10/02/10
The Public Fundraising Regulatory Association is pleased to welcome the Institute of Fundraising’s revised code of practice on Face-to-Face Fundraising and its associated guidance on Cold Calling Control Zones (CCCZ).
The main change to the code relates to fundraising in CCCZs and sets out a four-step process that charities conducting all types of door-to-door fundraising (including cash and lottery sales – which are not regulated by the PFRA – as well as direct debits – which PFRA does regulate) must abide by.
- Fundraisers ‘ought’ to check if fundraising is permitted in a CCCZ before they visit
- If it is not they ‘should’ check with local trading standards officers whether it has been set up according to the ‘spirit’ of Trading Standards Institute (TSI) guidance* on CCCZs
- If a CCCZ has been set up legitimately, fundraisers ‘ought’ not call
- If a CCCZ has not been set up according to TSI guidance, or fundraisers are unable to obtain sufficient information from local trading standards, fundraisers may cold call in that CCCZ but ‘should’ carry out a reputational risk assessment first.
The code of practice also says that charities ‘should’ develop an approved policy on fundraising in CCCZs.
[In the context of an IoF code of practice, ‘ought’ signifies something that is mandatory for IoF members, whereas ‘should’ signifies something that is best practice but not mandatory.]
PFRA endorses these revisions, which reflect guidance that PFRA issued to its members in February 2007. This recommended that members always ask council licensing departments whether there is a CCCZ in operation for the areas for which they are seeking a licence. In the 2007 guidance, PFRA also advised its members that, as CCCZs are not legally enforceable, fundraisers are within their legal rights to enter a CCCZ. However, we also said that if a CCCZ had been set up “correctly” – i.e. according to TSI guidance – then members should “seriously consider” observing the CCCZ for operational reasons (because a legitimate CCCZ will be in place for reasons such as to protect the elderly or minimise distraction burglaries) or because of the “potential for reputational damage”.
The revised IoF code now strengthens our requirement that PFRA members “seriously consider” observing correctly-instigated CCCZs to a requirement that they do so. PFRA is happy to endorse that change.
However, it remains true that PFRA members are entitled to enter wrongly-constituted CCCZs provided they have conducted a risk assessment.
PFRA will now work with members to develop pro-forma policies and risk assessments on fundraising in CCCZs that members will be able to adapt to their specific requirements, and to develop a map of properly constituted CCCZs that PFRA members can access.
* Trading Standards Institute guidance on CCCZs
- CCCZs should only be considered when supported by a “real” local need to stop sellers/callers – such as to prevent distraction burglaries, protect the elderly from bogus callers etc
- The size of a CCCZ should be “relatively small” and “easily defined by its boundaries”, such as a cul-de-sac, small estate or neighbourhood watch area.
- The CCCZ must have the “wholehearted support” of residents. Consultation with residents is the first step.