Cancer Research and Genetics UK and Recycle Proline Ltd: December 2022

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

Fundraising method: Charity bags

Code themes examined: Delivery of a charity bag to an address displaying a ‘no charity bags’ sign, complaint handling, fundraising during the pandemic and third-party monitoring

Code breach?

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

The complaint

Despite having a ‘no charity bags’ sign, the complainant complained that they had received two charity bags in two weeks from Recycle Proline Ltd (the agency) on Cancer Research and Genetics UK’s (the charity’s) behalf. The complainant was concerned that both deliveries had taken place during a time when they thought coronavirus (COVID-19) pandemic restrictions prohibited all but essential work.

What happened

The complainant initially tried to contact the agency to register their concerns about the bag deliveries, in particular that the distributors were not wearing any Personal Protective Equipment (PPE). The complainant was unable to reach the agency and then contacted the charity. The complainant said that the charity terminated their call and when they called back their call was not answered.

In line with our complaints process, we referred the complainant’s concerns to the charity asking them to respond directly to the complainant. The charity emailed the complainant with its response and apologised for the deliveries. It confirmed that it had asked the agency not to deliver to their address again. The charity also said it was aware of calls from a withheld number on the date of the complainant’s original complaint, but that it was its policy not to answer them.

The complainant was unhappy with this response as they did not consider that the distributors were acting in a COVID-19 safe manner. The charity confirmed to the complainant that its agency had carried out the appropriate risk assessments and apologised again for the bags being delivered to the complainant’s property. The agency confirmed it had been operating in the complainant’s locality at the time of the bag deliveries but without further evidence from the complainant, it could not investigate further.

Although the charity initially responded to the complainant, it refused to engage with our investigation process.

Our decision

The charity failed to address the complainant’s concerns in a thorough and timely manner and did not fully cooperate with our investigation following our initial exchange. On this basis, the charity breached the section of the Code of Fundraising Practice about complaints handling. We will be providing a copy of our final decision to the Charity Commission for England and Wales as failure to cooperate with the Fundraising Regulator represents wider governance concerns.

We found that the charity was unwilling to provide evidence that it has sufficient measures in place to monitor its agency’s work. On this basis, we have found it in breach of the code in relation to third party monitoring.

Despite having no direct response from the charity on this matter, the information provided by its agency shows that the agency had considered national guidelines and the risk of fundraising activity to the public during a pandemic, and in all likelihood, the charity was aware of that. On this basis, we have not found the charity in breach of the code in relation to risk assessments and following national guidance when fundraising.

We appreciate that the agency was not responsible for directly handling or responding to the complaint and that this lack of direct contact with the complainant may have hampered its own investigation into whether it had delivered bags to a property displaying a ‘no charity bags’ sign in error. However, having reviewed all the available evidence, we found that despite the preventative measures the agency told us it had in place, on the balance of probabilities the agency was in breach of the code standard prohibiting delivery of charity bags to properties displaying ‘no charity bags’ signs or their equivalent.


Cancer Research and Genetics UK

We recommended that the charity:

  • update its complaints process to include our details
  • consider if its contract with its agency is up to date and reflects the importance of following the code, as well as including provisions for it to regularly monitor the activities carried out in its name
  • has a formal documented process for training and monitoring all third parties acting on its behalf; and
  • uses the learning from this complaint to review its approach to decision-making so that it can respond to any future requests to account for a decision.

Recycle Proline LTD

We recommended that the agency reviews whether there are further steps it could reasonably take to minimise the risk of errors that result in unwanted charity bags being delivered to addresses displaying ‘no charity bags’ signs. We suggested that the agency liaises with the charity to establish a monitoring programme.


The agency requested an external review of our decision. Upon review of the case, the External Reviewer did not consider that the complaint about our decision met the threshold for a full external review.