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Effects of the Cost of Living Crisis on Charities

Group of charity volunteers

Charity Finances

The chief executive of a UK charity has been quoted as saying earlier this year that she expected soaring prices and falling real household incomes to have a worse effect on the fundraising income of charities than the pandemic. An economic think tank has said that it expects that, due to falling income and inflation, charity income will reduce by billions of pounds in 2022 and subsequently, and that as a result, charities’ reserves will shrink. Operating costs of charities have been rising, and these include, depending on the particular services provided by a charity, its costs of purchasing food, energy for heating and lighting, fuel for travel and delivery of services, and staff pay.

For some charities, it will be impossible to survive this crisis even if they do all they can to make cost savings and other changes. For others, they will survive but will be financially squeezed to an extent that they have never been before. The financial prognosis for charities is not looking good and it appears that for the remainder of 2022 and into the new year, the situation will worsen for charities and their beneficiaries.

Beneficiaries’ Needs

Against that background, however, more people are in need of the type of help that charities have hitherto provided, but will charities be able to cope with that demand? Charities’ beneficiaries are already suffering from the ongoing cost of living crisis, and that suffering is being aggravated by charities’ inability to provide them with the help that they need. The worsening financial pressures on the charity sector on the one hand, and, the increasing needs of existing and potential beneficiaries on the other, has created a perfect storm.

Staff Pay

Staff pay forms a substantial portion of many charities’ total operating costs. It is estimated by the Living Wage Foundation that over 14% of third sector workers are paid less than what it calculates is a “real living wage” (a figure which is higher than the legal minimum wage) but charity staff members need pay rises to keep their heads above water. However, charity pay levels are not rising in line with pay in other sectors simply because charities cannot afford such pay rises. Falling levels of fundraising from donations and events limit or prevent the ability to increase pay, and that means that charity pay levels cannot compete with pay levels offered by those other sectors. The result is that charities face difficulties when recruiting (and trying to retain) staff, and this in turn adversely affects the help that charities are able to offer to beneficiaries.

Trustees and Volunteers

Staff pay is not the only manpower issue: whether or not charities employ paid staff, many charities are dependent on input from volunteers and trustees. Those charities now face greater difficulty not only when recruiting volunteers and trustees but also in trying to retain them, due to the increasing financial pressures that existing and potential volunteers and trustees themselves are experiencing. It may be that this is tending to push actual and potential volunteers and trustees towards finding paid work rather than volunteering their time.

The Issue of Reimbursement of Expenses

A charity might adopt the practice of reimbursing expenses that volunteers and trustees incur on travel between home and the charity’s base as well as travel expenses incurred in the course of volunteering and carrying out trustee duties. If a charity reimburses such costs and expenses, that might help a charity attract and keep volunteers and trustees, but there nevertheless remains a problematic aspect where an individual uses their own vehicle.

A volunteer or trustee who uses their own vehicle might receive an allowance based on the relevant mileage driven by them, and charities, like any other organisations, will adopt a fixed sum per mile allowance that is equal to (or less than) the mileage rate set by HMRC for the purpose. If a charity or other organisation pays any volunteer or trustee at a higher rate than the HMRC rate, however, the excess over the HMRC rate is deemed by HMRC to be income in the hands of the individual receiving the payment and, as a result, subject to income tax. Therefore, in practice, charities will pay a mileage rate equal to the HMRC set rate, no more, no less.

The problem is that the HMRC rate was fixed in April 2012, and it has not yet increased to take account of inflation. (The price of fuel, running costs, insurance, and depreciation are all supposed to be covered by the mileage rate, but those costs have all risen considerably since 2012.)

The consequence for volunteers or trustees is that when they receive payment at that rate, they are not fully compensated for the cost of using their own vehicle. This is not conducive to encouraging individuals to join or stay with the charity, because many cannot afford or are unwilling to be out of pocket as a result of their work for the charity. A group of eleven charities wrote to the Chancellor in July 2022 about this problem, asking him to increase the HMRC mileage rate, and a petition to HM Government to the same effect ran until mid-August 2022. The trade union Unison considers that the rate per mile for use of a car or van should be increased from the present rate (45p per mile) to 59p per mile. At the time of writing, there has been no indication that there will be any movement on the HMRC rate.

Simply-Docs Expenses Document Templates

Amongst Simply-Docs’ numerous charity documents, there are a number of templates which are designed to be used to establish a charity’s policy on the reimbursement of expenses incurred by trustees, volunteers, and employees. They are accompanied by corresponding template expense claim forms. Together, these documents cover the whole range of expenses which a charity might reimburse:

Charities and Safeguarding

Recent High-Profile Safeguarding Incidents

This month we consider the important and sensitive issue for charities of safeguarding. There have been a number of fairly recent high-profile failures by charities to ensure adequate safeguarding. In early 2018, the Department for International Development called for assurances from aid charities in the light of the Oxfam scandal relating to its work in Haiti. In response, charities reported over 80 serious safeguarding incidents to the Charity Commission. Overall, in the weeks after the Oxfam scandal broke, more than 500 reports of serious incidents involving safeguarding were received by the Commission.

What is Safeguarding?

“Safeguarding” means taking a range of measures to protect people in a charity, or those it comes into contact with, from abuse, maltreatment or other harm of any kind. (This includes physical, sexual, emotional, discriminatory, institutional or organisational, financial or material abuse, neglect, or impairment of the health or development.) For a full definition of safeguarding, see The Care and Support Statutory Guidance issued under the Care Act 2014.

Charity Trustees’ Legal Duty

All charity trustees have a legal duty (“safeguarding duty”) to take reasonable steps to protect their charity’s beneficiaries, staff, volunteers, and those connected with the activities of the charity from harm. The Charity Commission has stated that safeguarding should be a key governance priority for all charities, regardless of size, type, or income, not just those charities working with children or vulnerable adults.

Adopting a Safeguarding Policy and Other Steps

The Commission has also stated that it is essential for charity trustees to have and implement a safeguarding policy and procedure.  Adopting and implementing a safeguarding policy and procedure assists charity trustees in discharging their safeguarding duty. With this in mind, we maintain a template Safeguarding Policy in our Charity & Non-Profit Group. In any event it is good practice to have such a policy.

Adopting such a policy is one of ten action points which the Commission recommends to ensure good safeguarding governance. The other action points include identifying possible risks, improvement of safety culture, communicating within a charity how to follow up any safeguarding concern, keeping safeguarding training current and relevant, and carrying out risk assessments. The Commission sets out these action points in more detail here, and we urge you to implement them if you are a charity trustee.

Safeguarding also entails other actions, including ensuring that trustees and others recruited to the charity are not disqualified from being appointed to the role in question, and that DBS checks (and enhanced checks) are carried out as appropriate.

More generally, trustees must make sure that their charity’s assets are used only to support or carry out the charity’s purposes. Trustees must not expose the charity’s assets, beneficiaries or reputation to undue risk.

Children and Vulnerable People

Safeguarding is a particularly important and sensitive issue for you as a charity trustee if your charity works with children or vulnerable people. People may use your charity to get to children, vulnerable people, or their records for inappropriate or illegal purposes. You must be alert to this and actively manage the risk that your charity may be deliberately targeted, that its culture may allow poor behaviour to take place, or that people in a position of trust may abuse this. It is also important to carry out checks on any organisation, including an overseas organisation, that has contact with children or adults at risk before your charity gives them funding.

What is Your Risk as a Trustee?

You can be held responsible for any consequences or loss that your charity incurs if you do not discharge your safeguarding duty. When the Charity Commission looks into whether there has been a breach of trust or duty, or other misconduct or mismanagement by trustees, it can take into account whether they followed safeguarding practice.

Prevention, Not Cure

Safeguarding failures can adversely affect a charity’s reputation but there is a built-in conflict of interest for charities in that they are bound to properly report serious incidents to the Charity Commission. However, if they do so and the full nature of the incident only becomes public knowledge because of that reporting, their reputation may be sullied and they can lose grant, donor, and other funding as a result.

Our message, therefore, is that prevention is better than damage limitation: if robust policies and procedures are implemented, the occurrence of such incidents is more likely to be deterred. This should produce, in terms of morality, the most important consequence, i.e. improvement in the behaviour of all connected with the charity. As a by-product, a charity’s reputation is preserved and its funding is not adversely affected.

Charity Trustees’ Conflicts of Interest

Trustees’ Legal Duties

The role of a trustee of any charity (“trustee”) is an honorary one, i.e. it is unpaid, and it is often supposed that trustees therefore have few or no legal duties. This is far from the actual position.

All trustees have numerous legal duties, as outlined in our Guidance Note on Charity Trustees’ Duties, Responsibilities, and Liabilities. For example, every trustee must not accept any personal benefit from being a trustee unless legally authorised, must act in the best interests of the charity, manage conflicts of interest, administer the charity properly, safeguard its assets, act prudently, act with care, act collectively, and ensure restrictions on funds are observed. In this post, we focus on one of those duties: the duty to manage conflicts of interest.

What is a Conflict of Interest?

A “conflict of interest” is defined by the Charity Commission in its 2014 guidance on managing trustees’ conflicts of interest as ‘any situation where the personal interests or loyalties of a trustee could, or could be seen to, prevent them from making a decision only in the best interests of the charity’ of which they are a trustee.

A conflict could arise where a trustee might gain a personal benefit in a situation, e.g. a financial benefit or pecuniary interest. It might instead arise where they have a competing loyalty to another organisation or person. A trustee has a “fiduciary” duty to their charity; this means that in law they have a relationship of trust and confidence with it which imposes a duty of loyalty. Case law emphasises that they must have “single minded loyalty” to their charity, i.e. it is exclusive, and not dilutable. An example of a conflict of loyalty would be where a trustee simultaneously holds a trustee role with another charity since that other role gives rise to the same duty to maintain “single minded loyalty”.

A conflict of interest between duties to the charity and some other interest can cover any type of duty, obligation, transaction, interest, situation, or receipt of information which creates a conflict with his duties as trustee.

Further, the trustee need not be the person directly gaining the benefit in order for them to have a conflict: if a person “connected” with the trustee may gain a benefit, this will also give rise to a conflict of interest for the trustee. Persons “connected” include family members, relatives, business partners, or businesses in which the trustee has an interest.

What is an “Interest”?

Here are some examples of categories of “interest” which (depending on the circumstances) might give rise to a conflict. These are only some examples, and something else may also be an interest although not covered below. The “person” below means either the trustee or a person connected with them:

  • • Current employment and any previous employment in which the person continues to have a financial interest.
  • • The person’s other appointments (voluntary or otherwise) e.g. trusteeships, directorships, local authority membership, tribunals. (Where, for example, they are also a trustee of another charity that is competing for the same funding, that would be a conflict.)
  • • The person’s membership of any professional bodies, special interest groups or mutual support organisations.
  • • The person’s investments in unlisted companies, partnerships and other forms of business, shareholdings exceeding the percentage set by the charity, and beneficial interests.
  • • Gifts or hospitality offered to the person by external bodies.
  • • Where the person uses, or cares for a user of, the charity’s services. (There would be a conflict in those circumstances where, for example, the trustees are discussing whether fees for service users should be increased.)
  • • Where the person has any contractual relationship with the charity.

There is no conflict of interest where a trustee also acts as a volunteer with the charity or donates money to it.

How Must Conflicts of Interest be Managed?

Trustees have a legal duty to manage conflicts of interest correctly, not a duty to avoid a conflict arising. We recommend that you familiarise yourself with the Charity Commission’s 2014 guidance on management of conflicts. It sets out a three-step approach as follows:

(1) Trustees should declare their interests.

Trustees each have an individual personal responsibility to declare conflicts of interest which affect them. Trustees should also provide a full disclosure on appointment of their interests which could potentially result in a conflict of interests so that consideration can be given to their suitability for appointment prior to their appointment. They should keep their disclosure updated at least annually and when any material changes occur. Trustees should also declare any gifts or hospitality received as a trustee that could potentially result in a conflict of interests – it is good practice for a charity to maintain a policy on the subject.

A trustee board should ensure that the charity has strong systems in place (including maintaining a register of the trustees’ interests) so that the trustees are able to identify conflicts of interest. The trustee board should have a standard agenda item for board meetings requiring trustees to declare any actual or potential conflicts of interest at the beginning of each such meeting. A trustee should declare any interest which he or she has in an item to be discussed at a board meeting, and should do so at the earliest possible opportunity, and certainly before any discussion of the item itself.

(2) Trustees should consider removing a conflict of interest.

They must consider the interest so that any potential effect on decision-making is eliminated. Where there is a serious conflict, the trustees may need to remove the conflict by not pursuing a course of action or by proceeding with the issue in a different way so that a conflict of interest does not arise or by not appointing a particular trustee or by securing a trustee resignation.

(3) Where trustees decide not to remove the conflict, they must instead prevent it from affecting their decision by following any specific requirements in the law or the charity’s governing document (i.e. its constitution) which deal with conflicts of interest and how they should be managed.

Trustees should also follow any conflicts of interest policy that the charity has adopted.  Alternatively, where there are no specific governing document or legal provisions, they must require a conflicted trustee to declare their interest at an early stage and, in most cases, withdraw from relevant meetings, discussions, decision making and votes, or they may consider updating their governing document to include provisions for dealing with conflicts of interest. They may instead, exceptionally, seek the authority of the Commission where the conflict of interest is so acute or extensive that following these options will not allow the trustees to demonstrate that they have acted in the best interests of the charity. Trustees should formally record any conflicts of interest and how they were handled, and must, if they prepare accruals accounts, disclose any trustee benefits in the charity’s accounts.

The Commission recognises that it is good practice for all charities to adopt and use a conflict of interest policy. We have included two template Conflict of Interest Policies in our Charity & Non-Profit Group for that purpose.

Consequences of Failing to Declare and Deal Properly with a Conflict of Interests

Where there is a conflict of interests which has not been properly managed, that will be a breach of the trustees’ legal responsibilities, and a trustee board decision made against that background could be contrary to the charity’s best interests or could impact negatively on its reputation, public trust or confidence in it. Such a decision could be legally invalid and/or challengeable.

The failure to manage conflicts of interest could result in a trustee having to repay the charity for any loss caused by their breach of trust, to account for any unauthorised benefit that the trustee may receive, or the reversal of a disposal of charity property where there has been a conflict of interest even though the trustee did not receive any personal benefit.

Comments on Conflict of Interest in Practice

Conflicts of interest can and do arise. It is a common issue especially in smaller charities.  The existence of a conflict in itself does not mean that anyone has acted improperly: it is how you manage it that is important.

Although the legal requirements relating to managing conflicts of interest should be understood and met by all trustees of all charities, it is all too common in practice that trustees overlook, and in some cases wilfully ignore, their duty to properly manage or avoid conflicts of interest.

Failure to deal with a conflict can easily often happen where a trustee has competing duties of loyalty between their charity and some other organisation. It is all too easy to overlook competing loyalties, and that may well be because trustees do not derive any personal (tangible or other) benefit where they have such a conflict.

Perhaps the best guiding principle that trustees should be aware of and follow is that a charity trustee can never serve two masters, and that the trustee board needs to be very wary even where in a particular situation they perceive that the conflict of loyalty that one of their number has poses a low or no risk to decision-making in the best interests of the charity.

A failure can also often happen where a trustee has a personal potential financial or measurable benefit, for example if the charity sells assets to a trustee or acquires assets from them, or pays a trustee either for their trustee role or for providing services to the charity, or employs a trustee or a relative of the trustee, or where a beneficiary of the charity is also one of its trustees.

Have you had any experience of a conflict of interest arising at your charity, and if so how did you deal with it? Have you ever contacted the Charity Commission for advice about a conflict of interest? We would like to hear about how your charity resolved a conflict of interest situation.

Technical Issues in Charity Law | Part Two

In Part One, we covered a number of technical charity law issues examined in the Law Commission Report of 14 September 2017. This note deals with further issues dealt with in that Report.

Making Regulation of Charity Land Transactions Less of a Burden

When a charity sells, lets, or mortgages its land, it is subject to restrictions and requirements (as explained in our Guidance Note: Charity Property Transactions). Compliance with these can give rise to substantial professional costs and can cause delays to charity land transactions.

The Report recommends that the current position, whereby trustees have a duty to obtain and consider advice before entering into certain land transactions, should remain. However, it notes that there is strong support for trustees to be able to have more flexibility in how they obtain advice about any particular transaction so that the advice is tailored to that transaction. It also emphasises the importance of guiding trustees to the right category of adviser and the desirability of them obtaining advice from a property professional.

The Report proposes modifying the existing advice requirements as follows. Where, currently, charities can only obtain advice from a member of the Royal Institution of Chartered Surveyors, the Report proposes that the category of advisers who may give advice should include members of the Central Association of Agricultural Valuers and fellows of the National Association of Estate Agents, all of whom have professional qualifications, are bound by professional conduct rules, and carry indemnity insurance. The Report proposes that such a property professional should be permitted to advise when the transaction is within their expertise, and that, to enable a charity to save costs, an employee or officer of the charity who is such a property professional should be permitted to advise.

Further, the Report recommends simplification and rationalization of what an adviser currently has to set out in a report in order that in future there is not only more flexibility but also receipt of advice that is more pertinent to the charity’s needs for any particular transaction.

The Report also proposes changes to the “certification” regime. Currently, if trustees dispose of charity land but fail to comply with the advice requirements, purchasers are protected if the trustees provide a certificate in the “completion” document stating that they have complied with the requirements. The Report recommends that the certificate should also be effective if is contained in a contract so that the purchaser is protected from the point of “exchange of contracts”. The Report also proposes that trustees should have power to let the charity officer delegated to sign the contract or completion document to also give the certificate. These changes should help avoid additional transaction costs for purchasers and make purchasers more willing to enter into land transactions with charities.

Other proposals include removal of the need to give public notice of disposals of “designated land”, relaxation of some of the requirements to obtain Charity Commission consent where the charity’s transaction is with certain “connected persons”, and changes to the Charity Commission’s guidance for charities acquiring land.

Improving the Position where there is a Permanent Endowment

The Report proposes not only making clearer the definition in the Charities Act of “permanent endowment” (i.e. property belonging to a charity that cannot be spent), but also making it consistent and more in line with the sector’s understanding of the term. It also proposes reform to the ways in which a charity may use its permanent endowment.

Allowing More Payments to Trustees

The Report recommends a new power for a charity to pay for a supply of goods to it by one of its trustees. This would be equivalent to the existing power to do so where a trustee supplies services.

Streamlining Incorporation and Merger

The Report identifies some problems arising from the law governing the merger and incorporation of charities, in particular in relation to transfer of property and gifts by will to charities that have merged. It proposes changes to the law to remove these problems.

Changes to Charity Commission Powers

The Report suggests changes to the Charity Commission’s powers so that it can, wherever appropriate, refuse to register a charity or refuse to register a change of name by a registered charity because of unacceptability of its name, or require a charity to change its legal or “working” name. At present its powers in these situations are unsatisfactory.

The Report also recommends that there should be power for the Charity Commission to confirm the appointment or election of a trustee where there is uncertainty as to whether a particular person was properly appointed or elected.

Procedural Changes in Legal Proceedings in the Charity Tribunal and the Courts

The Report makes recommendations for changes in relation to:

  • 1) authorisation to pursue “charity proceedings”;
  • 2) costs protection in the Charity Tribunal;
  • 3) suspending decisions pending a challenge; and
  • 4) the procedure for references to the Tribunal.

Your Experience

Will any of these proposed reforms be relevant to your charity? Do you think they will be beneficial for your charity or for other charities? As ever, we would like to hear from you.

Technical Issues in Charity Law | Part One

The Law Commission published a Report on 14 September 2017 on various technical issues in charity law, focussing on areas where there is inappropriate regulation of charities and any unnecessary legal complexity and inconsistency. It aims to remove or adjust the legal and regulatory burden on charities, whilst still safeguarding the public interest in ensuring that charities are properly run. (It does not also address high profile issues such as the law of public benefit, the charitable status of independent schools, or fundraising practices.)

The Report proposes a number of important changes to charity law. The draft Bill appended to the Report, when enacted, will bring those changes into effect. We have reviewed the Report and set out below a summary of those of its recommendations likely to be of interest to small and medium sized charities. For details of those recommendations, please see the Report (or a summary of it) on the Law Commission’s website.

Making it Easier to Make Ex Gratia Payments

The Report considers ex gratia payments out of charity funds. As we explain in our Guidance Note, Ex Gratia Payments by a Charity, an “ex gratia” payment is one which the trustees of a charity feel morally obliged to make, but which they have no legal power to make. For example, it might be clear from the circumstances that a testator intended to include in his Will a legacy to a family member but did not live long enough to amend his Will. In such a case, the charity’s legal entitlement to the residue under the Will would be greater than intended, and the trustees might therefore wish to pay such a legacy on a voluntary basis. The Guidance Note also details various other circumstances in which trustees might wish to make an ex gratia payment. (“Payment” for present purposes, includes a transfer, waiver or release of any property or rights.)

Charity trustees can currently ask the Charity Commission to authorise an ex gratia payment but if it is a small ex gratia payment, the costs of obtaining authorisation and the resulting delay before making the payment may be disproportionate to its value. The Report proposes amending the law to give trustees the power to make ex gratia payments that are small relative to the income of the charity without their having to obtain Charity Commission authorisation. Any payment is deemed “small” for this purpose under the Bill if it is no more than a certain amount and its gross income in its last financial year is no more than a certain amount, as follows:

  • ● £1,000, where gross income is up to £25,000;
  • ● £2,500, where gross income is more than £25,000 and up to £250,000;
  • ● £10,000, where gross income is more than £250,000 and up to £1 million; and
  • ● £20,000, where gross income is more than £1 million.

Trustees currently must personally take any particular decision to make an ex gratia payment, and they must only make a payment if they personally “regard themselves as being under a moral obligation” to do so; a subjective test. The Report proposes an objective test instead, namely that an ex gratia payment may be made if trustees “could reasonably be regarded as being under a moral obligation” to make the payment.

The Report proposes that, to ensure efficiency in charity administration, trustees should in future have power to delegate any decision to make an ex gratia payment wherever they wish to do so. With that power, they could then decide to make all such decisions personally or delegate any or all such decisions. Where any officer of the charity (e.g. the chief executive or a legacy officer) is delegated to make any such decision, the officer could then decide on behalf of the trustees if the objective test has been met. Where the test is met in any case, the trustees will have power (but not a duty) to make a payment.

For further guidance about ex gratia payments, see our Guidance Note, Ex Gratia Payments by a Charity.

Fundraising Appeals

Our Guidance Note, Fundraising Appeals By Charities – Suitable Wording for Appeals explains the current legal position where too much, or too little, money is raised by a charity in response to a fundraising appeal.

At present, where too much is raised, the Charity Commission can direct that the surplus is applied cy-près (“Cy-près” means “as near as possible”.); when too little is raised, the funds cannot usually be applied cy-près and the trustees must try to contact donors to offer a refund.

For small donations, the cost of contacting donors will often be disproportionate to the value of the donations. Where too little is raised, there needs to be a balance between protecting donors’ wishes and the administrative inconvenience and expense of contacting donors. The Report recommends reduction of that expense by amending current law such that the law does not require trustees to offer a refund of any donation of £120 or less in a year, and such that such donations can be applied cy-près. Trustees would only then have to try to contact a donor if he requested that when making the donation.

When funds raised are to be applied cy-près (because too much or too little has been raised by the appeal), trustees can currently ask the Charity Commission to make a scheme authorising the funds to be used for other similar purposes. In the case of small amounts, the charity’s and the Commission’s associated costs may be disproportionate to the amount in question. The Report therefore recommends amending the law so that, if a fund does not exceed £1,000, the trustees may apply it to new purposes without Charity Commission consent, provided that they first consider the desirability of securing that the fund is used for similar purposes.

Changing Purposes, Amending Governing Documents

The Report notes the importance of the ability to make changes to a charity’s governing document quickly and efficiently, whilst retaining safeguards so that any such changes are in the best interests of the charity and its beneficiaries. It concludes that greater alignment of the procedures currently available to corporate and unincorporated charities when altering their governing documents would be beneficial to create legal simplicity and consistency. It consequently recommends new powers for unincorporated charities to be able to make changes to their governing documents so that those powers are brought into line with those of charitable companies and CIOs. The Report also recommends that the same requirements for Charity Commission consent should apply to all charities, whatever their legal form, when they alter their purposes.

Your Experience

Will any of these proposed reforms be relevant to your charity? Do you think they will be beneficial for your charity or for other charities? As ever, we would like to hear from you.

Charities and Loss of Personal Data

One of the major risks faced by UK charities is loss of data. “Loss” includes wrongful transfer, disclosure, corruption, or deletion of data, or wrongful access to data. Charities often hold large amounts of personal data, some of which is particularly sensitive. It may relate to donors or supporters, beneficiaries or service users (including children and vulnerable adults) and their families, carers, staff, or volunteers of the charity. The range of personal data held by charities is often very broad. For example, it often includes bank details, details of donations made, contact details (home or email addresses, phone numbers), dates of birth, information about mental or physical health, or care needs.

How Does Loss of Data Occur?

There are numerous ways in which data may be lost. For example:

  • ● loss or theft of a laptop or memory stick containing unencrypted personal details;
  • ● hacking into IT systems to obtain such details;
  • ● hacking or a virus attack which corrupts or erases data, e.g. ransomware which in effect locks up data until a ransom is paid;
  • ● leaving paper documents in places accessible to thieves;
  • ● unauthorised disclosure by staff or volunteers;
  • ● IT system breakdown or destruction where there is no data backup or disaster recovery facility;
  • ● staff responding to forged emails purporting to come from a legitimate source.

 

High-Profile Examples

There have been some high-profile cases of personal data loss. A break-in took place at the premises of the children’s charity Plan UK in November 2015, when five servers containing data including supporters’ contact and bank information were stolen, although in this case it would have been very difficult for the thieves to extract that data. In March 2012, a hacker broke into the IT systems of the British Pregnancy Advisory Service and obtained sensitive personal data about their clients. In January 2016, volunteers at The Alzheimer’s Society used personal email addresses to receive and share sensitive information about clients of the charity, stored unencrypted data on their home computers, and failed to keep paper records locked away. The Society’s volunteers had not been trained in data protection, did not understand charity policies and procedures, and had little supervision. The Society also suffered a hacking incident in 2015, and in 2010 unencrypted laptops were stolen from its premises. In 2011, a social worker at the charity Norwood Ravenswood left a detailed paper report about four children at the side of a house in London after attempting to deliver them to the children’s prospective adoptive parents, and the report was stolen.

What Are the Consequences of Data Loss?

Loss may impact the charity’s own activities, for example, where a database of individuals’ details is deleted or corrupted, and the charity has no other record of them to use as a backup. Alternatively, loss may adversely impact the individuals who are the subject of data held by the charity, for example, where an unauthorized third party gains possession of the data. Apart from the direct financial cost (and other effects) of recovering from its data security being compromised, a charity is likely to suffer damage to its reputation and that may have an adverse impact on the level of donations and trust of donors, supporters, volunteers, and beneficiaries. Indirect possible effects include substantial fines being imposed by the Information Commissioner’s Office (ICO) where the charity is in breach of data protection legislation – the ICO is no longer reluctant to issue substantial fines to charities just because they are charities.

Increasing Risk of Data Security Breaches

It is clear that the risk of data falling into the wrong hands is prevalent and has been rising significantly over the past few years, both for charities as well as other organisations. Although the ransomware attacks in 2017 did not appear to target charities, experts think they could well be prime targets in future because of the large amount of sensitive stakeholder data that they hold – they often hold more sensitive data than other organisations, and personal data is often a saleable commodity. Charities are often seen as easy targets partly because they, more than larger commercial organisations, often lack the resources and expertise to guard against security breaches.

Tighter Regulation

The new requirements of the General Data Protection Regulation (GDPR), which comes into force in May 2018, reflect the degree to which a data breach is now regarded as a very serious issue. In particular the GDPR will require any organisation suffering a breach of personal data to report it to the ICO without undue delay unless it is unlikely to result in a risk to the rights of individuals.

How Can My Charity Prevent Data Loss?

It appears from a Third Sector Insight survey, conducted in 2016, that the majority of charities are not sufficiently well protected against loss of personal data. So, what steps do charity trustees need to take to improve the security of personal data? Here are some measures that might be implemented:

  • ● Review (“audit”) the activities of your organisation, identify weak spots, assess the risks and take steps to mitigate them.
  • ● Adopt a data protection and handling policy. Not only will this assist your charity to comply with the law, it will also confer a range of other benefits: adopting and implementing an effective data policy within a charity will protect your charity’s reputation, while also increasing donor, supporter, and volunteer confidence in the running of the charity. It will also, by making sure all information is kept accurate, save your charity time and money when you market to your fundraising base.
  • ● Appoint a Data Protection Officer to take responsibility for GDPR compliance.
  • ● Have procedures to detect, report, and investigate a personal data breach.
  • ● Make sure that all charity staff and volunteers are fully trained so that they understand their legal obligations (i.e. under the Data Protection Act (DPA), and, when the GDPR comes into force, both the GDPR and the parts of the DPA not repealed at that time). Training should be appropriate to ensure that they know in practical terms what they must do to comply with the law. For this purpose, you should adopt and implement procedures and organisational measures designed to meet the requirements of the legislation. New employees and volunteers should receive data protection training to explain how they should handle, store and transfer personal data. Existing employees and volunteers should be provided with refresher training every couple of years.
  • ● Make sure you use strong passwords on files and portable devices: a weak password, easily guessable, is very poor protection for personal information. Use combinations of upper and lower-case letters, numbers and (where possible) symbols in passwords (If you want to see how long it would take a computer to crack your password, try it out at How Secure Is My Password?).
  • ● Encrypt laptops, backup discs, USB memory sticks, and any other portable devices or media. Also consider installing a remote ‘wiping’ solution that will delete your hard drive in the event it is stolen.
  • ● Consider whether your IT servers (including email) and connected devices (on or off site) are as secure from unauthorised access as they reasonably can be.
  • ● Look at what data (in electronic or hard copy form) might be lost in transit or when staff and volunteers work remotely (e.g. at home), and ensure that your data policy and procedures extend to how they should deal with data not kept at all times within the charity’s office.
  • ● Ensure that when data leaves your charity, the most secure means is used (for example, use VPNs for electronic data and couriers for hard copies).
  • ● Only keep data for as long as necessary. Make sure your charity has established retention periods and has put a process in place whereby personal information is deleted when it is no longer required.
  • ● Implement a system to update information. If you can, ask those whose details are on your database to check and update those details. You can do this via email or by checking their details if they telephone you.
  • ● Make sure that your premises (and physical records and IT equipment there) are secure, that there are proper controls over who comes into the building, and that you know who (including staff, volunteers, cleaners, visitors) is able to and does enter your premises.
  • ● If you outsource data storage to specialists (larger charities may need to do so) then first check their data protection policies and credentials to ensure that they are trustworthy.
  • ● If you store personal or other data on your own systems (i.e. you do not use third party systems), then you would be well advised to frequently backup your data on separate media or secure cloud storage.
  • ● Adopt a data and/or disaster recovery plan, and consider including, as part of that plan, arranging for third party backup data centre facilities to be available so that you can recover data if you suffer an IT failure, data corruption, or a hacking incident.

 

What Are Your Experiences?

Are you a trustee or employee of a UK charity? Do you think your charity is well protected from a potential data breach? Does your charity follow the recommendations we have set out above? Has your organization suffered a loss of data, and what was the result? What should have been done to prevent that loss?

We are, as always, keen to hear your views.

Charity Fundraising and Data Protection

Damage to a charity’s reputation often diminishes the level of trust in the charity on the part of its donors and supporters, leading to a decline in funding. Reputation of a charity is a key influencing factor in a prospective donor’s decision to donate to that charity.

 

Damage to Reputation

Reputational damage can arise from a number of causes. For example, supporters might become aware of a serious incident which reduces their confidence in the charity. A serious incident at a charity might consist of fraud, theft, significant financial loss, abuse or serious harm of beneficiaries, links to extremism, investment in or support by an organization whose aims or activities are at odds with those of the charity, or loss of personal data (e.g. theft of a charity laptop containing personal details of beneficiaries, staff or donors, or the hacking of IT systems to obtain such details).

Improper Processing of Donor or Supporter Personal Data

Other matters can also adversely affect reputation, and in this post, we are focusing on one in particular: a charity’s failure to deal with donor/supporter data correctly. A number of well-known charities were recently fined by the Information Commissoner’s Office (ICO) for misusing donors’ personal data. Media coverage adversely affected not only the reputation of the particular charities involved, but also that of the charity sector generally.

The ICO found that the charities concerned had been using personal data of individual donors in ways which breached the Data Protection Act 1998 (DPA). The breaches comprised failure to be sufficiently transparent about the charity’s use of donors’ personal data, and failure to obtain their consent to that use of data. The charities had been sharing personal data with other charities, using personal data to estimate donors’ wealth (wealth screening), and using what personal data they had about individuals to discover missing information (data matching), all without being transparent or having consent from those donors to do so.

How Will the GDPR Affect Fundraising?

These issues have come increasingly to the fore because of the impeding implementation of the European General Data Protection Regulation (GDPR) which will require all organizations, including charities, to comply with new consent and transparency requirements that will be tougher than those under the DPA. If a charity fails to comply with those GDPR requirements, there will be a consequent decline in its reputation because people will tend not to trust it to deal properly with their personal information. That distrust will have a clear and direct adverse twofold impact on donations. Firstly, potential supporters/donors will be disinclined to donate to the charity (or even make contact with it with a view to supporting it in some other way). Secondly, current or past donors will no longer be inclined to donate, and they might ask the charity to no longer contact them and to delete their personal information. In order to ensure that donations to charities do not fall due to misuse of donor information (and to avoid the risk of substantial fines for breaching the GDPR) it will now be more important than ever that charities review their fundraising practices to ensure that they comply with the transparency and consent requirements of the new GDPR in relation to personal data of donors and others. The ICO has issued draft guidance on data protection and consent under the GDPR, and the Fundraising Regulator has recently issued a best practice guide, “Personal Information and Fundraising; Consent, Purpose and Transparency”, available here, designed to help charity trustees understand their responsibilities under the GDPR.

Even if a charity has met the transparency requirement to tell individual donors that they are processing their data, what it is being processed for, and any other information needed to make it fair to process the data, the charity also needs to establish a clear legal basis for using the data. We will not try to cover that in any detail here, but in general terms this means – depending on the particular circumstances – either having a “legitimate interest” for that use, or consent to that use. Where consent is required by the GDPR (e.g. for direct marketing by electronic means), it will be express consent that will be required. This will be stricter than under the current law, and as a result it is now a hot topic. The existing DPA consent requirements will be tightened up under the GDPR so that from May 2018, the data subject must have the right to withdraw consent at any time and it must be as easy to withdraw as it is to give, and consent mechanisms will need to be genuine and granular (‘catch-all’ consents will likely be invalid), and individuals must take affirmative action to provide their consent such as signing a form or ticking a box.

What Will be the Effect of Complying with the GDPR?

There are two opposing general attitudes to these changes, and we would like to hear your views about them.

One view amongst charities and critics is that those outside the charity sector (including legislators and regulators) do not understand fundraising and have approached it in a legalistic way without taking account of reality, with the result that the GDPR and the manner in which it is interpreted by regulators will lead to fundraising being destroyed in some charities. In particular, they see “opt in” (express) consent as leading to decline in fundraising because it requires a positive act whereas the normal tendency is towards inertia. The argument is that when one looks at the donor experience in practice, donors do not need or want to have to opt in, and they would be just as satisfied with an effective system that allows them to opt out of contact quickly and easily. Those against the new strictures of the GDPR also point out that the burden imposed by the GDPR on fundraising involves charities having to spend a great deal of time and money working on implementing strategies and processes to comply.

The opposite view is that the new requirements of the GDPR actually create an opportunity for charity fundraisers to increase donations and contact with supporters. The argument is that by complying with the GDPR, charities will actually improve and increase engagement with donors, and will build and strengthen trust amongst existing and prospective donors, and that this will outweigh the issues raised by those who take a negative view of the effects of GDPR on fundraising. The proponents of this positive view say that complying with GDPR will entail charities explaining why data is being collected and what it will be used for, that this can be coupled with an explanation of how the funds raised will be used, and that this will encourage individuals to “opt in” to being contacted and to allow use of their data in the way the charity has explained.

On which side of the argument do you stand?

Small Charity Funding: Is The Decline Reversible?

There are five major risks to the wellbeing (or even the existence) of small charities in the UK: decline in funding and donations, damage to reputation, inadequate insurance cover, loss of data, and fraud.

Funding

In this post, we are focusing on funding. Many small charities are in crisis due to lack of adequate income. On average over the past three years, when earned income, voluntary income and statutory income sources are placed together, it appears that small charities have only experienced a total overall growth of 3%. What can be done to improve the situation?

Voluntary Income

The charity sector relies heavily on voluntary income. The National Council for Voluntary Organisations (NCVO) found in 2016 that the overall trend for voluntary income is that it has been flatlining for some time. This has been the experience of small charities in particular. In a recent edition of a quarterly report produced by the Foundation for Social Improvement’s (FSI), it found that total voluntary income of small charities since 2013 has only increased by 1%. This is causing increasing difficulties for many small charities trying to bridge the gap between static income and a significant rise in the demand for their services.

Why Has Voluntary Income Not Increased?

A number of factors have affected voluntary income levels. Fundraisers at small charities are having to contend with an increasingly challenging environment. Although public trust in small charities delivering local services is still relatively high, as at mid 2016 there was a fall in public trust of charities’ fundraising methods to the lowest level since 2005 although there are now some signs that public trust is now growing). There is less disposable household income than in the past, and so a lower level of donations. Corporate donations have fallen. Many smaller charities find that their message is being lost due to larger charities presenting a challenge to their fundraising efforts. There is the potential for the economy to perform less well following the Brexit referendum vote with the consequent real threat that there will be a reduction in charitable donations. Regulation of fundraising has also become tougher, and trustees’ responsibilities in relation to fundraising activities are now greater.

What Has Happened to Other Forms of Income?

Over the past three years, charities’ statutory income has dropped by 8%. Since the 2008 financial crisis, small and medium-sized charities have lost substantial income from central and local government in the form of both grants and contracts. With voluntary income of small charities remaining static or falling in some cases, many are struggling. Some small charities who have been reliant on statutory income find that their voluntary income does not sufficiently compensate for falls in their statutory income. An increasing number of small charities are having to dip into reserves in order to continue their day to day work. This trend is worrying, especially in view of the fact that a substantial proportion of small charities do not hold any reserves.
However, in contrast, over the same period the level of charities’ earned income has increased by 9%. Charities’ earned income includes fees for their services and also income from selling goods or services to raise money.

Increasing Small Charities’ Income

So, there is a need to increase income of small charities across the UK. How can they achieve an increase, and which type(s) of income can they realistically increase?

Data seems to indicate that in comparison to larger charities, small and medium-sized charities have proportionally lost more of their government income and gained less income from individuals, and they can expect to see little rise in income from donations or government.

However, small charities have increased their earned income very significantly. Although this has not been enough to cover all lost income from government, it has replaced some of that shortfall. Between 2007/08 and 2014/15, across all of the charity sector earned income from the public grew 35% while donations from the public grew only 6%. According to NCVO analysis, earned income is the best prospect for future growth.

Are small charities trying to increase their earned income? Should they try to do so further? Will they be able to do so?

It appears that some charities – especially those which have seen no increase in government funding – have set out to alter their approach to generating income. For example, charities have developed partnerships with other charities or merged with other charities, and some have made use of financial mechanisms such as social impact bonds and creation of social enterprises. Increasing earned income may involve setting up a trading arm of a charity, market research, upskilling finance and other staff, and taking greater commercial risks. It might be a new type of activity or service or it might be selling services to the public using existing expertise already used or developed within the charity.

For some charities, “earned income” is now a major part of their total income, but for smaller charities, i.e. those more likely to have lost voluntary or statutory income, it may be difficult to establish and maintain an earned income stream especially where they lack the necessary skills and resources.

What has been your experience?

Personal Liability of Charity Trustees

The House of Lords Select Committee noted in its recent Report “Stronger Charities for a Stronger Society” (March 2017, available here) that registered charities in England and Wales with an annual income of less than £100,000 make up almost three quarters of the sector.

These smaller charities contribute significantly to the wellbeing of the nation, but, given the voluntary nature of trusteeship, charities have for some time found it difficult to recruit suitable trustees. It is worth noting that the average age of trustees is 57 and rising, half of all charities have vacancies on their boards (with many struggling to fill those vacancies), the age and gender profiles of trustee boards differ significantly from those of wider society, and the recruitment problem is being exacerbated by trustees being overburdened with responsibility or regulation.

The Growing Burden of Regulation

As the Report found, being a trustee has become more challenging: the environment for charities has changed substantially (particularly as a result of increased financial pressures and significant shifts in funding models), and there are also additional legal and regulatory requirements to comply with, such as new data protection regulations and fundraising standards. The Charity Commission noted in evidence to the Select Committee that navigating these challenges required “strong strategic leadership and the ability to take managed risks; we see many boards failing to rise to the occasion”.

Lack of Knowledge of Trustees’ Roles & Responsibilities

Evidence submitted to the Select Committee indicated that many new and existing trustees were not really familiar with the role, its requirements, and responsibilities (although, following the collapse of Kids Company, trustees have become more conscious of their responsibilities). This is a problem for small and medium sized charities (as well as for some larger charities) since, irrespective of the size of a charity, the role of trustee (although an honorary position), carries with it legal duties, responsibilities, and potential liabilities, and crucially, trustee boards need to have both the necessary knowledge of their legal responsibilities and the necessary range of skills between them to enable them to carry out their responsibilities correctly.

Additional Risk of Personal Liability if Your Charity is Unincorporated

Against this background, we are concerned that trustees of small and medium sized charities often bear a potential risk over and above the risks and responsibilities borne by trustees of larger charities. This stems from the fact that rather than being set up in a corporate form (e.g. as a company limited by guarantee or as a CIO), smaller charities are more likely to be set up as “unincorporated associations” or “trusts”. As we explain below, this increased risk arises from the lack of “separate legal personality” that a corporate form provides.

Whether a charity is in corporate form or it is an unincorporated association or trust, failure of a trustee to discharge his/her governance liabilities is a personal liability of each trustee (“breach of duty” or “breach of trust”) and any resulting loss to the charity is the trustees’ personal liability. Where a trustee has acted honestly and reasonably, the Charity Commission is less likely to enforce that personal liability. Trustees will also have personal liability if the charity is insolvent and they have engaged in wrongful or fraudulent trading, or if they fail to file certain documents, or they breach certain health & safety, environmental, discrimination, tax, or other laws.

Where the charity is incorporated, its liability for debts and other liabilities incurred by it (for example, to suppliers or staff) remain its sole liability even if it has insufficient assets to meet the liability – its trustees will not also be personally liable. Establishing a charity in incorporated form will therefore mitigate potential exposure to personal liability of trustees for a charity’s debts and other financial liabilities. There has been a growing trend towards use of incorporated vehicles for charities. The usual form is the company limited by guarantee but charities may also use the CIO form introduced by recent charity legislation.

Compare this to a charity which is an unincorporated association or trust: its trustees might also incur personal liability due to the activities of the charity (i.e. not due to their own conduct as trustees). For example, a charity might provide services to a local authority, or hold a lease on premises, or employ staff. In each case, the charity will have a legal relationship under which it could become liable to another party. The trustees might also become personally liable as a result of that liability of the charity (even though they may personally have acted properly) since they are in effect the organisation and they can be sued as individuals. All liabilities of their organisation will be theirs, but they will normally not be ultimately liable (i.e. the liabilities will be met out of the assets of the charity). However, if the charity does not itself pay a debt or some other liability of the charity, and it has insufficient assets to meet liabilities, the trustees could be personally liable to the extent of the shortfall. Although it is rare, it is not impossible for trustees of an unincorporated charity to be held personally liable in this way for the activities of their charities. This was illustrated in a recent decision of the High Court in the case of Chandra v Mayor (2016) where it was affirmed that each member of an unincorporated charity’s trustee board was personally liable for the charity’s wrongful dismissal of an employee.

Should There Not Be a Level Playing Field for All Charity Trustees?

Trusteeship carries important responsibilities and that message needs to be clear. Against this, there is a need to encourage volunteers to take up trustee roles since, as the Charity Commission points out, volunteer trustees play a vital role in a sector that contributes significantly to the character and wellbeing of the country. So, if many people consider that it is reasonable to remove the potential for personal liablility of trustees arising solely from the fact that their charity is unincorporated rather than incorporated, shouldn’t legislation be introduced to protect trustees from that personal risk?

We would like to hear from you on this. Do you feel that, to remove this risk from their trustees, charities should have to go to the trouble and expense of incorporating, and then incur the ongoing additional trouble and expense attached to maintaining a corporate entity, given that most charities have very limited resources? Should there not instead be a simple piece of reforming legislation which has the effect of removing this inequality between incorporated charities on the one hand and unincorporated charities on the other hand? Your thoughts, as ever, are encouraged and welcome.

Should You Run a Charity Like a Business?

To remain financially stable in today’s competitive climate, a charity needs to run its operations with business-like standards.

Just like a business, many not-for-profit organisations have a board of directors, executives, human resources personnel and a marketing department. So why run a charity differently from a business just because the goals are different?

Successful not-for-profit organisations have strategic plans, keep financial records and have audits, so it’s important to invest in key aspects of the charity, just as you would with a business, to help it make a difference.

Importance of effective strategies

When a business is doing well, consumers realise the value of purchasing its products or services. When a charity is doing well, donors enjoy seeing the rewards of doing something good. A charity needs a competitive, effective strategy to help it support its beneficiaries. Typically, charities have less resources and capital for investment so, in a way, it’s even more important for good business sense to play a role.

The not-for-profit sector must ‘do more with less’ in every way, so needs to think differently to be more innovative and creative with what it has. In order for charities to experience business growth, sustained quality investment to promote their goals and values is crucial. A charity’s success should be measured by how its investments help it to raise more funds and do increasing amounts of good work. Charities should work to a set of standards that include leadership, transparency and results.

Streamline operating processes

The best way for charitable organisations to save on running costs is to work towards achieving streamlined processes with well-trained leaders, as spending vast amounts of money on staffing is not feasible and can eat away at funds better spent elsewhere. To this end, charity leaders could benefit from taking advice from small businesses; something that many may not even consider because they have never viewed themselves as a business.

As with business investors, charity investors wish to see the results of their investment. To produce a sustained and strategic impact, charities must be run like a business, with strategy, discipline and a strong focus on outcomes.

Be accountable

Any organisation receiving charitable support must be as accountable to the donors as a company’s board is to the shareholders. In a way, the donors are the stakeholders and therefore should be able to understand the ‘return’ on their investment.

Otherwise, they may feel as if they’re throwing their money into underperforming organisations that aren’t spending it in the most effective manner. Anyone who supports any cause has the right to expect effective strategies and efficient operations to put their money to best use.

For example, if an organisation is seeking to provide greater community amenities, it can prove the impact it’s having by counting the number of wells it has built in central Africa, or the number of playgrounds provided for poorer inner-city areas.

Management skills

Management skills are often as important as technical know-how. Trustees should search for chief executives who have the right qualities and skills to lead their organisation. Charities can benefit greatly from the experience of managers in the field who can make qualitative judgments based on comparing costs with benefits.

Putting the focus on efficiency and outcomes will work for any type of charity, no matter who the beneficiaries are. Whatever the mission, there must be a balance between expenses and revenue, with goals being set so that funding will continue.

There’s no aspect of running grass-roots and charitable movements that won’t benefit from a disciplined approach. Adopting sound business principles will make a charity more likely to accomplish its goals.

Overcoming sector challenges

It’s not always easy for charities to think like businesses. Due to the nature of the causes they support, some may find it more difficult to show clear, measurable goals. However, that doesn’t mean they shouldn’t try, as they owe it to the donors, managers, the board, the beneficiaries and the employees to adopt the best strategy possible to achieve their aims.

In today’s technical age, when the internet has made it easy and inexpensive to collect data of all kinds, anyone who is passionate about a charity’s work has more options to find out how it’s performing. Collecting data can measure results, enabling the charity to improve its performance.

Metrics should be seen as useful tools, rather than shackles. They can improve the effective use of money, time and people. A dream with a firm plan behind it has a better chance of becoming a reality.

Skilled people at the top

Today’s charities are a far cry from those that started life in the Victorian era to help impoverished sections of the community. In reality, many of today’s national and international charities resemble multi-million pound businesses, with funding coming from many quarters. As such, the managers should possess the skills to run an organisation of this size.

Charities must focus on squeezing the best value out of every pound that’s donated. By stripping out unnecessary administration costs and streamlining operations, efficiency savings can equate to more money being donated to those who need it.

Long-term focus

Strong leadership and effective business acumen are transferable skills that can benefit not-for-profit organisations. Some new charities fail within a relatively short period of being launched. In order to have a sustainable, long-term impact, a charity must focus on achieving its intended outcomes and also making a surplus.

Otherwise, it will be extremely difficult to continue operating, because in addition to fundraising for your cause, expenses must be taken into account, such as salaries, bills and other running costs. It’s crucial that finances remain steady because, however worthwhile the cause, if it’s being run by someone who can’t balance revenue and expenses, it’s going to end up in debt and will fail. Just like in business, it all comes down to maximising efficiency by having a good strategy, business-minded people in control and strong discipline to work towards a goal.

How can we help? Simply-Docs have a wide selection of ready-to-use document templates designed to help charities run more efficiently.

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