When door-to-door fundraisers encounter a notice on a house saying "no cold callers", what should they do? One option is not to knock on the door. Another is to make the assumption, which may or may not be correct, that the householder does not class charities as cold callers – as they would double glazing salesmen, say – and to go ahead and knock. An agency fundraiser working for Battersea Dogs & Cats Home took the second option recently and the householder complained. The charity backed its fundraiser, who had followed its policy, and the complaint ended up with the Fundraising Standards Board for adjudication.
The FRSB was unable to uphold the complaint because it judges complaints against the code of practice drawn up by the Institute of Fundraising, and the code does not say that fundraisers should not knock on doors where there is sign saying "no cold calling", or words to that effect; all it says on this subject is that fundraisers "ought not" to knock on doors in official "no cold calling" areas that have been established according to Trading Standards Institute guidelines.
But the FRSB was clearly uncomfortable about having to make this decision and has recommended, among other things, that there should be research into whether the public considers "no cold calling" to include charities; that consideration should be given to setting up a doorstep preference service, similar to the Telephone Preference Service and the Mailing Preference Service; and that the agency concerned, APPCO, should join the FRSB.
The FRSB points out that this is the second time it has had to adjudicate on a complaint about this subject and that it will be asking the IoF Working Party on Doorstep Fundraising, set up late last year after the first case last May, to "identify any relevant outcomes as soon as possible".
Is the FRSB, as some seem to feel, exceeding its remit by seeking, in effect, amendments to the code of which the IoF, rather than the FRSB, is the guardian? In this context it's instructive to recall a previous FRSB recommendation that the IoF should consider a code of practice on approaching potential donors who might be vulnerable. The initial reaction from some fundraisers included dismissive remarks along the lines of "where do you find a database of vulnerable donors?" But when an expert group was set up to look into the subject, it became clear that there were indeed measures charities could take to ensure vulnerable donors got appropriate protection. The code has been amended, all parties seem happy with it, the right thing has been done and it is now less likely that similar complaints will arise in future.
Maybe there could be a similar outcome here. The FRSB, which takes into account wider considerations than professional fundraisers, appears to feel the code is inadequate. Looking at the question from the outside, it seems unlikely that people who put up "no cold calling" signs don't intend them to apply to charities. They tend to be the kind of people who just don't want anyone knocking on their door, full stop. There is a possibility that they will make an exception for charities, but if charities go ahead and knock it seems, on balance, more likely that they will get a complaint than a sign-up. Why take the risk when success is unlikely and negative consequences could ensue, not just for the charity concerned but, by extension, to the sector generally? When the issue is looked at in the round, it might well be agreed, once again, that a modification to the code is needed.
More generally, it would be helpful if there were less territoriality about such questions and a greater acceptance that the code of practice is not just the fiefdom of the IoF but a joint enterprise in which the IoF represents the interests of professional fundraisers and the FRSB and others supplement this with a wider perspective, including the point of view of donors and the public. The report last year on the structure of fundraising regulation by the consultancy PwC recommended that the IoF standards committee that sets the code should have an independent chair and wider membership. It would be a good thing for this to be implemented.