Church Urban Fund: June 2020

Name and type of organisation: Church Urban Fund (registered charity no: 297483) 

Fundraising method: Direct marketing 

Code themes examined: supporter data, fundraising communications and vulnerable donors

Code breach? Yes

The complaint

The complainant told us that they used the Fundraising Preference Service (FPS) to request that Church Urban Fund (the charity) stop contacting their relative, but their relative continued to receive further contact from the charity. 

What happened?

The complainant completed an FPS request on 3 December 2017 to suppress all communication from the charity on behalf of their relative who has dementia. However, the complainant’s relative continued to receive mailings from the charity. The complainant completed follow up FPS requests on 30 December 2017, 26 June 2019 and 10 October 2019.

Despite the follow up requests, the charity telephoned the complainant’s relative on 3 December 2019 to thank them for their previous donation. It regarded this telephone call as administrative and not for the purpose of fundraising. However, during this call the complainant’s relative consented to being added to another mailing list and a further mail was sent to them that month.

The charity did not record this telephone call but provided us with the script that was issued to its members of staff. The script detailed that staff should thank the individual for their donation, remind them that they are an important donor and ask them if they would be interested in receiving the charity’s communications. 

The script did not provide guidance on detecting the potential vulnerability of a donor during the telephone call or what to do should the staff member have concerns. The charity provided us with a copy of its safeguarding policy but it did not have a vulnerability policy.

The charity did not have a formalised process to check that FPS requests had been carried out until we informed it of this complaint. The charity acknowledged that a lack of a formal process did not allow it to check that the supporters who had requested their details be suppressed via FPS were not included for further mailings. 

Our decision

We had concerns that the charity considered its telephone call to the complainant’s relative was for administrative purposes only. We consider that the campaign was designed to promote the work of the charity and to refresh consent to send donors further marketing materials, including requests for donations. Therefore, this was a direct marketing call and the charity acted in contravention of the FPS request.

In addition, the complainant’s relative received further direct marketing from the charity despite their FPS request, so we found the charity had breached the section of the code in relation to the FPS. Therefore, we will be sending a copy of our final decision to the Information Commissioner for their information.  

The investigation also raised concerns regarding how the charity may have interacted with individuals in potentially vulnerable circumstances during its telephone calls. We saw no evidence that staff members would have been equipped with the skills to recognise if they were speaking to potentially vulnerable people. 

We consider that it is important that staff are aware of the signs of vulnerability and understand what to do if they encounter someone who may potentially be in vulnerable circumstances. However, due to a lack of evidence relating to the telephone call, we were unable to reach a finding on this point. 


We are encouraged that the charity has said that in light of this complaint it is reviewing the processes it has in place for recording FPS suppressions. 

We recommended that the charity:

  • consider its process for completing initial FPS and follow-up requests and review the FPS requests it has received up to this point.
  • consider reviewing its database to assure itself that its records accurately reflect all of its communications with donors, as well as their communication preferences. 
  • review its staff training regarding recording the outcome of telephone calls to reassure itself that its records accurately reflect the conversations that have taken place.
  • consider reviewing its policy and training regarding potentially vulnerable members of the public. 


The charity accepted our recommendations. We asked that the charity write to us within two months of the date of our final decision to outline the actions taken in response to our findings and recommendations.