Only a handful of large charities have the technological tools to comply with the Fundraising Preference, according to a consultation response from CRM software provider Blackbaud.
The FPS is a system which will in theory allow any donor to opt out of communications with all charities for up to two years. It was proposed in the Etherington Review of fundraising regulation, and will be set up shortly by the new Fundraising Regulator.
But John Bird, managing director of Blackbaud Europe, has written to the Fundraising Regulator to say that the FPS as currently envisaged is so complicated that charities will not be able to comply with it.
He said the FPS “represents a data processing challenge that resembles virtually no other process charities currently follow and few, if any, have the tools available to meet it”.
Bird said in his response https://www.blackbaud.co.uk/fps-consultation that the current process would use a different system to the Mail Preference Service and Telephone Preference Service, and would be much harder for charities to obey.
“It is my view that with the best will in the world, a combination of technical and logical barriers will prevent all but a small handful of organisations being able to fully screen their data against the FPS list, as the proposal currently stands,” he wrote.
He said the process of matching a donor against the FPS was far more complicated than TPS or MPS because it was not just a question of checking a number or address.
He said the FPS would also require charities to screen much more frequently than the TPS and MPS.
He said the FPS would cause problems if as few as one in every 200 people signed up.
“A data file of 250,000 contacts will not be small,” he said. “It will require IT expertise to understand how to move it and keep it secure – as will understanding of the formats suggested in the proposal.
“This is no small challenge for many charities, even of a medium size. Additionally, at some point, to screen against their own data, the data will need to be extracted and moved around within the organisation – where the benefits of the secure file format would be lost.
“However secure the file transfer format, ultimately large volumes of public information will be held and processed outside of this format in a large number of charities. This must be a concern for all involved.”
IoF: Reconsider or introduce in phases
The Institute of Fundraising, in its response to the consultation, called on the regulator to carry out an impact assessment to consider whether the FPS was still necessary. It said that if it was found necessary, it should be implemented in phases.
“We acknowledge the improvements to the FPS model that this paper introduces and welcome the engagement and opportunity to feedback on the proposals,” the IoF said.
“While proposals have been introduced to mitigate the ‘unintended consequences’ of the FPS, the model proposed will have the inevitable outcome that, by pressing the ‘total reset’ button individuals will not give to charities that would have been happy to support as they will not be directly asked.
“Now that discussions over ‘how’ an FPS could work have concluded, the changing context that has developed since it first proposed means that the need, value, and rationale for the service must now be reviewed before implementation and a proper impact assessment undertaken.
“If, following the review, it is felt that there is a need for the FPS then we propose a phased approach. The FPS should be brought in as outlined above, and an assessment then taken in due course to determine whether any further action or additional service, such as the ‘total reset’ is needed.
