"The only Professional Fundraising Organisation
to include dedicated donor monitoring as part of what we do"
STC views complaints as an opportunity to learn and improve for the future, as well as a chance to put things right for the person or organisation that has made the complaint. Our policy is:
• To provide a fair complaints procedure which is clear and easy to use for anyone wishing to make a complaint
• To publicise the existence of our complaints procedure so that people know how to contact us to make a complaint
• To make sure everyone at STC knows what to do if a complaint is received
• To make sure all complaints are investigated fairly and in a timely way
• To make sure that complaints are, wherever possible, resolved and that relationships are repaired
• To gather information which helps us to improve what we do
Definition of a Complaint
A complaint is any expression of dissatisfaction, whether justified or not, about any aspect of STC.
Where Complaints Come From
Complaints may come from any person or organisation that has a legitimate interest in STC. A complaint can be received verbally, by phone, by email or in writing. This policy does not cover complaints from a member of staff, who should use STC's Discipline and Grievance policies.
All complaint information will be handled sensitively, telling only those who need to know and following any relevant data protection requirements.
Overall responsibility for this policy and its implementation lies with the directors of STC.
This policy is reviewed regularly and updated as required.
Adopted on 01/01/2015
Last reviewed on 27/11/2015.
Contact Details for Complaints:
Written complaints may be sent to STC at Fernleigh, Bullockstone Road, Herne Bay, Kent CT6 7NL or by e-mail at email@example.com. Verbal complaints may be made by phone to 01227 361 960 or in person to any of STC's staff.
Complaints may arrive through channels publicised for that purpose or through any other contact details or opportunities the complainant may have. Complaints received by telephone or in person will be recorded. The person who receives a phone or in-person complaint will:
• Write down the facts of the complaint
• Take the complainant's name, address and telephone number
• Note down the relationship of the complainant to STC (for example: charity, employer)
• Advise the complainant that we have a complaints procedure
• Advise the complainant what will happen next and how long it will take
• Where appropriate, ask the complainant to send a written account by post or by email so that the complaint is recorded in the complainant's own words.
In many cases, a complaint is best resolved by the person responsible for the issue being complained about. If the complaint has been received by that person, they may be able to resolve it swiftly and should do so if possible and appropriate. Whether or not the complaint has been resolved, the complaint information should be passed to a director within 24 hours. On receiving the complaint, the person who complaints go to will record it in the complaints log. If it has not already been resolved, they delegate an appropriate person to investigate it and to take appropriate action.
If the complaint relates to a specific person, they should be informed and given a fair opportunity to respond. Complaints should be acknowledged by the person handling the complaint within two working days. The acknowledgement should say who is dealing with the complaint and when the person complaining can expect a reply. A copy of this complaints procedure should be attached.
Ideally, complainants would receive a definitive reply within two weeks. If this is not possible because for example, an investigation has not been fully completed, a progress report will be sent with an indication of when a full reply will be given. Whether the complaint is justified or not, the reply to the complainant would describe the action taken to investigate the complaint, the conclusions from the investigation, and any action taken as a result of the complaint.
If the complainant feels that the problem has not been satisfactorily resolved, they can request that the complaint is reviewed at Board level. At this stage, the complaint will be passed to the Managing Director. The request for Board level review will be acknowledged within one week of receiving it. The acknowledgement will say who will deal with the case and when the complainant can expect a reply.
If an investigation has not been fully completed, a progress report will be sent with an indication of when a full reply will be given. Whether the complaint is upheld or not, the reply to the complainant will describe the action taken to investigate the complaint, the conclusions from the investigation, and any action taken as a result of the complaint. The decision taken at this stage is final, unless the Board decides it is appropriate to seek external assistance with resolution. At this point the complaint may be escalated to the APGO for resolution. See www.apgo.org.uk
StC Payroll Giving Ltd (STC) is committed to its mission to help charities of all sizes to raise regular income using the Payroll Giving Scheme in order to provide long term income for these charity clients. We commit at all times to be open, honest, fair and legal.
This policy seeks to cover the ethical issues and social responsibility within fundraising. All STC staff involved in fundraising have a responsibility to be aware and have a thorough understanding of the ethical issues referred to in this policy.
1. STC respects the rights of donors to clear, truthful information on the work of STC and to openly report how we manage donors' information responsibly.
2. We will comply with the Fundraising Regulator's Codes of Fundraising Practice as amended from time to time and UK law in every respect, including those regarding openness and honesty with members of the public.
3. As members of the APGO's self-regulatory scheme, we follow their Code of Conduct, which, amongst other things, helps to ensure that organisations raising money for charity from the public do so honestly and properly.
4. We will respect the privacy and contact preferences of all donors. We will respond promptly to requests to cease contacts or complaints and act as best we can to address their causes.
5. We will adhere at all times to the legal requirements the Charities Act 1992 and the Charities (Protection and Social Investment) Act 2016 and any amendments made to them. We will ensure that equivalent fundraising activities carried out in Northern Ireland are managed in the same manner.
Our fundraisers will at all times:
1. Provide clear and adequate, written or verbal, information to the public about possible follow‐up, including any applicable telephone procedures or other contact details as required by the Data Protection Act 1998 and comply with other provisions of the Data Protection Act 1998;
2. Act honestly and in a manner that does not mislead and will not knowingly or recklessly disseminate false or misleading information in the course of their fundraising duties, nor permit others to do so;
3. Utilise materials as agreed previously with the fundraising organisation;
4. Ensure that in the event of a complaint, a record of the name, address and telephone number of the complainant is made and the complainant is referred immediately to the organiser of the activity and to the Fundraising Director of StC as per our complaints procedure;
5. Not directly encourage existing donors in any way to change an existing charitable donation to another fundraising organization;
6. Use a courteous manner that will not bring StC, the charitable organisations or Payroll Giving into disrepute;
7. Ensure that donors are aware that committed giving schemes are intended for long‐term donations; that the donor has the right to terminate the agreement at any point; and that charitable organisations' needs may be better served by a one‐off donation if the donor does not feel able to undertake a long term commitment;
8. Terminate any contact politely and immediately upon request;
9. Ensure that donors are aware that they are free to elect to give to any charitable organisation following a Payroll Giving promotion, even if it is a charitable organisation that the fundraiser is not directly representing;
11. Wear photo identity badges provided by StC in a visible place at all times;
12. Ensure that sufficient safeguards exist and are followed throughout the solicitation process to avoid pressurising potential donors, though reasonable persuasion can be used;
13. Ensure that donors are aware that they have the right to terminate an agreement to donate to a fundraising organisation at any point;
14. Make legally compliant statements as to how StC are paid;
15. Process information as swiftly as possible and ensure that information relating to new donors is passed to the relevant parties as soon as possible;
16. When representing multiple organisations, ensure that all clients are represented in an entirely neutral manner;
17. Above all the fundraiser must ensure that the public are protected from unreasonable intrusion on a person's privacy, unreasonably persistent approaches or undue pressure to give, as per the Charities Act 1992 and the Charities (Protection and Social Investment) Act 2016.
18. Before any approaches to solicit donations are made to a group of employees, StC will agree conditions of access with the relevant employer.
StC Payroll Giving is a Professional Fundraising Organisation. We provide fundraising services to charities throughout the United Kingdom. Our appeal is to attract regular, ongoing committed givers to charity and we work with charities on a rolling year basis. Representation is free allowing funds to be raised without risk and at low cost. Only if support is generated from our work are we paid a fee by the charities we represent (please visit www.stcpayrollgiving.co.uk and click on 'Downloads' to find a full charity list). The average life of a Payroll Giving donation is 7-8 years. Last year, our work resulted in recruitment of new Payroll Giving donors pledging over 8.2 million pounds to charities (in one year alone). This year we estimate our annual remuneration will be in the region of £600,000. This cost is proportionately shared (in accordance with donations made) by approximately 160 charities we are contracted to.
Once deducted from your salary, your donation will be passed in full to the HM Revenue & Customs approved agency your employer is contracted with who is responsible for disbursing monies to the relevant beneficiaries according to your instructions. At this stage, there is a small fee payable dependant on the agency (the agency receives this, not StC Payroll Giving - details available on request). In many cases your employer will cover this cost.
StC Policy for dealing with vulnerable donors.
At StC we want our clients, both charity clients and employers, to feel comfortable with the ways that we recruit donors. This policy aims to make sure that we meet this pledge at all times. We also want everyone who works for us to understand their responsibilities to all donors, whether potential donors or recruited donors. We want to work together in a clear and consistent way, always taking reasonable care to treat everyone fairly.
This policy follows the Institute of Fundraising's guidance Treating Donors Fairly, specifically the guidance for fundraisers on responding to the needs of people in vulnerable circumstances and helping donors make informed decisions. The full report can be found here: http://www.institute-of-fundraising.org.uk/guidance/research/treating-donors-fairly/
Sections of this policy marked with an asterisk (*) have been taken directly from the Institute's guidance.
As well as the Institute of Fundraising, we are also members of the following professional body:
- Association of Payroll Giving Organisations (APGO)
We abide to follow the codes of each of these organisations and those regulations put forward by the Fundraising regulator and the Charities Act 1992 and the Charities (Protection and Social Investment) Act 2016, (as amended or replaced from time to time, or any statutory requirements or modifications thereof.
We want this policy to inform our working practices and be relevant to all. We will take steps to ensure that this approach is embedded in our organisation's culture and ensure that this policy is visible at all times on our website. http://www.stcpayrollgiving.co.uk/other-policies/
We will ensure all those that regularly communicate with donors are fully trained before they do so and that this training is refreshed at least once a year.
How do we identify an individual who needs additional care and support, or may be in a vulnerable circumstance?
The Collins dictionary defines "vulnerable" (amongst other things) as:
1. Capable of being physically or emotionally wounded or hurt
2. Open to temptation, persuasion, censure, etc.
3. Liable or exposed to disease, disaster, etc.
We first need to define someone as vulnerable and then ascertain if this is a permanent or a current life situation. We will not make sweeping judgements on people - for example, age is not necessarily an indicator of vulnerability - and everyone should have the opportunity to donate, if they are able to do so. We also need to bear in mind that actively avoiding someone based on a characteristic such as age could be seen to be discriminatory.
Permanent versus temporary vulnerabilities *
There is some overlap in these indicators above and the tests relating to mental capacity. The important distinction is whether the individual has a complete lack of capacity to make a decision, or needs more information and support to be able to make a decision to donate. Fundraisers need to be aware of this difference so that they can make a reasoned judgment and act appropriately when dealing with existing or potential donors. An individual who may need additional care and support, or may be in a vulnerable circumstance, can still have capacity to choose to donate to a charity.
Permanent Current life situation
Physical & mental medical conditions Physical & mental medical conditions
Disability Times of stress or anxiety e.g. Bereavement, redundancy
Learning difficulties Financial vulnerability
Financial vulnerability Influence of alcohol or drugs
English not being the donors first language
Indicators that the individual appears confused *
It is not possible to provide a comprehensive set of factors or characteristics which would enable fundraisers to be able to always identify an individual who is in a vulnerable circumstance, may require additional support, or lack capacity. Instead, what follows is a (non-exhaustive) list of indicators or triggers which could signal that someone may be in a vulnerable circumstance or lack capacity.
- Asking irrelevant and unrelated questions?
- Responding in an irrational way to simple questions?
- Asking for questions or information to be continually repeated?
- Saying 'yes' or 'no' at times that it is clear they haven't understood?
- Taking a long time or displaying difficulty in responding to simple questions or requests for information?
- Repeating simple questions such as 'who are you, what charity is it, what do you want?'
- Wandering off the subject at hand and making incongruous statements?
- Displaying signs of forgetfulness?
Indicators that the individual may have physical difficulties *
The displaying of physical difficulties by the donor does not necessarily indicate any issues of vulnerability or mental capacity. However, if a donor is experiencing or exhibiting any form of physical difficulty or distress, this could impact on their ability to make an informed decision on their donation at that time and could be addressed by a fundraiser acknowledging and addressing that need.
- Unable to hear and understand what is being said?
- Unable to read and understand the information they are provided with?
- Displaying signs of ill-health like breathlessness or making signs of exasperation or discontent?
Indicators that the individual may be in a vulnerable circumstance (or lack capacity) *
Different signs should be more or less apparent depending on the nature of the communication and fundraising interaction – talking to an individual face to face will allow for more signs or indicators to be picked up by the fundraiser who can then respond appropriately. What is important is that fundraisers are alert to any signs given which indicate that the individual may not able to make an informed decision about their donation.
- Giving a statement such as 'I don't usually do things like this, my husband/wife/son/daughter takes care of it for me'?
- Saying that they are not feeling well or not in the mood to continue?
- Indicating in any way that they are feeling rushed, flustered, or experiencing a stressful situation?
- Having trouble remembering relevant information, for example forgetting that they are already a regular donor to that charity (e.g. have an existing Direct Debit), or have recently donated?
- Donating an unexpectedly large gift with no prior relationship?
(NB. There being no prior relationship before a gift is made does not on its own constitute 'vulnerability': many legacy and major donor gifts to charities are given without the existence of a relationship between the donor and charity.)
What should we do if a potentially vulnerable person wishes to sign a donor form?
Interaction with vulnerable people may be unavoidable, especially as it is not always immediately obvious what a person's situation is. How fundraisers respond to the needs of an individual will depend on the nature of the particular interaction and engagement. Fundraisers should be responsive to the needs of an individual and adapt his or her approach to suit those needs and the context.
Examples of how a fundraiser can respond to the needs of an individual: *
- Talk in clear language, avoiding words and phrases that may be hard to understand (but avoid shouting).
- Repeat information.
- Try to reflect the terminology used by the donor which may help to increase/speed up their understanding.
- Be patient and do not rush the individual.
- Provide alternative formats of fundraising materials (different language, accessible formats).
- Be upfront and tell the person why you are communicating with them and check they are happy to continue.
- Ask if they would prefer to be contacted in a different form (email, letter) and offer to contact them at a different time.
- Ask if they would like to talk to anybody else before making a decision.
- Check their understanding at relevant parts.
- Check with a supervisor of HR manager if they are available.
Taking or returning a donation
If you're still unsure about whether or not we should allow the donor to complete a form, you should refer to the following checklist: *
- Check against the charity commission gift acceptance/refusal policy (section 6.3). https://www.gov.uk/government/publications/charities-and-fundraising-cc20/charities-and-fundraising
- See whether the individual has completed a form before or if there is a prior relationship.
- Consider whether the donor was given any additional support at the time of completing the form to help them make an informed decision.
- Attempt to contact the donor to check that the donation, and amount, was intended.
- Make a judgment on whether you think that the person is able to make an informed decision – and if not, then do not process the form without checking with a supervisor or HR manager if they are available.
Based on your assessment of the situation, it may be necessary to end the interaction. When doing this, care must be taken not to cause offense or upset. Examples of ways to end a verbal or email conversation include:
- 'I've taken up enough of your time today, thank you for listening.'
- 'Maybe you would like to take some more time to consider whether you'd like to support us?'
- 'You're welcome to contact us at your convenience to discuss this further...'
Terminating the interaction could depend on whether the individual's vulnerability is judged to be a permanent or temporary situation.
What should we do if we are contacted by a family member or carer?
If a donor – or a family member with power of attorney – contacts to say that a donation was made by someone unable to make an informed choice, then we can (and should) cancel the donation. It may also be appropriate to mark this person on our database as 'do not contact'.
However, if the contact is made by a third party - such as a family member, without power of attorney - we need to be satisfied that the request is being made on behalf of the donor. The onus here falls to the third party to provide evidence that they have the right to represent the donor. We should, of course, remain sensitive to the fact the donor may be going through a permanent or temporary change in circumstances that may be quite stressful to the third party.
In all situations, the outcome and the preferences recorded should be followed up with a written confirmation to the dono
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