This guidance was published on 25 June 2020.
This guidance has been prepared in consultation with Public Health England and the Health and Safety Executive.
Fundraising key principles
COVID-19 is a public health emergency. Everyone needs to assess and manage the risks of COVID-19, and in particular fundraising organisations should consider the risks to their workers and supporters. As the lockdown restrictions begin to ease and phased approaches start to be introduced for how and when certain ways of working may return across the UK, charities and their partners will be thinking about what it means for fundraising activities that have been paused or stopped. Although going back to a complete ‘business as usual’ is unlikely to be acceptable or realistic – whether by charities, government, or the public – as some fundraising activities resume in the weeks and months ahead it is important that they are carried out sensitively, safely and responsibly.
This guidance is part of a series of resources produced by the Fundraising Regulator and the Chartered Institute of Fundraising that aims to support charities and other fundraising organisations to be able to return to fundraising activities in a responsible way. By responsible fundraising we mean fundraising that is carried out in a sensitive and safe way, in-line with the Code of Fundraising Practice (the code) and current Government advice on coronavirus including working safely during coronavirus. Requirements may also differ across the UK. So, depending where your charity carries out fundraising, you should always check the relevant guidance and apply it to your fundraising activity, especially as guidance is likely to evolve over time. For further advice, see guidance from the devolved nations of Scotland, Wales and Northern Ireland. We will keep this guidance under review, and will update it in line with any changes to Government guidance.
This guidance highlights the issues you should consider when adapting the way your organisation fundraises as lockdown measures are eased. In particular it provides advice on:
- how to plan your future fundraising;
- how to behave and interact safely and respectfully with the public;
- how to safeguard the public, staff and volunteers; and
- undertaking a risk assessment.
Status of this guidance
This guidance sets out a framework to aid good decision making and ensure responsible fundraising. It is intended to supplement existing government guidance and highlights the key issues and areas that fundraising organisations need to consider as they plan their return to fundraising. It is the responsibility of individual organisations to apply this guidance in their fundraising activity so that the safety and wellbeing of fundraisers and the public are protected. Part of acting responsibly will also include fundraising organisations properly documenting their decisions, undertaking risk assessments, and being prepared to explain and justify these if necessary.
Getting back to fundraising – planning and risk assessments
Fundraising should only restart when fundraising organisations are satisfied that this can be done safely, in line with this guidance and following relevant Government advice, and where the risks associated with the activities can be properly managed. Fundraising organisations should consider this guidance, the nature of their activity, the location, their preparation, and undertake a risk assessment to inform decisions.
- Keep up-to-date and follow UK Government guidance, including from devolved nations of Scotland, Wales and Northern Ireland. Restrictions and advice are likely to change over a period of time. It is therefore important that you keep up-to-date with announcements and apply any new requirements and limitations to your fundraising activities. Be prepared to be flexible and understand that long-term planning is still difficult at the moment. There may be differences in the easing of restrictions across England, Scotland, Wales and Northern Ireland, and therefore you will need to make sure your fundraising is carried out in-line with Government advice in the country in which your fundraisers are operating. Any guidance issued by any other body, including the Fundraising Regulator and the Chartered Institute of Fundraising, can only apply if it is in-line with Government advice for that country.
- Carry out risk assessments. It is important that all fundraising organisations carefully consider the risks associated with each type of fundraising activity they carry out. Risk assessments should be properly documented and reviewed regularly, as appropriate. See section 2.2 of the Code of Fundraising Practice for more information and the UK Government’s guidance on Five Steps to Working Safely during coronavirus. Fundraising organisations need to think about the risks staff, volunteers and members of the public will face and do everything reasonably practicable to minimise them, recognising you cannot completely eliminate the risks arising from COVID-19. Employers have a duty to consult their employees, and volunteers including fundraisers, on health and safety, which can be done by talking and listening to them about the work they do and how you will manage any COVID-19 risks. For more information go to Health and Safety Executive and also see relevant guidance in England, Wales, Scotland and Northern Ireland. You must share the results of your risk assessment with your workforce. If possible, you should consider publishing the results on your website (and the government expects all employers with over 50 workers to do so). We would expect all fundraising organisations to demonstrate to their workers and supporters that they have properly assessed their risk and taken appropriate measures to mitigate this.
- It is important that decisions to fundraise are thoroughly considered and carefully evaluated. You don’t have to try and resume fundraising straight away – talk to your teams and fundraising partners about a timetabled approach. Many fundraisers will have been furloughed so you should make sure you take into account the workload of your staff and the resources you have available. It is important that you only restart fundraising at the right time, and in the right way.
- Ensure proper oversight of decision making. All fundraising organisations must weigh up the benefits and risks of their ongoing fundraising activities and exercise judgement when deciding what is in the best interests of the public, supporters, staff, volunteers and beneficiaries. It is important to have appropriate management and oversight of all decisions that are made, and ensure that these are properly documented. Trustees are crucial in ensuring proper oversight of fundraising decisions as they have ultimate responsibility for charities’ fundraising.
- Co-operate effectively with third parties. If you work with third parties, it is important that you are clear about your expectations in relation to fundraising conduct and the approach that should be taken as lockdown measures are eased. You must also check or update any contracts that you have in place to make sure these remain fit for purpose as your fundraising activities adapt.
- Be transparent with the public and others. You should make information available (for example, on your website) that explains to the public and others how you will fundraise responsibly as restrictions are eased. You should set out the measures you are taking and how these align with Government advice for the country in which you fundraise.
- Listen to feedback. Fundraising organisations should listen and reflect on feedback they receive from the public, staff and volunteers as this will help to inform the way they carry out fundraising during this period. Your activity should be continually reviewed, taking into account comments, complaints and feedback.
Safeguarding the public and fundraisers
- Protect the public, staff and volunteers. Sufficient measures must be in place to protect the public, your fundraisers, staff and volunteers. Depending on the method of fundraising, you’ll need to consider what changing Government guidance means for staff and volunteer safety. This includes ensuring that fundraisers take appropriate measures to keep them and the public safe and ensure social distancing is observed. You can read more advice from the Government here. People who can work from home should continue to do so. Employers should decide, in consultation with their employees, whether it is viable for them to continue working from home. Where it is decided that workers should come into their place of work then this will need to be reflected in the risk assessment and actions taken to manage the risks of transmission in line with this and government guidance.
- Make sure that any fundraiser, member of staff, or volunteer self-isolates if they have symptoms of Covid-19 or have received a positive test result. If you have symptoms of coronavirus (COVID-19), however mild, OR you have received a positive coronavirus (COVID-19) test result, the clear medical advice is to immediately self-isolate at home for at least 7 days from when your symptoms started. Do not go to a GP surgery, pharmacy or hospital. You should arrange to have a test to see if you have COVID-19. Consider alerting the people that you have had close contact within the last 48 hours to let them know you have symptoms of coronavirus (COVID-19). More guidance on what to do if you have symptoms is here. The opening up of the economy following the COVID-19 outbreak is being supported by NHS Test and Trace. You should assist this service by keeping a temporary record of your staff shift patterns, fundraising locations and sign-ups for 21 days, in a way that is manageable for your organisation, and assist NHS Test and Trace with requests for that data if needed. This could help contain clusters or outbreaks. If you do not already do this, you should do so to help fight the virus.
- Train fundraisers on new approaches before restarting fundraising. New ways of working will need some time to be communicated, with appropriate training materials and resources produced to help guide fundraisers on what they should be doing. Any training should be delivered virtually, in order to meet Government guidelines. It is important that fundraisers feel confident and reassured before going back out to fundraise – if you work with a fundraising agency or partner, talk to them about their approach and agree appropriate measures and training.
- Take into account the needs of people in vulnerable circumstances or with protected characteristics. It is inevitable that fundraisers will come into contact with people who may be in a vulnerable circumstance, or need additional support to make an informed decision. Fundraising organisations should also be mindful that during the pandemic, there are approximately two million people that have been asked to shield, because of the increased risks associated with COVID-19. The pandemic may have increased the number of people who are vulnerable and research tells us that the crisis has had an impact on the nation’s mental health. You must take into account the needs of anyone who may be in vulnerable circumstances, including people who may be at higher risk from COVID-19. You should also consider the particular needs of those with protected characteristics, such as those who are hearing or visually impaired. You may want to consider reviewing any existing policies on vulnerable circumstances your organisation has, to ensure adequate safeguarding of the public. See section 1.3 of the Code of Fundraising Practice for more information.
- Where the enforcing authority, such as the HSE or your local authority, identifies employers who are not taking action to comply with the relevant public health legislation and guidance to control public health risks, they are empowered to take a range of actions to improve control of workplace risks. For example, this would cover employers not taking appropriate action to ensure social distancing, where possible.
- Failure to complete a risk assessment which takes account of COVID-19, or completing a risk assessment but failing to put in place sufficient measures to manage the risk of COVID-19, could constitute a breach of health and safety law. The actions the enforcing authority can take include the provision of specific advice to employers to support them to achieve the required standard, through to issuing enforcement notices to help secure improvements. Serious breaches and failure to comply with enforcement notices can constitute a criminal offence, with serious fines and even imprisonment for up to two years. There is also a wider system of enforcement, which includes specific obligations and conditions for licensed premises.
- Employers are expected to respond to any advice or notices issued by enforcing authorities rapidly and are required to do so within any timescales imposed by the enforcing authorities. The vast majority of employers are responsible and will join with the UK's fight against COVID-19 by working with the Government and their sector bodies to protect their workers and the public. However, inspectors are carrying out compliance checks nationwide to ensure that employers are taking the necessary steps.
Respectful interaction with the public
- Do not apply undue pressure to donors. As the services provided by charities come under increasing demand, public donations are more important than ever to enable charities to meet those demands. Although you can talk about your cause and why a donation matters to your charity, this needs to be in-line with the Code of Fundraising Practice (see section 1.2). You must not apply undue pressure (for example, intrude on their privacy or to press ahead with a fundraising ask if they have already said ‘no’). See section 1.1.3 of the code for more information.
- Be polite and respectful. You must remain polite and respectful at all times. This is particularly important now as people’s daily lives have changed so dramatically and there is heightened concern around personal and financial wellbeing. See section 1.1 of the code for more information.
- Be mindful of how the public may respond to your fundraising. Although the public continues to be hugely supportive of charities during the pandemic, do not assume that all individuals will want to donate or engage with you in the same way as they did before. Many people will want to give and are keen to donate, others will be experiencing financial difficulties, anxiety or grief. It is impossible to know every individual’s situation, but you should consider the range of likely responses and ensure that your fundraisers can and are actively responding appropriately to the signals and needs of any individual. You should be ready and willing to explain openly and clearly why you are fundraising, and the steps you have taken to ensure it is being done responsibly.