Yesterday the Fundraising Standards Board (FRSB) published its interim report into fundraising practices following the death of Olive Cooke.

It has made eight key recommendations. They are:

1. Frequency of approaches

Overall, the Board feels that the sector must take steps to ensure that the public who support charities are given more control over how often and in what ways a charity communicates with them.

Specifically on the subject of frequency of contact, the Board recommends that the IoF amend the Code to
specify the maximum amount of times that a charity can contact an individual per year.

2. Opt-outs

The Board recommends that the IoF Code stipulates that “opt outs” must be made available in all marketing communications, be clearly presented and simply worded.

3. Elderly and vulnerable people

The Board recommends that the IoF must review how charities currently communicate with older supporters and how those communications could be tailored to better reflect the needs of the audience.

4. Use of scripts by telephone fundraisers

The Board believes that industry practice of making three donation requests during the course of a call could constitute “pressure” and not “reasonable persuasion”. Therefore, it recommends that the IoF considers stipulating how many times a fundraiser can request a donation during one individual approach.

The Board recommends that the IoF considers including a stipulation in the Code that charities must regularly monitor the content and tone of telephone pitches that are being made on their behalf; either through a regular review of call recordings or through mystery shopping.

Finally, the Board recommends that the IoF should remove the reference to “reasonable persuasion” in clause 1.3 (b). The Code should be clear that it is never acceptable to pressurise the public into giving.

5. Data sharing between charities and external data agencies

The Board recommends that the IoF make it a requirement of the Code that organisations engaging in data sharing must, at first point of contact, make it clear to donors that their personal contact information may be shared.

Furthermore, Section 7.2 (a) of the Code merely states that fundraisers must observe provisions of the Data Protection Act on data sharing but does not provide the specific provision. It is the FRSB’s view that the provision should be included in order to ensure greater compliance with it.

6. Effectiveness of mail and telephone preference services

The Board recommends that the IoF strengthen compliance with the Telephone Preference Service. The IoF Code does not reflect the view of the Information Commissioner’s Office that TPS registered supporters must not be contacted by telephone unless they have given clear permission to receive calls.

The Information Commissioners Office (ICO) have confirmed that it is not sufficient to assume that a TPS registered supporter has given consent to receive calls simply due to the fact that they have made a donation.

Based on the complaints so far received about the Mail Preference Service, the FRSB feels it is clear that the service is not working the way that people expect it to and encourages the IoF to look into this particular issue as part of its review.

7. Enclosures in direct mail

In keeping with the Code, the Board believes charities must be more mindful of whether or not a recipient may feel pressurised as a consequence of receiving an enclosure.

8. Additional comment

The Board believes that compliance with the IoF Code could be further strengthened by making all clauses in the Code 'must' requirements. It feels that the use of the term 'ought' has the potential to undermine the importance of complying with those clauses by suggesting that they are optional. That view has also been articulated by a number of complainants contacting the FRSB over recent weeks.
Taking this important step would strengthen the message that fundraising organisations across the UK must comply with the Code in its entirety.

The full report is available here. 

More analysis and reaction to follow. Please get in touch on 020 7819 1200 if you work in the charity fundraising sector and you are interested in making a comment.