International Liberty Association: September 2022

Name and type of organisation: International Liberty Association (registered charity no 1160607) 

Fundraising method: Face-to-face fundraising 

Code themes examined: Vulnerable donors, fundraiser behaviour and complaints handling processes 

Code breach? Yes

The complaint 

The complainant contacted us about International Liberty Association (ILA, the charity) on behalf of their parent, who has dementia. The complainant was concerned that their parent had been targeted by the charity for donations. 

What happened 

The complainant contacted the charity to advise that they held Power of Attorney for their parent. The complainant asked the charity to delete any information about their parent and to stop contacting them. The complainant told the charity they were aware of three large donations that their parent had recently made to the charity and that this was completely out of character. The complainant also said that they considered that their parent, who had dementia, was a vulnerable person who had been targeted by the charity. 

The charity responded to the complainant’s concerns and confirmed that they had removed their parent’s details from its contact list. It thanked the complainant for bringing the matter to its attention and confirmed that it would investigate what it could learn from the complaint. The charity did not at the time address the complainants’ specific concerns about it targeting their vulnerable parent. 

The complainant replied to the charity to advise that they were disappointed with this response as they had concerns that it had used “heavy-handed tactics to extract money” which is not in line with the Code of Fundraising Practice. They explained that the charity had visited their parent at home and asked for £12,000, claiming that other people had donated larger sums. The complainant considered that this was unacceptable pressure to donate. The complainant told the charity they would therefore seek to recover their parent’s donations.

The charity explained to the complainant that their parent had a long-standing relationship with the charity. It explained that its fundraisers are prohibited from taking donations during home visits and that their parent had sent the donations in by post some time after they were visited at home by the charity’s fundraisers. The charity also explained that its fundraisers had not been able to detect any signs of vulnerability when they had visited or spoken to the complainant’s parent. It also said that the complainant’s parent attended charity events before the pandemic and talked with trustees who were also unaware of any vulnerability. 

The charity confirmed to the complainant that given the chronology of the events, and after talking to six volunteers who had been in recent contact with the complainant’s parent, it had concluded that its fundraisers had not breached the code. The charity was confident that the complainant’s parent had appeared in full control of their affairs and decisions. To support its decision, the charity sent the complainant copies of its recent correspondence with the complainant’s parent.

The charity believed it therefore did not have the authority to return the donations. It said to the complainant that if they insisted on the return of the donations, they would need to take legal action, in which case the losing party would be expected to pay legal costs. On receipt of the charity’s response the complainant escalated their complaint to us. 

To assist with our investigation the complainant provided us with evidence of their parent’s diagnosis that the charity had not had sight of. 

Our decision 

We looked into the how the charity investigated the complaint, such as its record of interviews with the volunteers and trustees that had interacted with the donor and its correspondence with the complainant’s parent. We also considered that at the time of making the donations in question, the complainant’s parent had been living independently and had attended two charity events on their own. Based on the information provided by both the complainant and the charity we did not find that the charity missed any key indicators of vulnerability and on this basis did not breach the code. 

We did not find that the charity’s volunteers acted in a way that was either unreasonably persistent or placed undue pressure on the complainant’s parent to donate. The charity therefore did not breach the code in respect of these concerns. We also found that the charity responded to the complainant’s concerns promptly and attempted to investigate. 

We acknowledge that at the time the complainant raised their concerns with the charity they did not provide it with evidence of their parent’s diagnosis. Yet, by mentioning the possibility of legal action if the complainant continued to challenge the charity’s decision not to refund the donations, it was not acting in a fair and proportionate manner. On this basis, we found that the charity had breached the section of the code that relates to complaint handling. The charity has recognised that the tone of its final response to the complaint was not appropriate and may have come across as intimidating. As a result of our investigation, the charity has made improvements to its complaints process. 


We recommended that the charity considers if the improvements it has already made to its complaints process are sufficient and fully implemented. It should ensure that the learning from this investigation informs its complaints handling going forward.

We recommended that a discussion about learning from this investigation is added to the agenda of an upcoming board meeting and that we are provided with the relevant section of the minutes to evidence this discussion.


On receipt of medical evidence that the complainant’s parent had been diagnosed with dementia, the charity approached the Charity Commission for England and Wales to ask permission to return the donations in question.