The Small Charities Coalition has urged the new Fundraising Regulator to reconsider its plans to introduce a Fundraising Preference Service, despite proposals not to require charities with annual incomes below £1m to check their fundraising campaigns against it.

Responding to a consultation launched by the working group set up to consider the scheme, which closed on Thursday, the SCC says it does not believe the FPS is the best model to the resolve the difficulties with charity fundraising practices.

The umbrella body writes in response to a discussion paper published last month by the group, which offered to excuse fundraising organisations with incomes of below £1m a year from the requirement to check their fundraising campaigns against the FPS.

"The stand-alone FPS model is too complex," the SCC says in its submission. "This complexity could exacerbate public frustrations, due to requiring an individual to complete three registration forms across three preference service (FPS, Mail Preference Service and Telephone Preference Service), as well as contacting individual charities regarding other communication preferences – and accepting the individual may still receive unregulated or indirect charity communications."

It says that instead of setting up an FPS, the regulator should build upon and simplify the user experience of the MPS and TPS and ensure charities make it easier for people to unsubscribe from email mailing lists.

The SCC says that in considering the size of charities to which the FPS would apply, the service should focus on organisations’ income or expenditure from individual giving specifically, rather than their total income. "This means the FPS is targeted at those who have a strong focus on individual giving fundraising," the submission says.

The FPS working group, which is chaired by George Kidd, the chief commissioner of the Direct Marketing Commission, also received a submission from the Institute of Fundraising. This calls for the service to allow individuals to remain opted in to charities that they currently support without that person needing to name those charities.

"Many donors will want to continue hearing from, and donating to, charities that they support but may be unable to recall the names of those charities at the time of registration on an FPS," says the submission.

The IoF says that unless the FPS allows people to opt out of particular channels, but remain opted in to others, the service will end up being a "blunt tool that will fail to provide genuine choice to people".

It calls for a full consultation and assessment to be carried out on the potential impact on the sector of introducing an FPS and says the group should consider whether the service is necessary, given the changes made to the Code of Fundraising Practice over the past year and forthcoming legislative changes.

It says that the main priority of the service should be the safeguarding of individuals in vulnerable circumstances and the FPS should separate the needs of such people from the wider service.

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