This document sets out the procedure that must be followed to meet the regulatory requirements of the Fundraising Regulator (FR) and ensure a consistent, fair and timely investigation of all fundraising complaints.
Definition of a Complaint:
A complaint is any expression of dissatisfaction, whether justified or not, about any aspect of SSAFA. All complaints must be reviewed without bias.
Where Complaints Come From:
Complaints may come from any individual, volunteer or organisation who has a legitimate interest in SSAFA, including the general public if something is perceived to be improper. A complaint can be received verbally (such as in person at an event), by phone, by email, website webform, letter sent by post, or social media.. This policy does not cover complaints from staff, who should refer to SSAFA’s internal policy on such matters.
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Our policy:
• Provide a fair complaints procedure which is clear and easy to use for anyone wishing to make a complaint.
• Ensure everyone at SSAFA knows what to do if a complaint is received and feels confident about how to proceed.
• Make certain that all complaints are investigated fairly, in a timely way and without bias.
• That complaints are, wherever possible, resolved and that relationships are repaired.
• Use the information about complaints to learn and improve what we do.
• Publicise the existence of our complaints procedure so that people know how to contact us to make a complaint.
How a complaint can be made:
Complaints can be made by -
- Phone: 020 7463 9200 (this is SSAFA’s main switchboard number).
- Online: Submit a comment or complaint | SSAFA.
- Email: [email protected] (this mailbox is managed by the Supporter Engagement Team).
- Some individuals send their complaints to [email protected] or other email addresses featured in outgoing e-newsletters such as [email protected] and [email protected]
- Letter: SSAFA, the Armed Forces charity, Queen Elizabeth House, 4 St. Dunstan’s Hill, London, EC3R 8AD
Receiving Complaints:
Complaints may arrive through channels publicised above or via any other contact or opportunities the complainant may have, such as social media or in person at an event.
Complaints received by telephone or in person need to be recorded in the following way:
- Write down the facts of the complaint
- Take the complainant’s name, address and telephone number
- Note down the relationship of the complainant to SSAFA, e.g. donor, volunteer, sponsor
- Tell the complainant that we have a complaints procedure
- Tell the complainant what will happen next and how long it will take
Where appropriate, ask the complainant to send a written account by post or by email so that the complaint is recorded in the complainant’s own words
If a fundraising complaint is made to a volunteers or non-fundraising staff the details shown above should be emailed to [email protected] who will send to the Head of department of the relevant fundraising team for action. They will also log it on the FMC supporter database (currently SAVI).
*Refer to Response Guide to responding to Fundraising complaints for more information, and the Response Templates for letters or emails according to the nature of the complaint.
Resolving Complaints
Stage One
In many cases, a complaint is best resolved by the person responsible for the issue being complained about. If the complaint has been received by that person, they may be able to resolve it swiftly and should do so if possible and appropriate. Whether or not the complaint has been resolved, the complaint information should be passed to the relevant Head of department within five business days.
Complaints received should also be forwarded to Data Governance Manager by emailing [email protected]
On receiving the complaint, the Head of department records it on the FMC supporter database (currently SAVI). If it has not already been resolved, they delegate an appropriate team member to investigate it and to take appropriate action. If the complaint relates to a specific person, they should be informed and given a fair opportunity to respond. The Head of department will advise the Director of Fundraising about the complaint and inform on the action to be taken.
Complaints should be acknowledged by the person handling the complaint within five working days. The acknowledgment should say who is dealing with the complaint and when the person complaining can expect a reply. An abridged version of the complaints procedure should be attached. Ideally complainants should receive a definitive reply within a month. If this is not possible because for example, an investigation has not been fully completed, a progress report should be sent to the complainant with an indication of when a full reply will be given.
Whether the complaint is justified or not, the reply to the complainant should describe the action taken to investigate the complaint, the conclusions from the investigation, and any action taken as a result of the complaint. All communications to be logged under the complaint on the FMC supporter database (currently SAVI).
If the complaint has not been resolved at the end of Stage One, the complaint will be escalated to Stage Two. The Director of Fundraising, Marketing & Communications will be advised and will inform the Chief Executive Officer and/or COO.
Stage Two
If the complainant feels that the problem has not been satisfactorily resolved at Stage One, they can request that the complaint is reviewed at CEO/Board level.
At this stage, the complaint will be passed to the CEO, and they would apply their discretion on whether the complaint should be escalated to the Board of Trustees. The request for Board level review should be acknowledged within five working days of receiving it. The acknowledgment should say who will deal with the case and when the complainant can expect a reply.
The CEO and/or Board of Trustees may investigate the facts of the case themselves or delegate a suitably senior person to do so. This may involve reviewing the paperwork of the case and speaking with the person who dealt with the complaint at Stage One. The person who dealt with the original complaint at Stage One should be kept informed of what is happening.
If the complaint relates to a specific person, they should be informed and given a further opportunity to respond. Ideally complainants should receive a definitive reply within a month. If this is not possible because for example, an investigation has not been fully completed, a progress report should be sent with an indication of when a full reply will be given. Whether the complaint is upheld or not, the reply to the complainant should describe the action taken to investigate the complaint, the conclusions from the investigation, and any action taken as a result of the complaint. The decision taken at this stage is final, unless the Board decides it is appropriate to seek external assistance with resolution.
Fundraising Regulator
As SSAFA is a registered charity, the complainant can complain to the Fundraising Regulator at any stage. Information about the kind of complaints the FR can involve itself in can be found on their website at: https://www.fundraisingregulator.org.uk/more-from-us/resources/complaints-process.
Please note that SSAFA is also regulated by the Scottish Charity Regulator which covers activity in Scotland. If the complaint is associate with activity in Scotland the complainant can approach the Scottish Charity Regulator at any stage. Information about the kind of complaints the OSCR can involve itself in can be found on their website at: https://www.oscr.org.uk/about-charities/raise-a-concern/
Changes to the Complaints Procedure
The CEO and Board may update the procedure if deemed necessary. This may be necessary to avoid a conflict of interest, for example, a complaint about a Chair or Trustee should not also have the Chair and/or Trustee involved as a person leading a Stage Two review.
Monitoring and Learning from Complaints
Complaints are logged and reviewed annually. The complaints information is used to identify any trends which may indicate a need to take further action and to review any lessons learned.
Fundraising Complaints Reports
SSAFA is required to submit an annual return to the Fundraising Regulator setting out the number and nature of complaints received and the extent to which they were resolved. To complete it we need to know how many complaints we received per fundraising complaint topic in the previous calendar year. It is therefore paramount that the FMC Supporter database (currently SAVI) is kept up-to-date to ensure we can collate the data and access further information when necessary.
Guide to Responding to Fundraising Complaints
- How to record a complaint on SAVI
- Requests for Personal Data
- Types of fundraising complaints you may receive
- Response Templates
- Recording fundraising complaints on SAVI
First, find the relevant contact record on the FMC Supporter database (currently SAVI) and check whether the fundraising complaint has already been recorded. Complaints are recorded under Interactions.
If there isn’t a constituent/contact record you will need to create one. Update all relevant data fields (name and contact information).
Once a contact record has been created, add an interaction and complete all necessary fields:
Throughout the management of the complaint, a record should be kept on the Fundraising Supporter database (currently SAVI) of all developments and the details of any correspondence, including holding letters. As soon as the complaint has been resolved it should be closed on the database.
Complaints correspondence that cannot be managed in the supporter database can be saved in the following folder on S:drive - S:\CC and M\Fundraising\Due Diligence\Complaints
2. Requests for access to personal data
Requests for access to personal data (known as Subject Access Requests (SAR’s)) may come from an individual, third parties such as a parent or other relative, the police or via court order. In all cases advice must be sought from Data Governance Manager before any information is disclosed and they will inform on how the matter should be handled.
Please bear-in-mind that an individual or organisation has the right to access to any their records so always use appropriate language when documenting communications as they may see what has been written.
3. Types of fundraising complaints you may receive
Individual Giving and Legacy Fundraising
This team has the most contact with the general public via post, email, telephone and face to face fundraising; and consequently, may receive a higher volume of complaints, predominantly objecting to the fundraising methods used.
Complaints may arise from:
- supporter objecting to receiving what they deem is unsolicited communication.
- The individual may not be appreciative of the content in the communication they have received.
- unsubscribed from receiving e-newsletters but have received further communication.
- in the case of cold direct mail activity, individuals may complain about their personal information being shared and wish to find out how we obtained their details. Note: we do not upload cold data lists into CRM. This occurs only when the individual has engaged with the organisation by donating.
- member of public feeling that a face-to-face fundraiser was aggressive in their approach (this activity is carried out by third party agencies on SSAFA’s behalf.
These complaints, as well as details of the action taken in response, should be updated in the Fundraising Supporter database if applicable, and saved on SSAFA’s - S:\CC and M\Fundraising\Due Diligence\Complaints.
Challenge & Special Events
This team is responsible for running national challenge events and ‘special’ events. Complaints received are likely to relate to a specific fundraising activity or event. Any complaints are likely to come from donors/attendees dissatisfied with their experience and are investigated and responded to by the organiser of the event in question ensuring that complaints are recorded on SAVI and the Head of Events in notified.
Philanthropy and Trusts and Foundations
These two teams are responsible for high-value donations from private individuals, charitable trusts and military benevolent funds. Complaints can arise from donors perhaps not receiving thank you letters due to administrative errors or information requested not being received promptly. Any complaints are investigated and responded to by the team member involved.
Corporate Engagement
This team is responsible for our ‘charity of the year’ partnerships with individual companies and associated corporate events. It has less exposure to the general public and registered supporters; complaints received are few in number and are likely to relate to a specific corporate fundraising activity.
Trading and commercial participation
Complaints can arise from our trading operation including Christmas card sales and any cause-related marketing initiatives underway. They are handled directly by the responsible Head.
Complaints received via social media
Complainants via social media are informed that they can submit their complain via the web form Submit a comment or complaint | SSAFA or contact SSAFA’s Public Relations team about any serious complaint or allegation which is already on social media.
4. Response Templates
- Template for a holding response
With regard to your fundraising complaint, thank you for taking the time to contact us and bring this matter to our attention.
Please be assured that SSAFA takes complaints regarding any aspect of our fundraising activities very seriously and we endeavour to respond in a responsible and timely manner.
I am writing to confirm that we have received your complaint and have begun an investigation. We will be in touch again with a full response once the investigation is complete.
b. Template for response to a direct marketing complaint
Thank you for your letter regarding your fundraising complaint. I am sorry for the annoyance and inconvenience that our recent direct marketing campaign has caused you.
We take comments regarding all aspects of our fundraising activities very seriously and I would therefore like to explain why we send appeals of this nature to our supporters and the processes and problems associated with sending out large mailings.
Our direct marketing appeals are large scale, and the letters are written and presented in such a way as to generate the best response from a wide range of supporters. They are sent to hundreds of thousands of people nationwide, many of whom respond well to this type of approach and see it as a reminder to donate.
We do, of course, recognise that not all individuals like the direct marketing approach. The extremely important role of our supporters is recognised and we will always try to rectify their concerns.
One option is for individuals to opt out of direct marketing appeals; we always amend our records as soon as we are made aware of their wishes and have already made sure that you will not be contacted for future campaigns. However, as our appeals are arranged far in advance there is a possibility that you will receive a further letter. Unfortunately, we are unable to prevent this from happening. Should you receive anything please accept our apologies in advance and disregard it.
I hope that I have been able to address your concerns and would like to take this opportunity to thank you for your valued ongoing support.
Once again, please accept my apologies for any inconvenience caused.
c. Template for a request for further details regarding telephone fundraising
Thank you for your recent email to SSAFA.
I can confirm that we are currently in the middle of a campaign whereby we contact people via telephone to see if they would be prepared to set up a direct debit to support the work of our welfare services.
We are concerned to learn that our representative did not speak courteously when s/he approached you. This is something we take very seriously and will investigate.
In order to assist with our investigation, please could you provide the following details:
- the exact date and time of the telephone call.
- the nature of the campaign our representative was calling you about.
Please be assured that we only require this information to identify the representative concerned and take appropriate action. As soon as our investigation is complete, we will write to you again to let you know the outcome.
Thank you for bringing this matter to our attention. We look forward to hearing from you with the details above so we can investigate.
d. Template for a final response letter
With regard to your fundraising complaint, thank you for contacting SSAFA and bringing this matter to our attention.
Further to my email regarding your complaint of [insert date here] I am writing to you with the outcome of our investigation.
Please accept our sincere apologies for this incident and the offence caused; it was totally unacceptable.
We conducted our investigation with [insert agency name here if appropriate], which represents us on this campaign. The [insert fundraiser, person or representative as appropriate] who called you was identified and appropriate disciplinary action has been taken, resulting in [insert him/her undergoing further training/his/her removal from the campaign/suspension as appropriate].
[Insert agency name here if appropriate] has also expressed its sincere apologies, and we have requested that they remove your address from our activity list so that no one representing our charity on this campaign will call you again.
Our telephone fundraising campaign is a very successful and cost-effective means of raising money for our charity as we endeavour to meet the increasing demands on our welfare services to support our Armed Forces, veterans and their families; however, it must be conducted in the right way.
The [fundraising teams] who campaign on our behalf are aware that they are representing a well-respected charity and are always trained to be polite, friendly and respectful when responding to their refusals.
I am very sorry that the high standards of behaviour we expect fell short on this occasion and hope you will accept our apology.