Vulnerable People Policy – UK for UNHCR

Policy Purpose

We think it’s important to have a vulnerable people policy as part of our charity’s commitment to honest, fair and ethical fundraising. This policy outlines how we identify potential vulnerabilities, the measures we have in place to protect supporters in these circumstances and the actions we will take. This policy applies to all staff, volunteers, trustees and anyone acting on behalf of or in partnership with UK for UNHCR.

Introduction

Our supporters are incredibly important to us, helping us to realise our vision of a world where every person forced to flee can build a better future. UK for UNHCR is committed to making sure that our interactions with new and existing supporters are in line with our values and that people are treated fairly and appropriately. This is especially important when supporters demonstrate vulnerable circumstances. Four key principles underpin our approach:

Being respectful: being mindful of and sensitive to any particular need that a donor may have. It also means striving to respect the wishes and preferences of the donor.

Being responsive: as fundraisers we will adapt our approach and be flexible to meet the needs of individuals. It also means being prepared to ask questions or take additional steps when necessary.

Being fair: we will not make decisions based solely on a particular characteristics such as a person’s appearance, the way they talk, any medical condition, or disability. Fairness means responding to people as individuals.

Being accountable: we will take responsibility for our actions, ensuring we work in line with the Code of Fundraising Practice.

Our policy is informed by the guidance of the Chartered Institute of Fundraising, Treating Donors Fairly. UK for UNHCR is an organisational member of the Chartered Institute of Fundraising and is registered with the Fundraising Regulator. We are committed to upholding the Fundraising Regulator Code of Practice.

Definitions

Words and definitions matter, and it is important to us that we recognise that someone who needs additional care or support or who may be in vulnerable circumstances can have autonomy and the capacity to choose to donate to a charity. As such, we have chosen to avoid using the phrase “vulnerable person” as circumstance and context can leave a person especially susceptible to harm, affect their behaviour or decisions and change a person’s need for additional support or care when choosing to donate. For example, a recently bereaved person may be in a vulnerable circumstance following the death of a relative but this can change over a period of time. At the time of bereavement, they may have the capacity to make the donation but may require additional support or external advice to help with their decision.

Capacity to make a decision

Different situations and factors can affect an individual’s capacity to make a decision regarding donating. UK for UNHCR will communicate with supporters on the assumption that they possess the full capacity to make financial decisions unless we have reason to believe otherwise.

A supporter may experience some or all of the following circumstances:

A diagnosed condition such as dementia or schizophrenia
A person facing times of stress or anxiety (for example, following a recent bereavement or redundancy)
An undiagnosed or temporary mental health condition (such as severe anxiety)
Learning difficulties
Difficulty understanding the language
Being under the influence of alcohol or drugs

Please note that this is not an exhaustive list. We will look for indicators that could show a supporter needs extra care and support or may be in a vulnerable situation through our verbal and written communication with them. We may identify them using the following channels:

A supporter informs us that they need extra care and support around decision making and are in a vulnerable situation.
A family member, carer or person acting on a supporter’s behalf informs us that they need extra care and support around decision making and are in a vulnerable situation.
If we suspect that a supporter may be in vulnerable circumstances even though we have not explicitly been informed.

Our responsibilities

If we have sufficient reason to believe that a supporter is in a vulnerable situation and does not possess the required capacity to make a financial decision regarding their donation, we will immediately remove the supporter from all fundraising communications (electronic and physical) sent by UK for UNHCR3 until given notice to do otherwise. The supporter will also be removed from administrative communications that do not impact them directly, and any other unnecessary data processing. We will ensure that our database records this information as soon as possible and we will confirm and communicate this change to the relevant parties (the supporter, a family member, carer or Power of Attorney.)

We recognise that it may be difficult in some situations to decide whether or not someone is in a vulnerable circumstance or lacks capacity, but if we suspect that a person may be in vulnerable circumstances we will end the conversation immediately and politely, without:

making a request for a donation
asking about the individual’s capacity to make a decision or the existence of vulnerable circumstances

When dealing with supporters via telephone, we follow guidance provided by the Direct Marketing Association (DMA), specifically: we will only work with telephone fundraising professionals who agree and follow the DMA’s guidelines for call centres dealing with vulnerable consumers (August 2015). If we become aware of a situation where a third-party agency acting on our behalf has not acted in accordance with this policy, we may stop working with the agency or ask that individual fundraisers responsible for non-compliance with the policy be removed from our campaigns]

We will not process a donation if we believe that an individual lacks the capacity to make a decision regarding the donation.

If we process a donation and receive information or evidence after processing that the person was in a vulnerable circumstance and lacked the capacity required to make a decision about donating, we will refund the donation and confirm this refund in writing. We will immediately remove the supporter from all fundraising communications (electronic and physical) sent by UK for UNHCR until given notice to do otherwise. We will ensure that our database records this information as soon as possible and we will confirm and communicate this change to the relevant parties (the supporter, a family member, carer or Attorney.)

We will not process a donation if we believe that an individual lacks the capacity to make a decision regarding the donation.

Our response

We will always endeavour to do the following with an individual who we have identified/has been identified as someone who requires additional care and support or is in a vulnerable situation:

Be patient and calm, take time to understand the context and circumstances the individual is in, even if this prolongs the conversation
Check how the individual would like to communicate and offer alternatives that give supporters more time to take in the information being provided e.g. offer to send further details in the post/via email.
Ask the individual if they need more time or if they need to talk to someone else before making a decision regarding a donation.
Check the individual’s understanding of the information they have provided and what they have agreed to – for example by asking them to repeat this information back to us or by sending a further confirmation in writing before proceeding to process anything.

These steps will help us to ensure that the individual involved is safeguarded and is provided with the necessary time and tools to make an informed decision, if they are able to do so.

Family members / carers / attorney acting on an individual’s behalf

If UK for UNHCR is contacted by a family member, carer or attorney regarding an individual who they believe or know to be in a vulnerable circumstance, we may ask to see documentation before we carry out actions requested on that individual’s behalf to evidence that they have authority to act on behalf of the individual.

If, for example, they are concerned about a person who is receiving requests for financial support, we will act upon this, asking what kind of communication, if any, is acceptable. Our database will then be updated to reflect their wishes.

Other indicators of vulnerability

Age will not be treated as an indicator of vulnerability for an individual. We will take care when communicating with older supporters and ensure that we are conscious of other indicators (listed in section 3 of this policy) that may indicate an individual’s need for additional support or position in a vulnerable circumstance.

The only instance where we will immediately cease marketing communications with a supporter based on age is if we identify them as being under the age of 18, at which point we will immediately stop them from receiving fundraising appeals and calls. The exception to this is if we are approached by a young person who has undertaken community fundraising for us; we will thank them and communicate with them about their gift. We will also make a note that they are under 18 on our database.

Contact Us

If you require anything further, have questions or feedback regarding this policy, please feel free to contact our Supporter Care Team. They are available via phone on 0203 761 8094, Monday-Friday 9am-5pm.

You can email the team at [email protected]

You can also reach the team via post by writing to:

UK for UNHCR, UN Refugee Agency
1 Mark Square
WeWork
London, EC2A 4EG