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Database screening and consent

Database screening and consent

When the Information Commissioner’s Office (ICO) fined The Royal Society for the Prevention of Cruelty to Animals and the British Heart Foundation last year, one of its findings was that the charities had screened their databases of supporters, but did not have their supporters’ consent to do so.

I find that surprising, and wonder if the problem was in the way that the charities sought consent.

In its “vision for a better future“, published in 2016, The National Council for Voluntary Organisations reported that the ICO’s Direct Marketing guidance advises that the safest way of demonstrating consent is by providing an unticked opt-in box for each specific form of marketing the charity wishes to use, as it requires a positive choice by the individual to give clear and explicit consent. If a charity undertakes database screening, it should make this clear in the fair processing statement, for example by making explicit use of words such as ‘profiling’, ‘targeting’, research’, and ‘wealth screening companies’.

I suspect the ICO is going to require charities to provide this kind of opt in when seeking consent. It will be interesting to see just how helpful the ICO’s planned (2017) educational event (in partnership with the Charity Commission and the Fundraising Regulator) will be.

Finbar Cullen, ResearchPlus

Finbar Cullen established ResearchPlus in 2005 to provide fundraising research services for the not-for-profit sector. He researches people, companies and grant-making trusts and foundations, mostly in the UK, but also other parts of the world. Finbar has published directories of “unpublished” grant-making trusts (registered with the Charity Commission and with the Office of the Scottish Charity Regulator), and each month he contributes to The Trust List, highlighting newly registered grant-making trusts worthy of particularly close attention.

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