‘Vulnerability may not always be obvious,’ regulator warns charities

Charities are being called on to factor in the UK’s ageing population and increasing rates dementia into their fundraising risk assessments.

The recommendation has been made by the Fundraising Regulator, which is concerned that vulnerable people with dementia may be targeted inappropriately by charities seeking donations.

“In the UK it is projected that by 2050 one in four people will be aged 65 or older,” states the Regulator in its Annual Complaints Report for the year ending March 2022.

“It is not right to identify someone as vulnerable just on the basis of their age but when combined with other factors, being older and in poorer health may indicate a person is more likely to be vulnerable.

“Dementia is an example that is often mentioned in our casework by concerned friends or relatives.”

The Fundraising Regulator reminds charities that dementia can affect memory, thinking and behaviour of people and “the signs and symptoms can change from day to day”.

“In a fundraising context, this means indicators of vulnerability may not always be obvious or even present during an interaction between a fundraiser and a potential donor,” it adds.

According to the World Health Organisation around 55m people globally have dementia, which is expected to rise to 78m by 2030 and 139m by 2050.

During 2021/22 the Fundraising Regulator received 15 cases where “the theme of vulnerable circumstances is explicitly mentioned”. This is up marginally on the previous year’s figure of 12.

These complaints were across a range of fundraising activities, including direct mail, advertising, in charity shops, collections, events, telephone fundraising as well as face to face pleas for donations.



Charities are also urged to be mindful of asking children for donations. While the Fundraising Regulator’s code specifies that charities must avoid asking for regular donations for those under 18, they can ask for one-off donations.

“However, not everyone will be comfortable with this and some parents or guardians may object on behalf of their child,” says the Regulator’s report.

“Also, fundraisers should be aware that what may not be considered undue pressure for most adults may feel different for a younger person.”

It adds: “The potential impact in this area can be significant, not only for the vulnerable person and their loved ones, but also the charity if this leads to a refund request or reputational damage.

“It is important that charities respond well when they are informed about a donor’s vulnerability, including after the fundraising happens.”

Misleading information complaints

The Regulator’s annual report also reveals that complaints around misleading information increased by 17%, from 60 in 2020/21 to 70 in 2021/22. In 30 cases this year complaints related to digital fundraising activity.

While most charities have returned to in-person fundraising activity post pandemic, including door to door collections, it is still below pre Covid levels “suggesting the sector may still be navigating the impact of this period,” said the Fundraising Regulator.

The number of complaints has increased in line with an increase in fundraising activity post Covid. However, the Regulator points out that the figures are still below 2019/20’s figures.

“The overall decrease in complaints made to charities since 2019/20, the most recent pre-pandemic year, is encouraging and a testament to the commitment that charitable fundraising organisations have to improving practices,” said the Regulator’s complaints and investigations committee chair Jenny Williams.

"We will continue to work closely with charities to support them in the areas of concern identified in the report and to ensure they are properly equipped with the tools to fundraise appropriately.”

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