Christian Aid and Gather Campaigns Ltd: July 2026

Name and type of organisation(s): Christian Aid (charity), Gather Campaigns Ltd (agency) 

Fundraising method: Door-to-door fundraising 

Code themes examined: Treating donors fairly, people in vulnerable circumstances, contracts and agreements, monitoring third-party fundraisers, and house-to-house collections 

Code breach? Yes 

The complaint 

The complainant contacted the Fundraising Regulator about two third-party fundraisers who had visited a family member in vulnerable circumstances at home. The complainant said the third-party fundraisers had taken details from a debit card and set up a direct debit, despite the donor having cognitive disabilities and speech and hearing difficulties. The complainant also said the property displayed signage communicating that charities were not welcome. 

What happened?

The complainant was concerned about an incident in June 2024, when two third-party fundraisers approached the donor in their front garden.

The complainant said the donor’s vulnerability would have been apparent and that the third-party fundraisers had persuaded them to provide debit card details. The complainant said they then had to cancel and replace the donor’s debit card. They also provided video doorbell footage which appeared to show one third-party fundraiser reading the sign on the door before continuing with the interaction.

After reviewing the correspondence and information provided, we decided that the issues raised met our threshold for investigation.

We reviewed information from the complainant, charity, and agency. This included:

• The charity’s vulnerable persons policy
• Training documents
• Complaints log
• Response to the complaint and a transcript of the verification call.

We also reviewed the agency’s policies and training about vulnerability, information about the contract between the charity and agency, and the agency’s arrangements with sub-contracted fundraisers.

Our decision

Vulnerable Circumstances

The charity and agency did not dispute that the donor was vulnerable or that a donation was taken. We found that, on balance, the third-party fundraisers should have realised the donor was vulnerable. The donor was enrolled for a regular donation and the donation was processed. We therefore found breaches of the code about treating donors fairly and people in vulnerable circumstances.

Third-party fundraisers

We found that the contract between the charity and agency was comprehensive and contained monitoring arrangements. However, the sample contract between the agency and sub-contracted fundraisers did not provide enough detail about the sub-contractor’s obligations under the Code of Fundraising Practice or monitoring requirements. We found that the charity was overly reliant on the agency to manage compliance further down the supply chain.

We also found that the third-party fundraisers ignored a ‘no cold calling’  sign on the property which met the criteria set out in the code for house-to-house collections. 

Code sections considered

Code of Fundraising Practice, version effective 1 October 2019 (last updated 4 June 2021)

Section 1.3 Informing donors and treating people fairly

• Standard 1.3.7: breach identified
• Standard 1.3.8: breach identified
• Standard 1.3.9: breach identified

Section 2.1 General duties

• Standard 2.1.1: breach identified

Section 7.2 Contracts and agreements

• Standard 7.2.4: breach identified
• Standard 7.2.9: breach identified

Section 7.3 Monitoring that fundraisers are meeting the code

• Standard 7.3.1: breach identified
• Standard 7.3.2: breach identified

Section 8.4 Further standards that apply to particular locations and activities

• Standard 8.4.3: breach identified

Our recommendations

The charity reviews its arrangements with the agency, specifically:

• Its use of sub-contractors and the way due-diligence and responsibility for performance in this context is defined, for both closed and open network contracts (relating to whether sub-contractors can work with more than one charity client).
• The level of detail required within the agency and sub-contractor’s agreement as to the agency’s monitoring and compliance activities and the sub-contractor’s reporting requirements, and;
• Increased clarity about how the agency ensures sufficient, effective, and regular oversight of the day-to-day activities of any sub-contractor.

The agency reviews its contracts and agreements with relevant sub-contracted fundraisers and provides specific details regarding:

• Its monitoring and compliance activities of the sub-contractor’s adherence to the code, including the method and frequency.
• The sub-contractor’s specific obligations regarding the Code of Fundraising Practice and its requirement to protect donors, and;
• The sub-contractor’s reporting requirements for its own methods of ensuring compliance and their efficacy.

The charity and the agency consider their monitoring and compliance arrangements with sub-contracted fundraisers, specifically:

• Oversight of training material and training sessions provided to fundraisers which relate to expectations set out in the code.
• The sub-contractor’s assessment tools for fundraiser knowledge of and adherence to the code. 

The charity to continue to review and update its own training materials about the code to:

• Ensure that it reflects the most up-to-date information from the Fundraising Regulator.
• Provide clarity on the practical applications for fundraisers;
• Clearly define and quantify undue and unreasonable pressure behavioural expectations for those fundraising on the charity’s behalf and;
• Ensure this level of detail is reflected in all code compliance training material provided to its fundraisers.

The charity considers further ways to identify potential inherent compliance issues within the full supply chain that may not be readily identified from feedback and complaints. 

The agency reviews the materials used for training its fundraisers. This should include:

• An appropriate level of detail about the requirements set out in the code, including undue pressure and unreasonable persistence; informed consent; vulnerable circumstances and use of personal information.
• Inclusion of the practical application of the code requirements as it relates to expected behaviour of fundraisers on the doorstep.
• Assessment of a fundraiser’s understanding of the compliance requirements placed upon them, and;
• Emphasising the importance of the standards of the code relating to vulnerability as a central theme in the information and training provided to fundraisers.
• A review of the verification call training with a focus on identifying vulnerability.

Whilst our recommendations are specific to the concerns which have been raised in our investigation, we would strongly urge all parties to consider any areas of our findings and recommendations which may be relevant to other professional fundraising arrangements.

Outcome 

It is positive that the charity and the agency have told us that they are implementing changes. We will continue to work with the charity and agency to support the implementation of our recommendations, including establishing appropriate timescales.