Cancer Research and Genetics UK and Recycle Proline Ltd: December 2020

Name and type of organisation/s: Cancer Research and Genetics UK (registered charity no. 1121512), and its agency Recycle Proline Ltd

Fundraising method: Charity bags

Code themes examined: the delivery of a charity bag to a ‘restricted address,’ complaint handling and third-party monitoring

Code breach?

  • Cancer Research and Genetics UK: Yes
  • Recycle Proline Ltd: Yes

The complaint

The complainant said that they continued to receive charity bags from Recycle Proline Limited (the agency) on Cancer Research and Genetics UK’s (the charity’s) behalf, despite asking not to receive them and having a sign on their door confirming they do not wish to receive them.

What happened?

In March 2019 the complainant told the charity that they had received a charity bag despite having a sign on their front door which said ‘No unsolicited or unaddressed mail’. The complainant asked the charity to remove their address from the agency’s circulation list. The agency responded and offered to send the complainant a ‘no charity bags’ sticker. It was only after the complainant asked a second time that the agency agreed to inform its distributors that the complainant did not wish to receive charity bags.

The complainant received a second charity bag in April 2019. The complainant informed the agency and the charity. The charity apologised to the complainant and said that it had told its agency to stop delivering charity bags to their address. The agency also responded and concluded that the delivery was a result of the individual distributor’s oversight.

The complainant received a third charity bag on a Saturday in October 2019 which they captured on CCTV. They subsequently complained to the agency and the charity. The complainant said they had an additional sign in place at this time which was more specific, stating ‘No charity bags’. This wording makes charity bag deliveries prohibited under the Code of Fundraising Practice (the code). However, the complainant said they removed this sign the next day.

The agency said that the complainant’s address had already been marked on their map as an address not to post charity bags to. It also said that its distributors do not work on a Saturday so needed to investigate if it was a bogus collector. The agency excluded complainant’s entire street from its distribution area.

The agency told us that its records showed that it was not operating in the complainant’s area on the day of the third charity bag delivery. It said that without a photograph of the complainant’s door sign or the charity bag it could not find out if the delivery was due to a bogus distributor.

Our decision

The charity did not engage with our investigation, which we are concerned about. We were therefore unable to make any findings in relation to the charity’s oversight of the agency’s fundraising on its behalf. We will be providing a copy of our final decision to the Charity Commission for England and Wales on the grounds that not cooperating with the regulator represents wider governance concerns.

The sign on the complainant’s door that stated ‘No unsolicited or unaddressed mail’ does not prohibit charity bag deliveries under the code. The complainant said they then added a temporary ‘no charity bags’ sign, which does prohibit charity bag deliveries. However, we were unable to reach a finding in relation to whether the agency breached this section of the code due to the lack of evidence regarding the third delivery. On the basis of the second charity bag delivery alone, we found that the agency engaged in unreasonably persistent fundraising, so was nonetheless in breach of the code.

The agency responded promptly to the complaints and kept the complainant updated. It also attempted to respond to all aspects of the complaints. However, due to how the agency handled the first complaint, we found that it breached the complaint handling section of the code. That said, the agency investigated the first two complaints appropriately. Therefore, we found that it had not breached the section of the code regarding investigating complaints.

We found that there was a missed opportunity to find out whether the distributor of the third charity bag was bogus as the agency did not ask to see the complainant’s CCTV footage of the delivery. On the basis of this flawed investigation of the third charity bag delivery, we found the charity in breach of the code regarding investigating complaints. We applied this breach to the charity, rather than the agency, because this section of the code now applies to the charity due to changes made to the code in October 2019.


Cancer Research and Genetics UK

We made no recommendations for the charity as it did not engage with our investigation.

Recycle Proline Ltd

In response to our draft decision, the agency said that its team leaders now remind the distributors of which addresses, roads or areas not to deliver to weekly. We asked to be updated about this action.

We recommended that the agency consider the learning from this complaint and review:

  • how it investigates and handles complaints that involve possible bogus distributions; and
  • its complaint handling and investigation. We asked that the agency pay particular attention to ensuring that all aspects of the complaint are addressed and responded to appropriately, and that it promptly identifies any evidence necessary to investigate the complaint.

We recommended that the agency provide the complainant with a written apology for its breaches of the code.


The agency accepted our recommendations. We asked that the agency writes to us within two months of our final decision to provide us with an update on the action taken in response to our findings and recommendations.