Database screening and consent
Howard Lake | 16 January 2017 | Blogs
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
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About Howard Lake
Howard Lake is consultant editor of UK Fundraising. He founded the site in 1994 and successfully sold it in 2022. As director of Giving X Ltd he is exploring growing giving on a massive scale.
He is the founder of Fundraising Camp and co-founder of GoodJobs.