Charity representative bodies have said they are broadly supportive of the Fundraising Regulator's proposed changes to the Code of Fundraising Practice, but have called for the sector to be given time to adjust.
NCVO, the Directory of Social Change, and the Institute of Fundraising have all agreed in principle with the proposed changes put forward by the Fundraising Regulator, but have all called for the sector to be given time to acclimatise to the changes.
All three groups have also welcomed the regulator’s proposals to further digitise the Code of Fundraising Practice.
This most recent consultation on changes to the Code of Fundraising Practice was opened on 7 September and closed last Friday, 16 of November. A spokeswoman for the Fundraising Regulator said that the consultation had received "over 100 responses" and that the regulator had "met with organisations and fundraisers across the UK".
Douglas Dowell, senior policy officer at NCVO, said the organisation was “in favour of a simpler, clearer and more consistent code” and called the proposed glossary of key terms “welcome”, although he said more could be done to highlight it within the code.
NCVO said: “There has been a good deal of regulatory change affecting fundraising over the past couple of years, and even more in recent months due to the impact of GDPR. Fundraisers should therefore be allowed a sufficient period of time to adjust before moving to the new code, especially to give them time to update training materials and internal policies which currently reference or are designed to be used with the existing code.”
It also called for a “further round of consultation” if the final version of the code is “significantly different from the current draft”.
Daniel Ferrell-Schweppenstedde, policy and public affairs manager at the DSC, said that “overall, the revised code contains many improvements that make it a clearer, more accessible document” but warned that it was still “lengthy” and that more work could be do to make the document more accessible and clear.
“Accessibility and clarity is especially important for smaller charities and voluntary organisations, as well as people who are doing fundraising but don’t necessarily identify as ‘fundraisers’. Further, seemingly minor changes to text may lead to confusion, and the FR needs to bear this in mind when rolling out the new version and in future investigations.”
DSC also called for the regulator to adopt a three-month implementation phase of the new code, to “ensure a smooth roll-out” and, “for a certain time” should “ask the question whether a particular breach of the Code or behaviour could be also a result of the changes implemented.”
The IoF said plain English review of the wording in the code was “a positive change” and would “improve the code’s accessibility”. It also welcomed the incorporation of the rulebooks and a glossary of terms.
However it said it would like the Fundraising Regulator to “continue to engage” with it on the topic of making the code a predominantly digital resource in the future.
“We acknowledge that for experienced fundraisers and those used to the current code, making large changes to the format and amending the style and structure will take some time to get used to. It will also mean that charities need to adjust policies, processes, training materials and compliance procedures to respond to a new version of the code – as such the communication and implementation of changes needs to be carefully considered.”
The Fundraising Regulator put forward its proposed changes to the Code of Fundraising Practice on 7 September, and said it was aiming to make the code easier to use and understand, as well as more easily accessible for members of the public.
It said at the time that this consultation would focus on “the style, presentation, clarity and accessibility of the” document, while not making any “fundamental changes to the standards within the code”.
The regulator proposed a new table of contents, glossary of key terms and “simpler ordering” of the code’s content; a review of the language used in the code and making it “plain English”; adding a new introduction to the code and incorporation of the old PFRA’s face-to-face fundraising rulebooks into the body of the code proper.
In terms of “plain English” the regulator proposes that the code use a “direct form of address” i.e. “’You’ must rather than ‘the organisation’ or ‘the fundraiser’ must” and have said the code should avoid jargon “where possible” and instead substitute in “simpler alternatives for some words” and use “active rather than passive verbs where possible”.
It has also proposed combining the 20 sections of the code; 14 legal appendices and the three face-to-face rulebooks into three sections called “General Rules”; “Working with Others” and “Fundraising Methods”.
A table of old rules have also been proposed for either complete deletion or amendments; including those of “limited relevance to fundraising specifically” such as paying trustees; those rules that are not “widely applicable” or those which only apply in limited circumstances or repeat “in detail” those regulations set up by other regulators.
A spokeswoman for the regulator said: "The levels of participation in this consultation have been hugely encouraging. We’ve received over 100 responses and have met with organisations and fundraisers across the UK. We now need to carefully consider everything we have heard during the consultation period.
“It is important that the Code of Fundraising Practice is a tool that fundraisers and organisations can use confidently to create a positive donor experience and the feedback we have received will help to ensure that it is. We’d like to thank everyone who has contributed to this important conversation.”