Three regulators involved in concerns about Captain Tom Foundation last year

08 Feb 2022 News

Captain Tom Moore

The Fundraising Regulator, Charity Commission and Information Commissioner's Office (ICO) all looked at concerns regarding the Captain Tom Foundation last year.

The Foundation’s annual accounts for May 2020-21, published this week, said that the Fundraising Regulator identified “a number of issues of concern” with its website, and that the ICO had received complaints over allegations that GDPR rules had been breached.

The Fundraising Regulator said that the Charity Commission had also been involved in work to help develop the charity's governance and fundraising structures.

Stephen Jones, the chair of trustees at the Foundation, told Civil Society News that the charity had worked closely with regulators to resolve these issues, and that it had not received any fines or formal warnings.

The financial accounts show that the Captain Tom Foundation paid more than £50,000 to two business run by Hannah Ingram-Moore, Captain Tom’s daughter, and her husband Colin Ingram-Moore. He is a trustee at the charity, while she was a trustee between February and March 2021. 


The financial report said: “During this period we received two complaints that were made to the ICO in respect of a GDPR breach, and furthermore The Fundraising Regulator identified a number of issues of concern on our website. 

“We have positively engaged with both regulatory bodies and all matters have been satisfactorily resolved. 

“We consider the Fundraising Code in all our activities to ensure that our fundraising continues to be legal, open, honest and respectful.”

Jones said that the charity was still in touch with the ICO and Fundraising Regulator. “They want us to get things right. They are very, very supportive”, he said.

The Fundraising Regulator said it “has worked alongside both the Charity Commission for England and Wales and also the ICO to support the Captain Tom Foundation to develop the fundraising and governance of its organisation.

“As a newly-established and high profile charity, we advised the Foundation of its regulatory obligations when it comes to fundraising so that the public’s confidence and trust in donating to charity is protected. In particular, we advised the Foundation to make sure that the statements on its website about its fundraising accurately described its activity.

“The Foundation was forthcoming and we are satisfied that our initial concerns have been satisfactorily resolved.” 

An ICO spokesperson said: “We can confirm we received complaints in relation to the Captain Tom Foundation.

“After meeting with the charity, we provided advice on data protection and direct marketing rules, and decided no further action was needed. The case has been closed.”

The charity was set up to continue the fundraising started by Captain Tom Moore after he captured the public’s hearts during the first national lockdown, raising more than £30m for NHS charities by walking laps around his garden. When he passed away in February 2021, the Chartered Institute of Fundraising praised his “legacy of inspirational fundraising”.

Questions about gin

In 2020, Civil Society News reported that the Captain Tom Foundation had refused to make public any details of a commercial partnership with Otterbeck Distillery, which pledged to make donations to the charity based on its exclusive right to sell Captain Tom-branded gin.

The charity and the firm has always refused to say what proportion or total from these sales will go to the Foundation. Charity Commission regulations on working with private firms state that voluntary organisations should make clear “how the funds raised will be distributed between the charity and the commercial partner”.

Otterbeck Distillery referred all queries to the charity. Jones declined to say how much money the Captain Tom Foundation had raised through this and other commercial partnerships, but confirmed that the proceeds were included as “a small part” of its fundraising income in 2020-21.

Jones added that the charity “has been very fortunate in that we have received lots of support from the public and private companies” in what he described as a “challenging first year”.

Payments to family companies

The accounts show that the Captain Tom Foundation reimbursed £16,097 to Club Nook Limited, a firm where Hannah and Colin Ingram-Moore are both directors, for “accommodation, security and transport” when Captain Tom travelled to promote the charity.

Another £37,942 was paid to Maytrix Group Limited, a company jointly controlled by Hannah and Colin Ingram-Moore, for communications, photography, office rental and “third-party consultancy costs”. The accounts say that these costs were initially covered by Maytrix Group and then claimed back by the firm “when sufficient funds were available” from the Foundation.

Over £1m raised

The Captain Tom Foundation had an income of just under £1.1m, according to the accounts, nearly all of which came from donations and legacies. In the same period it made four grants, each worth £40,000, to the charities it was established to support: Willen Hospice, Mind, the Royal British Legion, and Helen and Douglas House.

The accounts list a number of further, discretionary grants made after May 2021, to six more charities including The Florence Nightingale Hospice, Place2Be, and the Young Minds Trust.

The Captain Tom Foundation spent around £400,000 on fundraising and outreach projects last year. The accounts said: “As a newly established charity, expenditure has been incurred in building the team, which for some months worked on a voluntary basis until funds were forthcoming.

“During this period, we also incurred costs in appointing The Philanthropy Company who provided expert support on governance and fundraising initiatives as well as working with our charity partners to identify initiatives that the Foundation could support and which would drive value and public benefit.”

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