The Code of Fundraising Practice (the code) requires that all reasonable steps are taken to treat a donor fairly, enabling them to make an informed decision to donate.
All online fundraising platforms (platforms) should provide clear, transparent and accessible information on their services so that members of the public know where their donation is going and what their rights are if something goes wrong.
The code defines an online fundraising platform as:
‘A website or application run by a commercial company, not-for-profit organisation, charitable institution or a person, which charitable institutions can use for fundraising or which people or organisations can use for crowdfunding for charitable, philanthropic and benevolent purposes.’
- About this guidance
- Fees and charges
- Complaints procedures
- Refunds and repurposing policies
- Protection against fraud and money laundering
- Policies on donations to private bank accounts
- Guidance for fundraisers
This guidance does not apply to donation pages hosted on a charitable institution’s own website (where the donor is not directed away from the charitable institution’s own domain name to a third party’s) if no fees are charged on individual donations.
All platforms should make sure that they are familiar with the code and the standards for platforms.
This guidance represents the minimum standard of information we would expect donors to see to be able to make an informed decision to donate. All platforms should adequately address these points in an appropriate and prominent place before the individual commits to any donation. For example, before the ‘donate’ button is clicked.
In this guidance, we have used the word ‘must’ to indicate where a requirement is taken from the code. This guidance applies to both website and app-based platforms.
How much of each donation will reach the charity?
If you charge fees for hosting a fundraising campaign, you must make sure that certain details are clearly visible to people donating through your platform.
For example, if you charge:
- platform fees
- a proportion of the donation or Gift Aid
- payment transaction fees
- administrative fees; or
- monthly or yearly subscription fees paid by a charity or fundraiser.
You must display the following information before the point at which you ask for a person’s financial details.
- How your fee will be calculated. For example, as a percentage of the Gift Aid, a fee charged on each donation or number of pounds (or pence) of each donation.
- How much you will receive, if you know this at the time of the donation. If you don’t know the exact amount, give an example that demonstrates how much your organisation would receive on a £10 donation.
Where the fee is optional, you should make it as easy as possible for donors to donate for free, for example by including a ‘zero fee or tip’ option, giving equal prominence to this option.
All platforms should include a ‘fees and charges’ page on their website or in their app. As a minimum, this page should be clearly highlighted:
- on the footer links at the bottom of the platform’s homepage or clearly highlighted within the app.
- on the donation page or section before the point at which the donor commits to donating.
Information should be equally clear to the public, regardless of the device being used to access the platform.
Your ‘fees and charges’ page or section should include the following information to clearly set out how charges are levied on the donor and on charities, and how much of the donation reaches the charity. It should include a worked example based on a £10 donation, excluding Gift Aid.
- The status of the platform: whether, for example, the platform is a private company or charity.
- Gift Aid: the amount of Gift Aid that applies to the donation (normally 25p on every £1 donated), minus any fee taken by the platform.
- Administration fee: any fees levied on the donation by the platform for administrative purposes. This should include platform fees, payment processing fees levied by third parties, and any other fees taken from individual donations.
- Net donation: the total amount that goes to the charity or cause after deductions and the addition of Gift Aid.
In addition, you should include the following information:
- Setup costs: any cost charged to a charity for setting up an account with the platform.
- Cost per month: any monthly cost payable by charities for use of the platform.
- Interest arrangements: whether the platform keeps any interest accumulated while donations are in holding accounts (see also policies on donations to private bank accounts).
- Donors covering fees: whether the platform offers donors the opportunity to cover some or all the fees incurred.
You may add other details but we recommend that this core information is included in the order and format stated above. This will enable charities and members of the public to easily draw comparisons between platforms.
How can donors or fundraisers make a complaint?
Platform complaints procedures should be accessible, open and transparent. You should include:
- the scope and type of complaints that the platform can consider, and the scope and type of responses complainants can expect.
- How the platform will work with fundraisers to resolve complaints concerning specific appeals.
- Timescales for considering a complaint and any possible remedies, for example, an apology.
Clearly signpost to the appropriate regulatory body, such as:
- the Fundraising Regulator
- the Scottish Fundraising Adjudication Panel; or
- the Financial Conduct Authority (FCA)
if an individual is unhappy with the outcome of your response.
What is your policy on refunds and repurposing?
Sometimes a charitable fundraising appeal catches the public imagination, and the appeal far exceeds its target. At other times, an appeal might not reach its target.
Platforms must make fundraisers aware of what to do in these circumstances, including the need to follow charity law and regulations relating to refunding or repurposing donations.
You should include:
- whether and in what circumstances refund requests should be directed to the platform or the fundraiser.
- Whether the platform will allow a refund of the donation (where allowed in law) and/or any fees paid by the donor.
- In what circumstances a refund will be considered or automatically applied by the platform.
- Any criteria that the donor should be aware of in how the platform or fundraiser considers a refund request (for example, whether a refund is allowed in law).
- Whether and in what circumstances the platform charges a fee for processing refunds.
How are donations protected against fraud and money laundering, and how can donors be sure their contribution is being used for its intended purpose?
Platforms must take reasonable measures to avoid fraudulent activity and money laundering through their website or app.
If the money raised is not going straight to the bank account of a charitable institution, platforms must make it clear, before a donation is made, that donors give at their own risk.
Donors should have sufficient information to instil confidence that donations are protected against fraud and that the donation will be used for its intended purpose. Information provided by the platform should include:
- what safeguards the platform has in place to protect a donor’s money against fraud.
- what steps the platform will take if fraudulent activity is suspected.
- What happens to donations if the money is retained or recovered by the platform due to fraudulent activity.
- Confirmation that its payment services provider is regulated by the FCA.
What is your policy on donations to private bank accounts?
We recommend that all platforms have a clear and transparent policy regarding donations going to private bank accounts and set sensible limits to minimise issues regarding the transfer and administration of donations. Limits could include, for example, a maximum single or cumulative donation that can be given by an individual to a single cause, or a maximum target for personal crowdfunding campaigns.
It should be made clear to both donors and fundraisers what processing conditions and limits apply to donations. If the money is held initially by the platform:
- explain how this is held; and
- processes for sending donations to the recipient following the conclusion of an appeal, including timescales for transfer.
It is recommended that if funds are held by the platform, they are held in a ‘client account’ separate from the account of the organisation running the platform. This minimises the financial risk to funds raised if the organisation goes into insolvency.
You should also explain:
- what happens to any interest that may be accumulated on the donation while it is held.
- Whether there is a minimum and maximum amount that can be donated.
- Whether there is a cap on the maximum total amount that can be raised through a fundraising page.
- If no cap exists, what happens to the surplus money if a page raises more than the target amount.
The Fundraising Regulator has produced guidance for fundraisers setting up a page on a platform. You must:
- make sure our guidance is easily accessible for those setting up a fundraising page on your platform; and
- available before the point at which donation pages become active.
Platforms must also produce good practice guidance for those setting up a fundraising page on your website or app. This guidance must give fundraisers the information they need to plan an appeal to donors. You must include the possibility that a personal crowdfunding appeal may itself need to be registered as a charity with the relevant regulatory body. You should signpost the public to the appropriate charity regulator for the country in which they are fundraising.