Last month the news broke that The Salvation Army had breached the Code of Fundraising Practice for direct marketing, specifically for contacting someone who should have been removed from its lists and for failing to properly manage the individual’s data.
The adjudication found that the charity had failed to act on a request made to receive only communications for its Christmas and Easter appeals, with the person subsequently receiving unwanted emails (albeit only three, but still three too many). The charity was found to have updated the complainant’s postal preferences, but not email.
This was the second time that the charity has been found in breach of the Code in the Fundraising Regulator’s adjudications. Back in September, the Regulator revealed that the charity had failed to act on requests from 83 people received through the Fundraising Preference Service (FPS).
Importantly, The Salvation Army isn’t alone in having failed to check and abide by supporter preferences. In March, the Fundraising Regulator announced that some 59 charities had failed to honour requests lodged with the FPS since the service’s launch.
Why are charities getting it wrong?
So when this is all mandatory under the Code and GDPR, why are charities still getting it wrong? Is it simply lax consideration of the rules? I don’t believe for a second it’s intentional, so is it a case of charities not being sufficiently equipped or skilled? And in failing to give focus to this area, are charities missing vital opportunities?
While most charities are well aware of their responsibilities when it comes to working with and managing data, it can be very easy to miss certain elements if your data is not joined up. The best way of ensuring that all individual’s preferences are kept up to date is to integrate all supporter data, from every data source and platform you use, into one single supporter view. By this I mean uniting all of your data on each individual: every communication you have with them through every channel and every department, every contact and purchase, and every personal detail and permission they’ve ever given you. Bringing all of this valuable data together into one place means it’s instantly accessible, and details aren’t so easily missed.
360˚ view is critical
Where data protection, and compliance with the Code and GDPR are concerned, having this 360˚ view of individuals is critical. And it doesn’t have to cost the earth to do this, there are many CRM systems that offer charity rates and various pricing tiers depending on the size of your organisation, as well as customisable and specialist options available.
In instances such as this, a 360˚ view makes it much easier to avoid breaching regulations. A good organisational-wide system enables all departments to record and access consent choices, and to ensure that when you interact or communicate with a supporter, every action is traceable. It also enables you to respond promptly to requests from individuals to see, transfer, amend or delete their data or to change their permissions.
Updating through cleansing, suppression and deduplication
And there’s more. Data also needs regular maintenance to ensure it remains up to date, and this means regularly verifying it with the basic data hygiene techniques of PAF cleansing, suppression and deduplication – including suppressing it against the FPS.
This is one area The Salvation Army said it would be focusing on in its response to the September adjudication. It promised to improve its internal data management processes: ensuring for example that its mailing lists are accurate by updating marketing data weekly with FPS suppressions and, importantly, that only experienced members of staff collate mailing lists.
So, a good data management system is essential but also key in getting compliance right and maintained is staff skills and training. Relevant employees and volunteers must be trained in how to collect and input data accurately, as well as how to manipulate and work with data. Since the December ruling, the charity says it has also updated the training for its donor care team and improved its systems to ensure email lists are re-checked shortly before being sent.
These are all important areas to focus on, and, if necessary, to invest in for data management compliance. But this is only what is required of charities.
Going beyond compliance
The beauty of going over and above ensuring compliance, is that there is valuable insight and real opportunities to be gained from all your teams being able to access and work with accurate and up to the minute data. Getting it right will not only help you avoid disgruntling and even losing supporters and breaching regulations, but a focus here will also enable you to target people more appropriately and build genuine engagement and trust. All of which will serve to improve loyalty and retention and fundraising results.
It really is time to go beyond ticking boxes to a more holistic data approach that can be embedded both physically and culturally across the organisation for long-term benefits.
Suzanne Lewis is founding director of Arc Data and specialises in helping not-for-profit organisations source, manage and understand their data.
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