Introduction
The primary purpose of GoodPAYE is to provide a mechanism whereby individuals can donate to charity through their payroll. We believe that giving to the causes you care about should be a positive experience for everyone.
We agree with the Fundraising Regulator’s Promise to be open, honest, fair and legal. This Policy outlines our fundraising approach to ensure the safeguarding of individuals who may be vulnerable and/or in vulnerable circumstances.
What is a vulnerable person or vulnerable circumstance?
We recognise that some of the people we engage with through our fundraising activities will not always have the capacity to fully understand the nature of the donation they are being asked to make, or the consequences of making that donation. Furthermore, we recognise that vulnerability is complex and changeable and may, at some stage in life, affect any individual.
If an individual lacks the mental capacity to make an informed decision, then they are potentially vulnerable. The Mental Capacity Act 2005 states that this can be defined as an impairment of the functioning of the brain leaving that person unable to make a decision, for example
dementia.
As the Fundraising Regulator Guidance Treating Donors Fairly states ‘an individual does not have to have any medical, physical, or mental condition to be in a vulnerable circumstance’. Instead, something could have happened in their life that makes things difficult for them, meaning that it is harder for them to make decisions, or they are experiencing particular stress or anxiety.
We therefore understand that vulnerability can be a temporary situation defined by significant life events, such as times of extreme stress and/or anxiety. It is important for all our staff and representatives to remember that there is a wide range of potential vulnerabilities, which can affect different people in different ways. It is important to consider each supporter’s circumstance individually and refrain from making judgements.
We also recognise that there are times where an individual may have capacity to make a decision, but circumstances mean they may require extra support in making that decision e.g. if someone is bereaved.
An individual who finds it difficult to immediately make an informed decision about the choices offered to them is called a ‘vulnerable person’.
Examples of indicators which could lead GoodPAYE to believe that an individual is a vulnerable person, is in a vulnerable circumstance, or needs additional support could include:
- Physical and mental medical conditions
- Disability
- Learning difficulties
- Times of stress or anxiety (e.g. bereavement, redundancy)
- Financial vulnerability (where a donation may impact on their ability to sufficiently care for themselves or leave them in financial hardship)
- English not being the supporter’s first language
- Influence of alcohol or drugs.
Due to its nature, it is not possible to provide a comprehensive set of examples, so these serve as guidance and fundraisers are advised to always remain alert to the potential for vulnerability.
Our commitment to protect vulnerable people
All fundraisers receive regular training on how to identify and engage with potentially vulnerable supporters. All fundraisers are reminded that they should be alert to indicators of potential vulnerabilities in every interaction they have with potential and existing supporters.
If a fundraiser suspects that an individual they are talking to is in a vulnerable situation, or lacks the capacity to make an informed decision, then the interaction with the supporter should be ended immediately in a polite manner protecting their dignity, without making a request for a donation nor asking about the individual’s capacity to make a decision or the existence of vulnerable circumstances.
We recognise that it may sometimes be difficult for fundraisers to assess the vulnerability of a potential or existing supporter. Our approach is always to err on the side of caution, and in cases where a fundraiser is unsure, they must ask their manager for a second opinion and approval before accepting any donation instruction.
Furthermore, GoodPAYE’s fundraisers, employees, contractors and volunteers agree to:
- always be compassionate and never exploit vulnerability
- always do everything they can to assist new and existing supporters to make informed decisions about the charities they wish to support wherever possible
- fully comply with the Fundraising Regulator’s Code of Fundraising Practice
- allow supporters, or those acting on their behalf, to declare vulnerability
- not contact supporters with the aim of asking for an increase in their giving where the supporters’ records indicate a declaration of vulnerability
- not accept donations where they have reason to believe that a supporter may be experiencing vulnerable circumstances and that accepting the donation would be ethically wrong and/or harmful to the supporter, regardless of whether a declaration of vulnerability has been made or not
A lot of our fundraising is conducted digitally. We understand that in a digital environment the ability to recognise the vulnerability of a potential or existing supporter is more difficult than in a face-to-face environment.
If digital communications have come directly from a vulnerable individual’s employer, the individual (or their authorised third party) should inform the employer that they do not wish to receive further communications, or that they require further assistance to make an informed decision about their donation.
Digital communications will only be sent directly from GoodPAYE to an individual if the individual has given their consent to receive communications from us. Every email we send has the ability for the recipient to opt-out of future communications directly from the email.
Furthermore, existing supporters have the ability to update their communication preferences at any time via their login to the GoodPAYE platform. We encourage everyone who uses our services to keep their digital communication preferences up to date. If an individual receives a digital communication from GoodPAYE and requires further assistance to make an informed decision about their donation, they can contact us via email at: [email protected].
Should a situation arise where we become aware that we have unknowingly accepted donation instructions from an individual during a time that he or she was experiencing vulnerable circumstances, we will endeavour to return all donations accepted during this period.
If GoodPAYE becomes aware of a situation where a third-party agency acting on its behalf has not acted in accordance with this policy, it may stop working with the agency or ask that individual fundraisers responsible for non-compliance with the policy be removed from GoodPAYE campaigns.
If you believe you have interacted with a vulnerable supporter and you are concerned about their welfare, you must speak with your line manager.
Our policy is informed by the Code of Fundraising Practice and further guidance provided by the Institute of Fundraising and Fundraising Regulator.