National Deaf Children’s Society: June 2023

Name and type of organisation: National Deaf Children’s Society (registered charity no. 1016532)

Fundraising methods: Door-to-door and private site fundraising

Code themes examined: Vulnerable donors, pressurised fundraising, monitoring third parties, complaint handling

Code breach? No

The complaint

Over a 12-month period the Fundraising Regulator received 13 complaints about National Deaf Children’s Society (the charity) fundraisers going door-to-door or fundraising on private sites such as town centres. Some common themes were:

  • applying excessive pressure to donate
  • ignoring ‘no cold calling’ signs; and 
  • failing to identify or respect potential donors’ vulnerabilities. 

Some complainants raised concerns about the length of the charity’s complaints process and being unable to progress their complaint.

Our aim in this investigation was to take a wide view and identify whether NDCS had appropriate policies and processes in place. We found individual complaints were appropriately handled, so these were not material when considering whether NDCS's overall practices had breached the code.

What happened?

One complainant told us they were unhappy with the outcome of NDCS’s formal complaints process, after progressing through five stages. Another complainant told us they had struggled to progress their complaint. Both cases related to older people who were potentially vulnerable, which prompted us to ask for more information. 

We felt that NDCS’s complaints process was overly long and onerous. NCDS also told us it had identified an issue where emails to its complaints team had not been delivered, which meant we were concerned there could be wider systemic failings.

Our decision

As a large national charity, NDCS’s fundraising activities are extensive and it partners with several professional fundraising agencies working across the UK. NDCS supplied estimates of the total numbers of people its fundraisers interacted with and said complaint numbers were very small in comparison. We accepted that the scale of its fundraising operations meant errors would sometimes occur.

Donors in vulnerable circumstances

In two complaints, we found that fundraisers had breached the Code of Fundraising Practice (the code) due to a failure to consider the needs of people in vulnerable circumstances.

  • A fundraiser knocked at a home displaying a ‘no cold callers’ sign and asked for donations. They claimed they had realised their mistake and had waited for an answer to be polite. 
  • A fundraiser called on a vulnerable older person and remained there until a neighbour contacted the person’s relative, who drove to the property to ask the fundraiser to leave.

In each of these cases NDCS accepted the complainants’ version of events and responded appropriately by investigating, identifying the fundraisers, taking steps to prevent the problem reoccurring, and communicating this to the complainants. In response to one complaint, it put a new policy in place that it would only start direct debits from older donors after speaking to them by phone to confirm they understood and were happy to donate regularly. 

In these cases, NDCS had not breached the code in relation to complaints handling.

Monitoring third parties

We looked more widely at how NDCS monitored fundraisers working on its behalf. NDCS demonstrated that:

  • its third-party fundraisers received thorough training based on the code
  • it had measures to monitor fundraisers’ performance and respond appropriately to problems by re-training or removing individuals; and
  • it kept records of these actions to prevent an individual from continuing to work with it under a different agency.

We found that NDCS had not breached requirements to train and monitor third parties fundraising on its behalf and ensure they follow the code.

Complaints processes

We considered NDCS’s wider complaints handling processes and reviewed its complaints log. This satisfied us that:

  • NDCS assumed complaints were made in good faith and responded appropriately
  • while some complaints took significant time to resolve, most were concluded promptly
  • complaint responses were consistently thorough and appropriate; and
  • specific actions were taken in response to themes emerging from complaints. Examples included instructing its agencies to remind fundraisers of the importance of respecting ‘no cold-calling’ signs, and adopting a ‘two-strike’ policy for those who did not. 

We concluded that NDCS had not breached the requirement to respond to complaints promptly and fairly and had not breached the code standard requiring it to learn from complaints.

While not in itself a breach of the code, we had some concerns about the length of the complaints process, which had five stages, each of which could take up to five weeks. NDCS explained that the latter three stages assessed whether it should make wider changes in response to the complaint. While none of the complaints we saw took this long to resolve, we remained concerned that the process was unnecessarily difficult. Especially as we typically only consider complaints once the complainant has exhausted the organisation’s own procedure.

Code sections considered

Code of Fundraising Practice, version effective 1 October 2019 (last updated 4 June 2021)

  • Standard 1.2.1: breach identified
  • Standard 1.2.2: breach identified
  • Standard 1.3.7: breach identified
  • Standard 1.3.9: no breach identified
  • Standard 2.4.2: no breach identified
  • Standard 2.4.3: no breach identified
  • Standard 2.4.4: no breach identified
  • Standard 5.2.3: no breach identified
  • Standard 7.3.1: no breach identified
  • Standard 8.1.1: breach identified
  • Standard 8.1.2: unable to determine
  • Standard 8.1.3: no breach identified
  • Standard 8.1.8: no breach identified
  • Standard 8.4.1: no breach identified
  • Standard 8.4.3: breach identified
  • Standard 8.4.14: no breach identified


We recognised that in two cases, individual code breaches had negatively affected the complainants. We considered that NDCS had responded to them fairly and adequately. As a result, we didn’t make any further recommendations.

NDCS told us that it expects to update its fundraising complaints process in the near future, and is offering a streamlined process in the meantime. We recommended it makes the option of the streamlined process clear to potential complainants, and informs us how the process has been changed once its review is complete.


NDCS agreed to comply with our recommendations.