Fundraising Preference Service discussion paper - what do we think?
We should recognise that the Working Group have set this out as ‘top-line thinking’ with thoughts, ideas, propositions on the scope of an FPS. This is not a consultation on a detailed and complete model.
But the propositions are important as they will guide what an FPS may end up looking at. Saying that, whatever the next steps taken are, it will be essential that a wide and full consultation takes place to review and assess its potential impact.
What about the propositions?
- While we recognise that the Working Group has been tasked with looking at an implementation model for including a ‘total reset’, our concerns remain about what this will mean in practice, particularly in relation to overriding specific and informed consent that individuals have given to charities that they want to hear from.
- We support the proposition that the FPS should apply to ‘fundraising communications’ but not wider charitable communications. The FPS must guard against the unintended consequences for individuals of completely cutting people off from charities they have supported in the past. It is right that individuals are still able to hear about the important causes they care about while also having the reassurance that they will not be overwhelmed by fundraising asks
- Embedding donor choice in an FPS is absolutely fundamental. Individuals must be able to choose the particular channels through which they do not want to receive fundraising (mail, telephone, email). Without this, the FPS will be a blunt tool that will fail to provide genuine choice to people.
- Individuals must also be given the choice to remain ‘opted-in’ to ‘charities that they currently support or have supported in the past’ without the individual needing to specifically name those charities. Many donors will want to continue hearing from, and donating to, charities that they support (for example, in response to a Christmas appeal) but may be unable to recall the names of those charities at the time of registration on an FPS. This addition would also make for a far simpler and user-friendly experience for an individual through the FPS as they could choose to select an option which serves their needs without needing to find and select the names of multiple charities.
- The IoF strongly believes that the needs of individuals who lack capacity or are in a vulnerable circumstance must be appropriately met and acted on. The safeguarding for individuals in need should be the number one priority for the FPS and it is absolutely critical that this is achieved. We therefore support and endorse the proposition to separate the needs of individuals in vulnerable circumstances, or those lacking capacity, from a wider ‘communication preference’ service. However, there are some fundamentally important issues that need further thought in this area: We urge the FPS to avoid categorisations and definitions relating to vulnerability that may be discriminatory and exclusionary and believe that a great deal of thought must go into the potential registration of individuals by third parties (for example, a family member, friend, carer).
The Working Group has a huge amount of detail to work through as they listen to feedback and comments on their thinking and propositions. More conversations and consultation will be needed, and must take place, with the sector and beyond. We understand that there may well desire to see things changing quickly and swift actions taken. However, the importance for charities, donors, and beneficiaries in the UK and across the world demands that the necessary time is taken to get this right.
Take a look at our response to the FPS discussion paper