The British Red Cross, Macmillan, NSPCC and Oxfam all breached the Code of Fundraising Practice in their dealings with now defunct fundraising agency GoGen, a Fundraising Standards Board report released today has said.
The FRSB opened an investigation into telephone agency GoGen last year, after an undercover Daily Mail reporter found major failings. Several weeks after the article was published, GoGen went into administration.
In its investigation report, the FRSB said “all four charities failed to monitor GoGen’s fundraising activities appropriately”.
It also said that both Macmillan and the British Red Cross were “likely to have mislead donors” about the way in which their contact details would be used in the future.
The FRSB also found that GoGen itself breached three separate codes, including using “brutal” tactics to exploit donors in fundraising calls and putting undue pressure on potential donors. It said that GoGen’s fundraisers were trained “not to be honest” about why they were contacting potential donors.
The FRSB said that, “due to the complexity of this case” and the number of organisations involved “it has taken several months for the FRSB to draw this investigation to its conclusion”.
The report also conceded that, in the intervening months between last summer and now, “substantial improvements have since been made to the way in which fundraising is conducted in the UK”.
Investigation findings
The report outlines a number of ways in which the four named charities interacted with GoGen and outlined them in alphabetical order in its findings.
The FRSB looked at all four charities contractual agreements with GoGen; each charity's approach to monitoring the agency; opt out opportunities provided to supporters and each charity's approach to the Telephone Preference Service register.
The FRSB found that all four of the charities named failed to “adequately monitor” the fundraising activities being undertaken on their behalf by GoGen fundraisers.
The FRSB found that the Red Cross monitored just 434 call being made on its behalf by GoGen in 2014, approximately 0.16 per cent of the over 668,000 calls made by the agency in that time. Macmillan reviewed approximately 0.15 per cent of the 60,000 total calls made on its behalf, a figure that was also found to be insufficient.
Both the NSPCC and Oxfam were found to have had better monitoring protocols in place but, when asked for recorded evidence as part of the FRSB’s investigation, neither was able to provide figures of how many randomly selected or live calls they reviewed. As a result, both were found to be in breach of the Code.
In addition, the FRSB also found that both the British Red Cross and Macmillan were in breach of the code in relation to their use of supporters’ personal contact details.
Both the BRC’s ‘Privacy Notice’ and Macmillan’s ‘Fair Processing Notice’ – issued by both charities to new supporters outlining how their details might be used in the future – did not “make it sufficiently clear what type of further contact a supporter might receive” and were therefore found to have potentially “mislead supporters”.
The FRSB found that all four charities adhered to the IoF’s Code of Fundraising Practice in relation to the TPS register as they were worded at the time.
GoGen was also found to have breached the Code in three places - by exploiting vulnerable people, placing too much pressure on donors, and misleading donors.
GoGen fundraisers were “trained to be brutal” when asking for money for supporters, allegations that were supported by transcript and audio evidence supplied the Daily Mail.
GoGen was found to have breached the code where it relates to pressurising donors on multiple occasions and were also guilty of training fundraisers to mask the nature of why they were contacting supporters on behalf of the named charities.
GoGen was cleared on two other counts.
In its conclusion, the FRSB said that charities “should consider the donation targets they give to their external telephone fundraising agencies” as the higher the targets, the more pressure may be put on the public by fundraisers.
Andrew Hind, chair of the FRSB, said: “Working with telephone fundraising agencies can be an important way for charities to reach out to new and existing supporters, but it is essential that any fundraising activity meets standards laid out in the Code of Fundraising Practice.
“While this investigation outlines a number of failings at the agency, ultimate responsibility always rests with charities for the conduct of any third-party agencies representing them. We welcome the significant actions that each charity has since undertaken to ensure closer working with any agencies they work with in the future, including better monitoring and supervision procedures.”
Responses to the report
A spokeswoman from the British Red Cross said: “We were hugely disappointed to learn last year of the behaviour of GoGen agency staff. It was completely unacceptable and we suspended, not only our work with them, but all of our telephone fundraising whilst we conducted a full review of our standards and procedures.
“As a result we have further strengthened our practices to put in place extensive measures to monitor any agencies we work with. This includes unannounced drop ins, mystery shopping and a whistleblowing procedure for agency workers to raise any concerns directly with us.”
Lynda Thomas, chief executive of Macmillan, said: “We are extremely sorry that the work undertaken by GoGen on our behalf did not meet the high standards we expect which is why we immediately suspended our work with them.
“We have appointed a dedicated compliance manager who is undertaking a comprehensive programme of work to implement rigorous new training, quality assurance and monitoring procedures across all our fundraising activities. Alongside this we immediately reviewed and amended our data protection statement to make it easier and clearer for supporters to choose how they support us.“
Peter Wanless, chief executive of the NSPCC, said: “Specific fundraising actions exposed at GoGen were unacceptable and once revealed the NSPCC terminated its relationship with them.
“We accept it would have been good practice to keep better records of our monitoring activity and have made substantial changes to our fundraising operation so we are now better placed to serve our highly valued supporters without whose help we could not carry out our vital work of protecting children from abuse.”
Mark Goldring, chief executive of Oxfam GB, said: "We accept the FRSB’s findings and I would like to apologise once again for the fact we did not spot that GoGen were falling well below the high standards both we and the public expect of our fundraisers.
"We halted our work with GoGen last summer, as soon as we were made aware of the allegations. Since then - as the FRSB recognises - we have significantly strengthened the monitoring of all agencies which fundraise on our behalf."
Giuseppe Iantosca, former director of GoGen, said: “It is regrettable that in a minority of instances, procedures in place to safeguard fundraisers, and the donors they were speaking to, were not robust enough.
“There is still more that can be done in tightening the Code in relation to telephone fundraising and to improve the donor experience, for example: re-examining the advised maximum number of fundraising asks; defining acceptable levels of dial attempts; the employment of ‘trigger-based’ opt outs on all campaigns.”
