Adrian Sargeant has read the consultation document on how the Fundraising Preference Service might operate. He’s found quite a bit wrong with it.
The working group on the new Fundraising Preference Service (FPS) has now published a discussion paper on how best to implement the service and the issues that must be addressed.
It is interesting to note in the opening paragraph that they claim that the FPS has now been “accepted” by the sector when in reality only a tiny minority see it as a desirable step. Indeed it has been imposed with no consultation whatsoever and without anyone analysing the likely costs of the scheme or its impact on giving in the United Kingdom.
As I’ve written elsewhere if the scheme is implemented it will be deemed appropriate for the first time in this country for an individual to say ‘never talk to me again about need in my community or around the world’. No matter what disaster unfolds on their doorstep it will be unlawful to make an approach. We also face the interesting prospect of ministers actively promoting the FPS so they can be seen to have had an impact. The government will effectively be encouraging individuals to press ‘reset’ on their philanthropy – as though it was a bad thing, and something they should regret.
Philanthropy is a deep articulation of one’s love for others. That we would now be actively encouraging folks to abstain from it deeply sickens me.
Why should it be harder to ask someone to save or enrich a life than to ask them to buy insurance or a packet of soap powder?
I would encourage the new regulator to think very carefully about the implications of the FPS for philanthropy in this country and to ask the minister to give them time to do their job and implement a new code. In my judgement this may well be enough to curb the excesses that were highlighted last summer and allow us to hit the joint goals of improving the quality of fundraising practice while maintaining the current level of philanthropy available to serve need in this country
If we continue down the route of creating an FPS the very vulnerable people we were intending to protect will find their services cut and their quality of life suffering as some 20 per cent is wiped off the income attracting to the sector because of this and other initiatives.
The FPS will also be difficult and time consuming to implement and whatever is eventually decided on will inevitably be flawed as it isn’t practical to single out a single sector of society for attention in this way.
My thoughts on the minutiae are as follows:
- The FPS would deprive existing donors of communications we know they enjoy, derive value from and enhance their experience of philanthropy. The scheme is so complex that many individuals will not realise what they are opting out from. Remember the suggested move from opt-out to opt-in is being prompted because it is argued that folks don’t understand what they are signing up to. This scheme is a good deal more complicated than a simple opt-in or -out and will inevitably lead to public confusion and concern.
- We also know from research that people generally don’t have a good understanding of what a charity is, or what categories of organisation might be included. If I hit reset believing I don’t want to hear from ‘charities’ anymore, I probably won’t realise that I will no longer receive appeals from my alma mater, my son’s school, my local hospital, a faith-based group or the art galleries or museums that I love to attend.
- It is also very unclear how the scheme could possibly apply to membership scenarios. Many might not see their membership as a donation, yet under the proposals that would be reset too. Indeed, how does one distinguish meaningfully between a ‘membership’ scenarios and other forms of voluntary and particularly monthly giving?
- The authors also don’t address what exactly is meant by a fundraising ask. If I include a story of how someone’s legacy has magically transformed some area of our work in a newsletter, is that a fundraising solicitation and caught by the FPS, or does it only become so when I dare to ask you to call or email for further information? If I tell you stories of the work that a fundraising volunteer has conducted in the community and how you might help her hit her total, is that a fundraising ask?
- It’s also an utter disgrace that this committee is genuinely concerned by the minutiae of whether a thank-you might be interpreted as an ask for support – calling on readers to suggest how they could be clear on this issue. Is this really the level we’ve sunk to? That a regulator would read the text of my thank-you and determine whether my intention was really to encourage you to give again?
- More fundamentally, the scheme as proposed would seem to have some monumental data management challenges. If I hit reset that must quickly be communicated to every charity in the country (with a turnover of over 1 million), so that if that individual is giving, fundraising communication will terminate. But if that individual then calls them or sends in a cheque their ‘new’ wishes would then over-ride the original ‘reset.’ So charities would also need to store the date of relevant actions and process the difference between the dates when doing their selections.
- What happens too, if I decide I made a mistake and choose to cancel my membership of the FPS. How would charities be made aware of that – and what implications would there be for subsequent communication?
- Indeed, why is the working group not consulting on whether the FPS should be time limited? Why is that off the table completely?
- Consider too, the implications for small charities. If my organization routinely brings in around £900,000 a year in voluntary contributions, what would happen if we crossed the working group’s arbitrary boundary and raised a little over £1 million? Would we then have to run our dataset against the FPS and omit donors who had signed up previously to the reset? If we would, how would donors be made aware that that had happened? One presumes they would have signed the FPS believing that their relationship with their local hospice would be protected. Remember, legacy income can make voluntary income vacillate quite considerably from one year to the next, so this will become an issue. Many will find themselves in one year, out the next and so forth.
- The final issue that concerns me is the security of this data. Running a file against the TPS or MPS is easy, but the FPS would need to be fluid. It is easy to see how this might be hacked with the resultant impact on public trust and confidence.
Fundamentally, I call on Sir Stuart Etherington and others associated with this initiative to reflect on what the FPS would achieve that a newly constituted regulator and widespread promotion of the TPS and MPS would not achieve. Is that incremental gain really worth the cost to the sector and our wider society of rushing ahead with the FPS. Have they costed the thousands of man-hours that individual charities and the regulator will need to invest to make any of this work?
Somehow I suspect not and that fact needs to be conveyed to the minister in the strongest possible terms.
- Professor Adrian Sargeant is the director of the Centre for Sustainable Philanthropy and Plymouth University.