Following its report yesterday into some charities’ alleged practices of sharing donors’ data, The Daily Mail today criticises animal charity the RSPCA for its use of data analysis to better identify donors who might leave a legacy. It suggested that the charity saw donors as ‘walking wallets’ and questioned how the charity used its donors’ data.
Under the front page headline ‘Revealed: how RSPCA snoops on wills of donors‘, the Daily Mail Investigations unit continues its analysis of the case of Same Rae, the 87-year-old charity supporter who is suffering from dementia.
The Mail claimed that “The RSPCA pays investigators to assess how much money donors might leave in their wills”. It added that Mr Rae was one of the charity’s donors who “was subjected to ‘legacy prediction'”. It described this in a sub-heading as “a disturbing new twist”.
A subject access request by Mr Rae’s son revealed that in 2007 “Mr Rae’s details were shared with one of the RSPCA’s data processors for the purposes of profiling against a legacy predictor model”.
Furthermore, in 2010 the RSPCA “shared Mr Rae’s address details with our agent, Prospecting for Gold Ltd as part of a database screening exercise”.
The RSPCA told The Daily Mail that it had processed Mr Rae’s data lawfully. At the same time it confirmed that it “had initiated a full review of the charity’s policies on the use of supporters’ data and data protection statements”.
The charity added that its “use of legacy predictions was common practice for charities and helped ‘to understand the make-up of our supporter base’.”
FRSB to investigate
The Fundraising Standards Board said that it would “fully investigate” “the charities exposed by the Mail”, although this sentence by the Mail seems to refer to the FRSB (and ICO’s) response to its article published yesterday. The FRSB has published no statement on today’s article by The Daily Mail.
Method of fundraising or issue of consent?
It is not clear whether The Daily Mail’s principle concern is with the practice of legacy profiling or the question of individual’s consent over use of their personal data.
It would appear to be both. The front page headline leads with ‘Revealed’, suggesting that data profiling of donors is a novelty to the reporters. The business practice of analysing and profiling consumers, clients and donors (presumably employed by The Daily Mail’s commercial teams) is well-established around the world. Many charities, especially those with a direct marketing programme of fundraising, have long sought to understand better their donors’ interests, preferences (in terms of communications received), and indeed potential to give.
Indeed, charities that did not make efficient use of their data could be said to be failing in their duties to the beneficiaries. Specifically, by not maximising income and minimising costs, trustees themselves could be accused of failing in their duty.
Certainly, The Daily Mail is raising the issue of consent. Again it subtitled its two-page spread again with ‘Your privacy for sale’.
It published a timescale listing what it says were the RSPCA’s contacts with Mr Rae from August 2005 to February 2015. This included 10 letters from the RSPCA in 2012, and three occasions on which the charity is said to have passed Mr Rae’s name to Acxiom Ltd, the data firm that provides similar profiling of charity donors.
Whatever the Mail’s prime concern, their wording is misleading. The RSPCA does not ‘snoop’ or otherwise investigate the ‘wills of donors’. A Will is a private matter and only becomes public once probate has been granted, after the donor’s death.
What it and many other charities do is to analyse donors’ giving histories and sometimes match it against other publicly available data – including news published in The Daily Mail (lottery winners could make good legacy prospects) – to work out whom it should present with what kind of fundraising ask, when, and for what amount. They, and for-profit businesses, are required to process this data under data protection legislation, plus other relevant laws.
To describe prospect research specialists like Prospecting for Gold Ltd as ‘investigators’ is misleading too. They and other firms and long-established, provide a demonstrable return to many charities, and save charities the cost of employing specialist staff. They use publicly available information and commercially published data from many sources.
Again, prospect research and legacy fundraising are both very well established elements of fundraising and generate substantial sums for charities. Any exploration of UK Fundraising over the past nearly 21 years will find coverage of legacy fundraising, prospect research and indeed Prospecting for Gold Ltd.
Response from RSPCA
Indeed, the RSPCA makes similar arguments in its defence. It points out that “more than 50% of donations to the RSPCA are made through generous legacies and so it is important that such forecasting takes this into consideration”.
It argues that “It is good practice that the RSPCA – like any charity reliant on donations from the public – plans for the future and forecasts its ongoing financial position”.
It adds that:
“Legacy predictor modelling is used by many charities and helps the RSPCA understand the make-up of our supporter base. It is not used to determine values of anyone’s legacies to the charity. We can assure our supporters that we use their donations effectively. For every £1 the RSPCA spends on fundraising we receive £3 back, which is used to rescue animals in distress”.
Fundraising methods criticised
Today’s publication adds legacy fundraising, prospect research and data analysis to the fundraising channels and skills that the Daily Mail and other national newspapers have queried and criticised this year. They join telephone fundraising, direct mail, working with specialist agencies, and the tone of some fundraising. Criticism of face-to-face fundraising seems to have taken a back seat while these investigations were being carried out.
Donor consent is the theme
In fact, apart from demonstrating a surprising lack of awareness of how over the past 20+ years some larger charities have adopted and adapted some commercial business practices to make their fundraising more effective and efficient, the one consistent theme of The Daily Mail’s investigations and criticisms is donors’ consent and understanding about how their personal data is used.
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