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Adam Rothwell
- Wednesday, January 30, 2008
OH DEAR. The Fundraising Standards Board (FRSB), set up last year to police how charities raise cash, has failed its first test. We're not surprised. But we are disappointed.The FRSB's aim is to help you 'give with confidence.' To this end, the Board asks its members - which include most of the country's big charities - to sign up to the Fundraising Promise (PDF, 50K), which guarantees certain ethical standards. If you spot a charity breaking the rules, then you can complain to the FRSB. It can, in turn, impose a narrow range of piffling sanctions if it finds a charity guilty - which, as we've said before, isn't ideal, but is certainly better than nothing. We think that the FRSB is a good idea in principle. But in its first adjudication on a complaint, it has made the wrong decision. Asked to judge whether it was reasonable for Cancer Research UK to send a bemused gentleman thirteen pens over a period of two years, it decided that such behaviour was perfectly legitimate. Even the fact that the gentleman in question received four such pens in one day apparently did little to sway the FRSB's judgement. We are at a loss to comprehend the Board's reasoning. In its adjudication, it states: "whilst accepting that the complainant had grounds for being annoyed, the receipt of this number of mailings ... did not amount to unreasonable nuisance or disruption and neither did it indicate that Cancer Research UK is not committed to high standards." "Who judges what is unreasonable?"The key point here is who judges what is "unreasonable nuisance." We think it should be donors - within reason - who decide. They are, after all, the ones being targeted; they know how it feels. But the FRSB apparently disagrees. Its judgement - which is based in part on the astonishingly irrelevant fact that CRUK might not have sent similar numbers of pens to other people in the same area - is all that counts. And who in the FRSB makes that judgement? Unsurprisingly, it turns out to be a group of charity types and direct-marketing people. We hope that the FRSB will show greater concern for donors' wishes in future. Unsolicited gifts are only slightly worse than unsolicited mailings. As an example several years ago my wife and I made a donation to a charity on behalf of my father-in-law who had died. We said this was a one-off, and was made because he would want to support the charity, (and it was not one we had any particular intention of supporting). But once we were on their mailing list, it was nigh on impossible to get off it despite writing on many occasions. This is the sort of thing that gets charities a bad name, and I have named this charity to friends and family ever since, as one NOT to support because of their inefficiency and incompetence. It would be very useful indeed if IG had icons indicating whether or not a charity sends out unsolicited mailings, whether or not they dish out 'gifts' of any sort (there's no such thing as a 'free' gift), and whether or not a charity indulges in chugging. All very relevant to giving intelligently..... And I could envusage some very entertaining icons.... I'm not sure how 'normal' it is. But that's what IG (and others) should be getting worked up about if transparency is truly their prime concern..... And it's not just misrepresenting fundraising costs, there's far worse that goes on below the radar. rspcacambridge: I personally don't disagree with you about pens. But if incentivised mailing packs are not working for a particular organisation then all they have to do is stop mailing them. If donors don't like it then all they have to do is ignore them and stop giving..... Do we really need regulators to metaphorically hold our hands, look after us and tell us what's best? It's seriously depressing. Don't shoot the messenger Don't almost all charities use dubious figures to make themselves look more appealing to donors? For example 1p in every pound raised is spent on fundraising & admin (yeah right!) or every pound we raise could be spent (so could means maybe it will, maybe it won't!). My problem with the unsolicited pens is that donors treat ME as a potential pen-monger! I have no worries about things that really are incentives that the donor can choose or not - for example different types of membership with or without a glossy magazine. What's wrong with unsolicited items is the way they try to trade on people's guilt about not paying for the "gift" which leaves potential donors thinking charity fundraisers are basically dishonest. That then feeds into the belief that we're all paying ourselves enormous fees and expenses as "admin costs". And whilst we worry about who sent which plastic promotional novelty (and how many of them).... There are charities out there wilfully misleading the public, lying to donors and exagerating the impact of their work. It's all a matter of priorities I guess.
Don't shoot the messenger OK, maybe people don't like gifts. But in the nicest possible way, 'so what'. If you don't like it don't respond to it. If peole stop donating off the back of 'incentivised' (urghhh!) mail packs then charities will either adjust their practice or give way to others who are more responsive to public demand. Businesses regularly send unsolicited 'junk' out and I don't see the private sector ringing their hands and beating themselves up about it. My point is that it may well be bad practice, it may well be wasteful, but there's no lack of transparency. CRUK weren't sending out pens under the pretence that they came from somewhere else, or wilfully lying about the costs of their fundraising or the impact of work. They were doing something that some people might disapprove of. That's all. Why the need for this constant naval gazing and (self) regulation?
Don't shoot the messenger
It's fair enough to make the point about the phrasing of the question. The survey notes on the same page that: - 70% of FRSB respondents and 69% of CAM respondents think charities put gifts in to make people feel guilty about getting something for nothing. - 16% of FRSB respondents and 29% of CAM respondents think putting gifts in direct mail as an incentive to give is acceptable. That doesn't sound like a popular method of fundraising. Whatever the whys and wherefores of the debate on gifts in mailings, in this case one person received 13 pens from a charity over a relatively short stretch of time. Whether or not they were addressed or unaddressed or whether it was the postman's fault seems to me pretty much irrelevant. The pens arrived on one person's doormat, and they came from the charity. IG have simply pointed out that the basic facts of this particular situation seem to have been ignored, and also suggests that if self-regulation is going to be seen as transparent and effective, that donors should have more input to the process. OK, I found the survey - available to download from http://www.nfpsynergy.net/freereports/ (free registration required). And, as I expected, the actual wording says something completely different from how you've put it. The actual statement which 93% of existing charity donors (who cared enough to respond to the survey) agreed with was, "Money spent on putting gifts in direct mail might be better spent on the cause". Let's start by taking notice of that "might", which you've conveniently ignored - of course it "might", but that doesn't mean it should. But more importantly, what's any of this got to do with pens? If I'd been answering that questions, I'd probably also have answered yes, because I wouldn't have made the connection to pens at all. I've never thought that when I got a pen in the post, it was intended as a "gift". Some cheap, crappy biro - what sort of gift is that? No wonder you're calling it "junk" if you're thinking of it that way. I've always assumed that the idea of a pen was so that I had something to hand to fill in the direct debit form - I'd never realised that I was supposed to think of it as a present! When you look at another stat from that survey, which was that only 1 in 5 of the FRSB respondents claimed to have received direct mail containing a "gift", it seems like I'm not alone. Pen does not equal gift. I'm sure you're right about the majority of people not liking incentives/gifts/junk (call them what you will). But I also agree with Simon with regards to the inherent bias that creeps into market research - especially in contencious areas such as public opinion on charity fundraising, The trouble with creating such a stark (and false) dichotomy as pens versus valid charitable work is that it completely misses the point. As you well know, one funds the other. It isn't a matter of preferring fundraising activities over dying children/homeless greyhounds/ impoverished african communities etc. By extending the same argument you could make the case for sacking all professional fundraisers/ marketeers and depending entirely on the good will of people with a bit of time on their hands. All very worthy but the dying children, homeless greyhounds and imporverished african communities would ultimately suffer. My attitude to direct mail is that bad practice will be it's own penalty in the end. Charities that perfom badly and irritate the donating public will be forced to change their ways or lose out to 'better' organisations. If IG focuses on forcing charities to be open, honest and transparent then the public can make better informed decisions when they chose who to donate to. That, I thought, was your sole remit and it's a very worthy one.
Don't shoot the messenger Adam, do you have a link to that research that says "93% of people think charities should spend their cash on charitable activities instead of pens"? It strikes me as a classic example of survey data being led by how the question is phrased. If you ask people, "Do you think charities should spend money on charitable activities or on sending pens to potential supporters?" then you're highly likely to get a 93% response one way. But if instead the question was something like, "Research has consistently shown that including pens in direct marketing appeals will greatly increase response rates, meaning that charities can spend less on fundraising and more on their charitable activities. Do you think they are justified in doing this?", then you'll get very different figures. I'm not suggesting either of the wordings above is better - I'm just saying that loaded questions will get loaded answers, and without seeing the original survey, quoting the figure of 93% is meaningless. Hi Ginsters, OK, it's a fair cop: maybe using the word 'junk' to describe the 'gifts' charities send wasn't the best of ideas. However, I would hazard that the vast majority of people would have no problem with my phrasing. As the FRSB's own research has shown, 93% of people think charities should spend their cash on charitable activities instead of pens. So whilst perhaps I shouldn't have called them 'junk,' I think many people would. Adam, Intelligent Giving Adam , I thought your remit was confined to promoting transparency within the charitable sector.... By describing DM incentives as 'junk', you're clearly expressing a personal opinion. It makes any investigation that you undertake open to suggestions of bias from the outset.
Don't shoot the messenger Those are all good questions, Charity Chris, and it would indeed be interesting to see CR-UK's response to them. Not that I want to put words into their mouth, of course, but I also recently came across the following study which shows, apparently, that the inclusion of 'gifts' really does increase response rates significantly: http://opus.zbw-kiel.de/volltexte/2005/3439/pdf/cesifo1_wp1218.pdf
The study, though, unfortunately doesn't reveal how many people were put off giving by receiving such junk through the post. Adam, Intelligent Giving.
The FRSB promise is written in pretty tame language - for me, it's not really a great surprise that the first ruling should have gone this way. For example, the complaint in this case seemed to be more that the methods being employed appeared, on the sight of it, to be wasteful, which doesn't really seem to have been addressed. Perhaps that is because, under the promise, that simply isn't in the FRSB's remit. That' s a shame in some ways, and self-regulation, particularly as is pointed out in the article, by 'charity types' could very well be seen as too cosy. However, the fundraising promise does state that: "We answer all reasonable questions about our fundraising activities and costs". Whilst that is still open to debate (after all, what is or is not a reasonable question?), perhaps IG could put a number of questions to Cancer Research UK, for example: How much do you spend on pens each year? Whether or not the questions are asked, I will be interested to see what happens in future adjudications.
Why bother setting up the FRSB at all? Couldn't extra resources simply be given to the IoF to deal with complaints about breaches of its own guidelines? That would save the expense of running two organisations with two sets of overheads and it wouldn't be any less independent because the FRSB is a self regulatory model in any case.
Don't shoot the messenger I quite like them - the gifts that is. Saved me a fortune over the years in pens and address labels. Never had an umbrella from a charity yet but willing to accept one (or more). Gifts don't cause me to be more willing to support a charity. Neither do they make me less willing. I have a short list of charities that I'm willing to support because I believe in their cause and I like what results they generate. Martin Whilst I can understand the frustration of many about the use of incentives and the apparent inability of the FRSB to uphold the feelings of the average donor, we should consider the fact that the FRSB is only able to oversee complaints that break the IoF Codes of Practise. The question I would ask is why the IoF does not currently have a specific code on direct mail which forced the FRSB to judge the complaint on their Donor Promise? Face to face, payroll giving, events, corporate fundraising, the list of IoF codes goes on, yet the form of fundraising that tops most lists of hated forms of fundraising is currently being debated to go out shortly for consultation. Maybe that would be a more appropriate forum to feedback your thoughts. Anon SimonK seems to quite miss the point. One pen through my letterbox is enough. I will never support charities that send me ANY unsolicited 'gifts' -- pens, umbrellas or anything else. This is because being a charity worker myself I understand the economics of the process, and the motivation. And I do not agree with it. If the FRSB had any teeth, they would suggest it is totally abandoned as a practice. It is not a good use of a charity's funds. I have always been amazed it's actually legal, Giving unwanted gifts (however modest) to non beneficiaries of the charity seems to go against the spirit of charity law, if not the letter. I've fairly recently done some "digging" into this after a mailing from the British Heart Foundation, addressed "To Occupier". (No pen, just a postcard of a very cute baby [mentally deletes any number of funny but potentially offensive remarks]). Anyway, as I've been on the Mailing Preference Service for nearly five years, signed up to the Post Office "opt out of unaddressed mail" service for over a year, and *always* tick the "No, I don't want to speak to you ever again" and "Don't you dare sell my details" boxes on forms, I decided to investigate why I should have had this unsolicited mailing. (NB did the recipient of 'excessive' CRUK mailings sign up to either of these? I suspect not - and suggest that he be advised to do so, to save his blood pressure.). Let me be fair here and give kudos to BHF, for prompt responses to my enquiries - which were enquiries as a prelude to a possible complaint rather than an immediate complaint. Sadly they couldn't help me because the mailing went straight into the recycling, which meant I didn't have the reference number on it. Lesson: if you want to complain about a mailing, don't just keep the pen as evidence (if you have one), keep the whole lot (the adjudication did say that the complainant may have recieved cold mailings addressed to him as well as the unaddressed ones). So I did my own research. Two things: 1) "The opt out service only relates to unaddressed mail. Royal Mail is still legally obliged to deliver all addressed mail, which includes mail that is addressed “To the Occupier” (or with any other generic recipient information), as well as mail that is personally addressed to you by name." (source). 2) Any other delivery organisation - TNT, DHL, etc etc etc does not, apparently, have any opt-out service. Hmmm, typing this reminds me that I queried this with some 'body' so long ago that I can't remember whether it was one of these delivery companies or the Direct Marketing Association - must follow up. Summary: basically, if any organisation wants to send you stuff, they will get it through your door somehow. As quite reasonably pointed out, the error could have been in the delivery (postman shoving multiple envelopes in the same door). Probably impossible to prove without the reference numbers - lesson refers. Given that the "chain of evidence" is impossible to establish, I don't see how the FRSB could have made any other judgement. Which kinda confirms my opinion that it's a bit of a toothless waste of space really. (NB: Emphasis on opinion. Mine. May or may not be altered subject to other evidence offered/personal experience. All rights reserved, etc.) ----------------------------------------------- ... nearly Vlad the Impaler Gosh, I hate pens! They just cause SO much aggravation for those of us who meet the folks who get them but aren't the kind of people to send back a written complaint to the senders. I'm convinced they're a significant factor in creating the idea that charities are wasteful. The odd thing is that the FRSB commissioned report by npfsynergy on direct mail seems to say exactly this: "gifts" enclosed with mailings just put people off because they're resented as an attempt at emotional blackmail. http://www.nfpsynergy.net/freereports/ (registration required) I would guess that the reason why they didn't give Cancer Research UK a slap on the wrist was not so much an endorsement of "pens in mailings" as a feeling that there was no evidence that they were sending out ridiculous numbers of the things as a general policy. Hi Simon, You’ll be pleased to hear that I have indeed read the FRSB’s adjudication; and I can confirm that the blog entry above is certainly not a knee-jerk response to our ‘dislike for the FRSB.’ In response to your point about some of the pens being sent outside the claimed two-year time period, I would argue that this isn’t really relevant. Whenever precisely the offending instruments were sent, it remains the case that this gentleman received a large number of them – certainly in excess of the number he needed to fill out a single Direct Debit form, which is presumably why CR-UK posted them to him in the first place. As for whether the mailings were directly addressed to the gentleman or not, I again argue that this is not really the point. When a ‘charity pen’ drops through your letterbox, it matters little whether it is in an addressed envelope or not. Likewise, whether your neighbours are receiving the same ‘gift’ hardly makes a difference to your experience of being bombarded by the charity. Your final point – that my argument essentially rules out the FRSB ever exercising any judgement at all – is also wide of the mark. As I’ve written on our (new and rather nerdy) Accountability Log, what the FRSB needs to do instead is make sure its board of directors – ultimately responsible for its decisions – is more representative of the general public. If that happened, then the FRSB would be much more effective. PS – I should also point out that the FRSB’s own research shows that over 90 per cent of people think charities which send ‘gifts’ could better spend their cash elsewhere. Adam, Intelligent Giving The editorial in this week's Third Sector says much the same thing as Intelligent Giving. You've got to admit that 13 pens in two years (-ish) is absurd and a nuisance, and shows low standards from CRUK. And if it takes a complainant to pedantically record and photograph this absurdity, so be it. Where to begin? Have you actually bothered to read the adjudication at all, and to think about the issues it raises, or is this just a knee-jerk response, based on your dislike of the FRSB? The gentleman in question did not receive thirteen pens in two years. According to Cancer Research UK, at least four of them - and possibly more - were received more than two years ago. The charity itself had only sent three unaddressed mailings during that time period. Or maybe Cancer Research UK is lying. But what exactly was the FRSB supposed to do here - take the word of the charity (who presumably presented evidence from their expensive databases to back up their claims) or believe the word of a man who had seems to have had such a hatred/dislike of Cancer Reseacrh UK that he hoarded and photographed every pen that they sent him for years? If nobody else in the area received too many mailings, my guess would be that the postman couldn't be bothered to deliver them all, and simply dropped a load through one letterbox. Do you really want to blame Cancer Research UK for that? Or are we expected to believe that the charity was so utterly inefficient as to genuinely have sent four mailings on the same day? By your logic, there's no need for the FRSB to adjudicate on anything. The moment someone complains to them, they should simply take the complainant's word for it, without asking for any evidence or giving the charity a chance to present its case, and immediately impose penalties. After all, it's the donor who judges what is unreasonable nuisance, right? Post new comment |
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