Coronavirus (COVID-19): advice on fundraising from The Fundraising Regulator

Due to the outbreak of COVID-19, we understand that charities and fundraising organisations will be working in a challenging and changing environment. We know that many organisations will be making complex decisions, not only about their fundraising activity but what that means for future income generation and the important work they do.

We encourage all fundraising organisations to weigh up the benefits and risks of their ongoing fundraising activities and exercise judgement when deciding what is in the best interests of their beneficiaries, supporters, staff, volunteers and the public.

You should keep up-to-date with official information provided by the government that may affect your fundraising activity and prepare to review or stop your activity at short notice. You should ensure that any fundraising you continue to carry out (or decide to begin as a result of the changing situation) is legal, respectful, open and honest. This includes making sure that the government’s policies on social distancing are observed.

We will continue to update this advice as more information on the developing situation emerges. Please share this advice with your fundraising teams and contact us here, if you have any further questions.

Is it OK to keep fundraising?

Yes – at this time of crisis, charities still need to raise money – charity incomes have been drastically hit, and demand for services for many will be increasing. Charities will need to fundraise and many have already launched emergency appeals or developed new corporate partnerships. What is key is that fundraising continues to be carried out in a way that is respectful and follows the Code of Fundraising Practice. 

Person-to-person fundraising

Following the government’s most recent advice on social distancing, we advise charities to stop all person-to-person fundraising if they have not done so already. On Tuesday 23 March, the government outlined:

• restrictions on the size of groups which can congregate;
• restrictions on the number of times and reasons people can leave their homes each day;
• measures to safeguard vulnerable groups; and
• closure of all non-essential shops.

Failure to comply with these measures may lead to fines for organisations or individuals in breach. These restrictions mean that it would not be possible to carry out fundraising on the street, door-to-door, or through private site collections. These measures are in place to protect the public at large, as well as your own staff and volunteers.

If you have been working with third-party fundraising organisations on activities or campaigns that have now been cancelled, you should review your contracts and agreements as soon as possible to be clear about where you stand.

Direct marketing

If you intend to carry out direct marketing by telephone, email, text message or post, you must consider the following:

• Remind all fundraisers to keep to the principles set out in Section 1 of the Code of Fundraising Practice. In particular, fundraisers should be mindful that their behaviour is respectful and does not apply undue pressure, as people may be feeling unusually anxious at this time. Many people are responding to fundraising campaigns and are wanting to donate to help at this time of need. If you had previous campaigns and activity planned, it’s worth checking the wording, images, and messages to ensure they are still appropriate.
• Make sure you meet all standards in the Code of Fundraising Practice which relate to processing personal data. These can be found in Section 3. Other relevant sections of the code include:
  • 9: Fundraising communications and advertisements
  • 10: Digital
  • 4: Processing donations (if you need to adjust any payment processes)
• The Information Commissioner’s Office has released new data protection guidance to help organisations remain compliant with data requirements. Ensure your data protection officers are also up-to-date with this guidance.
• Observe any communication preferences that the individual has indicated to your organisation directly or via the Fundraising Preference Service.

Fundraising events

Under current government restrictions fundraising events which involve people attending an event venue would not be allowed.

Fundraising events which do not involve people gathering in one place may still go ahead, although we advise that charities are mindful of making sure these comply with government policy and guidelines. This would include making sure participants are fully aware of government regulations before they take part. Examples of events that could still go ahead may include fundraising through e-sports or gaming events, or virtual races which can be completed alone, for example, virtual races or meetups.

If you have recently had to cancel or postpone fundraising events you should consider the following points:

• Make sure you have contacted participants, volunteers and spectators so that they are aware of the changes to your event. Keep your databases and communications channels up-to-date so that you can contact people, and broadcast more widely, such as through social media, as appropriate.
• If you have cancelled your event, you may need to refund donations. Whether or not you need to will depend on the conditions under which the donation was made. For example, if money was donated on the condition that the fundraiser completes a marathon, donors should be asked if they are happy for funds to go to your organisation anyway, or if they want a refund. If there was no condition attached, for example the fundraising was carried out alongside someone’s marathon effort but without a condition of completion, then refunds may not need to be made.
• If the donations have already reached your charity, you may need permission from either the Charity Commission for England and Wales, Charity Commission for Northern Ireland or the Scottish Charity Regulator (OSCR), to issue a refund. You can find out more in Section 2.3 of the Code of Fundraising Practice.
• Section 11 (Events) of the code includes a section on event cancellation and contingency plans, including the possibility of refunding donations.
• If your event is postponed instead of cancelled, you should be clear with participants about the new arrangements. You’ll need to have things in place to work with people who can’t attend the new date, including refunding entry fees or offering alternative event entries as necessary.
• If your charity receives donations via online fundraising platforms, you should review their terms and conditions to establish what donors were told about refunds at the time of donating and what expectations they have set. If you have any queries about specific platforms you should contact them directly.
• If you need to cancel overseas events, you’ll need to know where you stand if you have paid up front for trips. Section 11.11 of the code sets out the key considerations, and make sure you keep in touch with the company organising challenge events on your behalf. If participants in your event are currently abroad, you can find guidance from the Foreign Office here.
• You should also review insurance policies you have for your events to make sure you know where you stand in light of cancellations or postponements.