FRSB complaints process for charities in Scotland and Northern Ireland

What are your obligations?

If you become a member of the Fundraising Standards Board (FRSB) self-regulatory scheme you will need to:

  • Nominate a complaints co-ordinator
  • Promote the Fundraising Promise wherever practical
  • Include the Fundraising Standards Board scheme logo on your fundraising materials (unless it is impractical to do so) and, where practical, the scheme strapline
  • State your complaints procedure in writing and/or on your website (if you have one) with an explanation of how a complaint can be made
  • Abide by the Institute of Fundraising's Codes of Fundraising Practice and the FRSB Fundraising Promise when fundraising
  • Endeavour to resolve fundraising complaints as promptly and as amicably as possible
  • Keep a record of all fundraising complaints
  • Make sure that your staff engaged with or supporting your fundraising understand your complaints procedure
  • In your annual review acknowledge your scheme membership, and, where practical, display the scheme logo and the website address of the Fundraising Standards Board
  • Complete and file with us an annual return about the number and nature of any fundraising complaints received within the period covered by the return

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What if you don't have an internal complaints process?

As a member we will supply you with a generic fundraising complaints process. This can be found on the members area of our website. This is intended to be a guide. You should adapt it so suit your organisation.

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What should your complaints process include?

Your complaints process should identify how a complaint can be made.

It requires your complaints co-ordinator to keep a complaints record containing the items below. If a complaint is received by the us at stage two of the complaints process, we will ask the member charity for this information.

  • A copy of the complaint
  • Details of the Code or section of the Fundraising Promise it is alleged has been breached [Note 1]
  • The date on which the complaint was received
  • A copy of all the communications with the complainant in connection with the complaint
  • Details of the investigation undertaken into the complaint

[Note 1: Complaints should be reported and referred to us if they are about a potential breach of any aspect ('must', 'ought' or 'should') of a Code of Fundraising Practice]

It requires your complaints officer to acknowledge in writing a complaint about fundraising within 14 days of receipt of the complaint

You will also be required to advise the complainant of the outcome of the investigation within 30 days of receipt of the complaint. In addition you will also be required to give them the opportunity to refer the complaint to the us at the Scotland & Northern Ireland office within two months of your response if they are dissatisfied with the outcome of your investigation

If a member of the public asks how to make a complaint regarding your fundraising activities, you are also obliged to provide the with a copy of your complaints procedure and the Fundraising Promise or, if they have access to the internet, details of your website. All this must be done within 14 days.

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How do we define a complaint?

In order to be clear about which complaints we will investigate (at Stage's 2 & 3 of the Fundraising Standards Board complaints process) we have provided the following definition:

The Fundraising Standards Board will deal with all complaints that are concerned with a potential breach of the Institute of Fundraising's Codes of Fundraising practice or a breach of the Fundraising Promise provided that the complainant has first directed the complaint to the charity concerned but is not satisfied with the answer received.

We will NOT deal with complaints that are not about good practice in fundraising. For instance:

  • Complaints about the services a charity provides
  • Administration and staff costs
  • Administration or processing errors
  • Retail complaints

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How does the complaints process work?

Stage 1 - A complaint is made to the member charity go to next step or A complaint is made to the Fundraising Standards Board, referred to Complaints Co-ordinator, Is the complainant happy? yes, no. -- If no - Stage 2 - Complaint referred to Fundraising Standards Board Scotland and Northern Ireland Office, Fundraising Standards Board Scotland and Northern Ireland Office seeks a resolution with all parties, are both parties happy? yes, no. -- If no, Stage 3, The complaint is referred to the Board of the Fundraising Standards Board, The Board upholds or rejects the complaint. End of process

Stage 1: The member charity attempts to reach a resolution

The complaint is received by the member charity and they attempt to reach a resolution. This can include the complaint being escalated to different members of staff within the charity if necessary as per their internal complaints procedure. If the Fundraising Standards Board Scotland and Northern Ireland office receives a complaint at this Stage, (ie.before the complaint has been through the charity's internal complaints procedure) they will refer the complaint back to the charity to deal with

Stage 2: The FRSB Scotland and Northern Ireland office seeks a resolution

The complaint has been through the charity's internal complaints procedure and the complainant is still dissatisfied and requires a further response. The complainant has contacted our Scotland & Northern Ireland office, within a two month time period after receiving the response from the charity. Once we have received the complaint, we will contact the member charity concerned to let them know and to get background information about the complaint (please see 'What should your complaints process include?'). Our Scotland and Northern Ireland office will investigate the complaint and seek a resolution with all parties concerned within 30 days. If the complainant is still not satisfied, they can seek adjudication by the FRSB Board (Stage 3 below)

Stage 3: The FRSB Board upholds or rejects a complaint

The complaint is referred to the FRSB Board for adjudication. They will review the complaint and report their conclusion within 60 days. The FRSB Board has the discretion to specify that either no further action is appropriate or to censure the charity and prescribe one or more sanctions.

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How do we judge complaints?

Our role is to ensure that charities and fundraisers are adhering to the Institute of Fundraising's Codes of Fundraising Practice and the Fundraising Promise, therefore this is how we judge complaints.

We will only be able to uphold a complaint if it is about a breach of a 'must' or 'ought' regulation contained in the Institute's Codes, or is a breach of the Fundraising Promise. In particular, 'must' indicates a requirement that is mandatory at law and 'ought' indicates a requirement that is mandatory within the Institute of Fundraising's Codes of Fundraising Practice and therefore for all members of the FRSB scheme.

The word 'should' used in the Institute's Codes indicates a course of action that is recommended as best practice, therefore we will not legislate based on these guidelines, unless there are exceptional circumstances. However, it is still important for charities to report and refer complaints to us that are about a breach of a 'should' guideline in a Code, so that they can monitor the effectiveness of them. For instance, if we receive a high volume of complaints about a breach of a certain 'should' guideline, we will advise the Institute of Fundraising of the situation, so that they can evaluate whether any changes or additions to the Codes are necessary.

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What can happen if the complaint is upheld?

If a complaint against you is upheld by FRSB Board, they will have the discretion to specify either that no further action is appropriate or to censure you and to prescribe one or more of the following sanctions:

  • You should apologise to the complainant
  • You should modify/improve your training systems or procedures to minimise the chance of a similar complaint reoccuring

In more serious cases or in the case of repeated complaints:

  • You should desist from using the fundraising method or the conduct that was the subject of the complaint
  • You should withdraw and/or reprint any fundraising materials that were the subject of the complaint

In the most serious cases or in cases where, despite being asked to desist from an unacceptable practice or take remedial action, you have continued with the unacceptable practice or declined to take the remedial action:

  • Your membership of the scheme will be withdrawn

For more detailed information, you can download the charity complaints process in pdf format.

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