Whilst the waters have yet to clear on the topic of wealth screening and prospect research, some excellent commentary and research is emerging to inform the way forward. Many people, myself included, find all this eye-wateringly boring, and would rather not spend hours dissecting the latest ICO rulings.
However, my observation is that many charities, and Trustees in particular, have become virtually paralysed with fear at doing ‘The Wrong Thing’. This can’t be good for the sector, or more importantly, for our wider purpose of raising funds to do good things in our society.
So here’s a round-up of some of the latest advice and information in the hope it may reassure, and provide fundraisers with some clarity on this otherwise difficult topic.
The view from a wealth screening agency…
Last week I attended an excellent seminar run by Prospecting for Gold . They offer wealth screening and prospect research services, so in some ways have a vested interest! But they also really need to know what they’re talking about.
The message coming through loud and clear is that wealth screening is not illegal and that it is still possible to research new prospects. The key point is that there is clarity for ‘data subjects’, i.e. your prospects and supporters, as to how personal data is going to be used.
Charities therefore need to review their practices around data, and ensure they have a well-worded privacy statement in place – this is essential. It’s not just about adding this as a footnote to your website either, but actively flagging up at the first opportunity and making supporters aware of it.
See here and follow the link under ‘information’ to their guide ‘Wealth Screening and Data Protection’
Evidence of public expectations
Another key matter is what public expectations are around fundraising, and whether screening and prospect research is genuinely a ‘legitimate interest’ for charities. There still appears to be some conflict here between the ICO and the fundraising community. A new report, ‘Good Asking’, commissioned by the IoF and written by Beth Breeze provides some useful evidence here as to why charities need to research supporter information.
Previous research by Beth Breeze and the Centre for Philanthropy also strongly supports the notion that major donors appreciate and actually expect fundraisers to have done prior research (e.g. ‘Richer Lives – Why Rich People Give’ by Beth Breeze and Theresa Lloyd).
Consent vs Legitimate Interest
If you want to get to the real nitty-gritty of what is meant by those two pillars of data protection – consent and legitimate interest – look no further than a comprehensive article by Adrian Beney of the More Partnership here.
This article also lead me to an excellent overall guide to Data Protection,Tim Turner’s ‘Fundraising and Data Protection – A survival guide for the uninitiated’. Although it’s lengthy at over 40 pages, this is one of the very few documents on data protection I managed to stick with, mainly because of Tim’s conversational, acerbic and often amusing style of writing.
How can small charities find their way through?
What I believe is most needed is a simple guide and check-list for small charities. Many recent articles on data protection contain suggestions for charities. However they often start with, ‘Read this hundred page document’, which just isn’t feasible for hard-pressed workers in small organisations.
Apparently, the Charity Commission is working on some simpler guidance, but perhaps we as a sector need to step up to this too.
To finish, here’s a quote from Peter Lewis, Chief Executive of the Institute of Fundraising, issued after the recent ICO fines for 11 charities for data protection breaches:
“Good charity fundraising is grounded in making connections between people and the causes that they care about. Understanding donors to find out more about what they’re interested in, identifying new supporters, and personalising how charities approach people ensures a better experience of charity fundraising for everyone. It’s equally important in helping to ensure that charities aren’t inadvertently approaching people who prefer not to hear from them. Rather than causing upset, we believe this is the approach to fundraising that many donors would like and expect charities to take…”