abuse. The most effective way to do this is by increasing the utilisation of government entitlements. Unlike debt waiving, this is a win-win: government grants pay the bills, easing pressure on both the customer and the provider. There are three key considerations for providers looking to increase the uptake of government supports by customers experiencing family violence: 

1. Providers should ensure specialist teams that work with customers to complete URG and Concession applications (hardship teams) are sufficiently resourced and available during normal business hours – a customer experiencing family violence should not have to wait for a callback to complete a URG.
2. Providers should actively promote applicable government entitlements to their customer base, e.g.. on bills, notices, websites, financial hardship policies, and call centre scripts.
3. Providers should track the utilisation of applicable government entitlements in their customer base and celebrate increases as a reflection that the help is reaching those who need it.

In Australia’s banking sector, customer care is shifting. Major banks now use advanced technology to detect vulnerability before it escalates: scanning transaction notes for abuse, flagging unusual activity, and making welfare checks when warning signs align (e.g. Buy-Now-Pay-Later debt, a string of missed payments). 

The household utility sector is a step behind the banks. Several factors contribute to this. For example, banks now operate in a more highly regulated environment, especially since the 2017 Royal Commission into Misconduct in the Banking, Superannuation and Financial Services Industry, which drives higher standards of consumer protection. There are also practical reasons: utility providers may not have the analytics capability of a major bank; the signals themselves are also more ambiguous, while a bank might spot abuse in a payment description, a sudden change in water or energy usage or a flurry of address changes could mean anything from a growing family to a leaky pipe.

That said, the principle remains: there is data available, and it can be used to protect customers experiencing family violence from harm, if providers are willing to look and the right processes are put in place. There are two practical considerations for utility providers looking to do this:

1. Providers can start to track customer data that could indicate family violence. If – when viewed from a multi-factorial perspective – the data indicates family violence harm is plausible, an outbound welfare check conducted by an appropriately trained staff member could be triggered.
2. Providers should ensure they have a formal process for staff members to escalate unusual matters (e.g. a strange call to the contact centre or suspicious field-based interaction) for consideration by a specialist. (e.g. the organisation’s risk lead) who can develop an appropriate response (e.g. an outbound welfare check). Without a formal process, these warning signs can slip through the cracks.

Six foundational organisational elements enable the specific actions required under the four practice areas to come together effectively in practice:   

1. Speed and urgency of action. When a customer experiencing family violence needs extra support, it is delivered urgently and without delay or lethargy.
2. Genuine engagement with lived experience. Product managers, policy and process owners, and service designers actively seek input from people with lived experience of family violence and see it as a pathway to better customer safety outcomes – not as a threat to their work.
3. Permission to use judgement. Practice guides and performance systems are shaped to encourage employees to use their judgement to protect customer safety in service interactions, rather than simply reward adherence to policy.
4. Shared responsibility across the organisation. Addressing family violence is not ringfenced in a single specialist or team. Instead, everyone – from frontline staff to managers – understands their role and responsibilities in supporting customers experiencing family violence.
5. Dedicated, well-connected resourcing. There is a visible, resourced team focused on family violence, with direct links to executive leadership. Investment in this area is structured for sustainability, ensuring the work is ongoing and not dependent on short-term projects or sporadic funding.
6. Governance architecture. The business has a principles-based Family Violence Policy, supported by a detailed Family Violence Standard that describes ‘what good looks like'. Policy and Standard ownership is clear, and division leaders are accountable for conducting their work in line with the Standard. 

The approach suggested in this article demands a lot from you. It asks you to:

• Design your services with regard to how they can inadvertently enable perpetrators of family violence.
• Step forward to protect the safety of customers experiencing family violence and facilitate their access to available supports, rather than waiting to be asked.
• Call out harm, suspected or real, when you see it, to disrupt and deter perpetrators of family violence.

These are big asks, for the organisation and for staff members alike, but the benefits are clear and the payoff is worth it. By strengthening your approach, you can help break cycles of harm and make your services a true source of safety and support for customers experiencing family violence.

Get in touch to discuss how your organisation can play a larger role in combating family and domestic violence.

Connect with Ashleigh Waldby, Marianna Brungs, and Gene van den Broek on LinkedIn.