CAS welcomes the Consumer Duty consultation paper. We believe that, in principle, Scottish public bodies should have an embedded duty to consider the impact that decisions related to policy, and adopted practice could, and does, have on those engaging in its services, particularly vulnerable consumers. Scotland’s Citizens Advice network regularly deals with clients who are impacted by a lack of regard to consumer outcomes or who fall victim to poor service design.
We believe that a consumer duty will strengthen consumer protection from unintended consequences resulting from public authority decision-making. It is essential that a consumer duty results in meaningful improvements in the consumer journey and achieves positive outcomes for public authority service users.