The University recognises that some people engaged with through fundraising activities may need extra support to make informed decisions about donating to the University of Bath. This policy outlines our obligation to people in vulnerable circumstances when undertaking fundraising activity.
The University of Bath is registered with the Fundraising Regulator and is committed to applying the Code of Fundraising Practice. This policy is informed by the IoF’s Code of Fundraising Practice and their guidance on Treating Donors Fairly.
1.1 Purpose of Policy
This policy outlines the University’s approach to fundraising with people in vulnerable circumstances, including how to identify if an individual may be in a vulnerable circumstance and what action to take as a fundraiser.
This policy applies to fundraisers and University supporters. Supporters are individuals connected to the University of Bath who may be contacted by fundraisers or other University staff about donating to the University. A fundraiser is not limited to those working in fundraising roles within the Department for Development and Alumni Relations. It could be any individual employed or contracted by the University of Bath who is communicating with supporters with a view to securing donations, even if that is not their primary role.
2.1 Identifying vulnerability
Vulnerability is complex and can be caused by a variety of reasons. Sometimes, but not all of the time, vulnerability can lead to individuals not having the mental capacity to make an informed decision. Vulnerability can be temporary, for example when somebody is experiencing stress or grief.
The below example indicators – though not exhaustive – may act as a guide for assessing whether a supporter is experiencing vulnerability: - any physical or mental-health condition the person may have; - any disability the person may have; - any learning difficulties the person may have; - whether the person is facing times of stress or anxiety (for example, following the death of a loved one or redundancy); - whether a donation is likely to affect the person’s ability to sufficiently care for themselves or leave them in financial hardship; - how well the person can communicate and understand what they are being told; - whether the person is under the influence of alcohol or drugs; - the person’s age.
2.2 What to do if you suspect a supporter is vulnerable
Fundraisers are reminded that they should be alert to indicators of potential vulnerability in every interaction with supporters. Not all supporters in vulnerable circumstances will lack the capacity to make an informed decision about a donation, and fundraisers should be equipped and ready to provide bespoke support where required. This might be through adapted communication, or by including friends or family of a supporter in discussion about a potential donation. Additional support and care is good fundraising practice and can help ensure the supporter is equipped to make an informed decision. However, as per the Code of Fundraising Practice, if a fundraiser knows or has reasonable grounds to suspect that an individual lacks capacity to make a decision about a donation, including under temporary circumstances, then the donation must not be taken. In cases where a fundraiser is unsure, they must ask their manager for a second opinion and approval to accept any donation.
If a donation is made and it is later realised that, at the time of donation, the supporter lacked the capacity to make an informed decision about their donation, then the University must refund the donation directly to the donor, or in some circumstances to a member of the donor’s family or a designated person. The donation return should be carried out in line with the Donation Return Policy.
If a fundraiser knows or has reasonable grounds to suspect that an individual is vulnerable, then the interaction with the supporter should be ended in a polite manner, protecting the supporter’s dignity. The fundraiser will ensure data protection policies and procedures are followed when recording interactions with the supporter. They will make sure that, where appropriate, supporters in vulnerable circumstances who lack the capacity to make informed decisions are not contacted by fundraisers in the future. They will also take care to ensure that supporter preferences regarding personal data are adhered to, for example setting temporary restrictions on communications to a supporter if they request this. Roles and Responsibilities
The Director of Development and Alumni Relations has overall responsibility for application of this policy. University staff fundraising on behalf of the University are responsible for ensuring they understand and apply this policy.
4 Related Policies and Procedures
Ethical Fundraising Policy Donation Return Policy Data protection policy and guidance
5 Document Control Information
Owner: Director of Development and Alumni Relations
Version number: 1
Approval date: 24 January 2023
Approved by: University Executive Board
Date of last review: