After thinking and reading extensively about the proposed Fundraising Preference Service, Andrew Scadding says he doesn't think it can work in practice.

I read Joe Saxton’s excellent blog: Twenty challenges that the Fundraising Preference Service needs to cope with, and it prompted me to wonder whether the proposed FPS is feasible.

The issue of the Fundraising Preference Service has also been covered extensively by Civil Society News in both blogs and analyses, and is due to be debated this Friday at a summit on fundraising regulation.

There are three fundamental requirements the FPS needs to fulfil:

• Security. This will be the largest list of active donors ever compiled. Unlike the Mailing preference service or the Telephone Preference Service, joining this list will clearly indicate not only that an individual does not wish to be contacted, but by whom (charities) and therefore why (because as known donors they get too many asks). Can these names and addresses be handed over to us, the rogues and felons of the fundraising fraternity?  Any breach of confidentiality would be fatal to the FPS.
• Responsiveness. A donor or prospective donor who signs up to the FPS should begin to see a reduction in incoming mailings reasonably promptly.
• Timeliness. Files submitted for matching must be returned promptly, appropriately flagged.

Foreseeable problems in reconciling these requirements arise from the volume of data to be processed and the quality of the data involved. The key here is that FPS will need to match warm donor files extracted from charities’ own databases. It will not, like MPS, be suppressing cold, usually bureau-maintained files.

Accepting Joe Saxton’s figure of 10,000 charities spending more than £100,000 p.a. on fundraising (although it represents only about two thirds of charities with income of more than £1m, and I know some charities in the £500k to £1m bracket who would qualify, so it is conservative) and assuming an equally conservative four donor mailings per charity per year, we have potentially 40,000 file comparisons to be made just for donor mailings, or 110 every day (not every working day!) if every mailing by every charity is to be fully checked.

Given that security is an existential risk for FPS, I believe that these processing operations must be carried out either by FPS itself or by accredited bureaux. This will have cost implications for charities, but more important it will limit capacity especially at peak times like Christmas and Easter.  Nobody wants their Christmas mailing to drop on January 10th so there will be real challenges for the bureaux in turning lists around promptly.

As Joe Saxton points out, this will only be possible if files presented meet basic quality standards, which will take some work in many cases. There is the promise of a huge bonanza for software companies writing procedures to produce match files in the standard FPS format. And as Joe also points out, there are all sorts of issues with even well-maintained data.  At least at first, this will slow the pace. Some of those files will be trivial and match in minutes, but others will be huge and take time. With an average 110 files per day to process, time will be short, and every hold-up will have consequences.

An obvious way of limiting the pressure of volume would be to require charities to match their files only once or twice each year. But this would result in people joining the file potentially continuing to receive mailings for up to twelve months - not an assured path to customer satisfaction.
It is almost twenty years since I had a close involvement with data processing, and things have moved on a lot in that time. But the volume of data to be processed by an FPS, the security requirements, and the need to satisfy customers (both charities and donors) by providing a timely response seem to me to present interesting challenges which will not be cheap to meet, if indeed they can be met at all.

I am concerned that these questions are not being asked by the sector’s leadership. Obviously NCVO are hardly likely to question Sir Stuart’s recommendations, but I had hoped for better from the Institute.  We should know whether any feasibility study has been undertaken, and we should be examining in detail how the FPS is expected to work. 

If we do not ensure that the proposed service is practicable, we run the risk of having imposed upon us expectations and requirements which are impossible to meet. The result of that will be further discredit to fundraising. 

This so-called service needs to be challenged now. Once legislation is in place it will be our problem to solve, not Rob Wilson’s or even Sir Stuart Etherington’s.

Andrew Scadding is chief executive of the Thai Children's Trust.