Why 18?

Why do we say that strategic donor (‘major donor’) programmes take eighteen months to break even? It’s a number I have heard again and again, and that I repeat when I am teaching strategy at the Postgraduate in fundraising at the University of Barcelona, without having hard data to back up the claim.

To find an answer, I have been experimenting on myself. Since January 2017 I have been working a few days a week with Pallapupas, the healthcare clown organisation in Catalonia. I’m their strategic donor fundraiser. I thought, with the arrogance of years of experience as a consultant and researcher, that – ha! – this was going to be easy. In six months, I thought, we’ll fix this and I can sit back and watch the money roll in.

And here we are, almost eighteen months later and now, after a lot of blood, sweat and tears, now we can see the money starting to roll in.

So why? Why does it take eighteen months to get to the tipping point in a strategic donor programme? I have worked with many different programmes across Europe, but there are common threads in all of them:

You, and Me

Fundraising shines a bright light on your own character. So I have learned, in the last 18 months, that I am no blooming good at cold calling by phone (OK, I am doing it in my second language, but that’s no excuse); that I really enjoy building networks of people and sometimes focus more on that than on the money; and that I develop relationships with people over time, not at speed. All of these factors help explain why it takes me time to reach breakeven.

But this is not some embarrassing confessional. I’m illustrating the point that each of us who takes on a strategic fundraising role brings our character to play – and that affects how long it takes to reach the moment when the programme is up and running.

The Case

Many European NGOs are starting strategic donor programmes after years of running mass-marketing, mail- and email-driven, fundraising programmes. They have had years, therefore, of making offers to donors like ‘with €10 a month you can save a life.’

So the first challenge for the new strategic donor fundraiser is how to build a case for €10,000, or €100,000, or €10m. That is an enormous leap for many organisations. Some of them back out, building middle donor programmes with asks in the hundreds, not the thousands of Euros.

Making the case means putting together a budget, making a business plan, winning buy-in from colleagues and key staff, and producing a convincing elevator pitch. All of which takes time…and more, if you hit problems with the Project Pipeline, or the words.

The Project Pipeline

Does the organisation have €100,000 projects? Or €10m projects? Or dreams at these levels of funding? For many organisations this is a challenge. The project pipeline does not exist – there is no ‘deal flow’ in investment terms – so there is nothing for the fundraiser to propose to her prospects. Sometimes, in large, complex organisations, you can see the projects but they are distant and hazy, and there are 30 layers of stakeholders between you, the fundraiser, and the project. You know it is going to take an age to cut through the jungle.

Even when you can see the projects, you need permission to use them. In some organisations this can take a long time. In others, it’s a race to own a project before another colleague grabs it to pitch to her favourite donor.

The Words

When you join an organisation as a new fundraiser, you have to learn that organisation’s language. Some of this is technical language – of the type you would use in a medical research organisation for example – and some of it is an adaptation to the language of your end-users or beneficiaries, as happens when you shift from talking about ‘people with disabilities’ to ‘people with different abilities.’

Your choice of words is sensitive, and more so when you are working with strategic donors because you will be working alongside the board and the director, both highly tuned to the right words. Eighteen months in, and I am still learning how to paraphrase the mix of culture, theatre, humour and hospitalised kids that typifies clowns in healthcare.

The Data

Too many organisations in Europe have too little data. We know so little about our donors. Yes, data protection and privacy are key issues, but your local supermarket knows more about you, your interests, your attitudes and your wealth than the biggest organisation that you donate to. Many organisations don’t know what jobs their donors do, what age they are, or anything about their family situation. Without this data we are working in the dark.

Compare this to the private banks, who are increasingly entering the HNWI and UHNWI area to offer philanthropic services. I spoke with the head of philanthropy at a leading private bank (50,000 clients, 500 account managers) a few weeks ago; he told me that because he can see the banking account details of his clients he knows exactly which charities they are giving to, and can work out which causes the client is interested in. He can offer philanthropic services (including channelling money via the bank’s own foundation) precisely tailored to that client’s needs.

Because they have too little data, many organisations have to focus on the tiny handful of prospects whom they know directly, via personal contacts. So instead of broadening their strategic donor programme to reach the hundreds of existing donors who have the money, they rely on the tiny inner circle.

That means lower productivity, a limited focus, and slow programme growth – because growth is organic, person-to-person.

Systems

Our systems don’t just slow us up, they can clog us up. A simple system problem – when, for example, the donor database does not talk to the accounts system, or where the two use a slightly different coding system – can mean that we have to manually re-enter data. Or it can mean that searches for a donor’s history are a headache.

Sometimes it is the thank-you system. I have worked with organisations that have an automated process for sending out thank-yous of the ‘Dear Sir/Madam Thank you for your gift of €xxxx [fill in number]…’ type. So Madame LaRiche, who has just sent you half a million, gets a ‘Dear Sir/Madam…’ letter and there is nothing you can do to stop it. It takes time to persuade the I.T. team to change their ways.

These are stupid niggles in the system. But they slow us down. Or more likely, catch us out just when we think we have a programme ready to go.

Leadership

You have produced the case, sharpened your elevator pitch, identified potential donors and built a workplan. But you need the leadership to be engaged if this is going to work. You need their buy-in because you want to work with them and their contacts, but also because you and they are going to have to take some tough decisions (this ALWAYS happens with strategic donor programmes); should we work with that potential donor? What do we do when a prospect offers us a lot of money…to do the project he wants, not the one we want?

“Bring in leadership from the start.” Yes, that is what the textbooks say. But making that happen in real, busy lives where people have a load of other priorities, takes time.

Reporting, and donor stewardship

This is going to happen after you win the new donations and partnerships. But you simply have to get this sorted out before you meet your first prospect. Bench-test the process with your colleagues so that you understand every potential glitch on the way. Your donors and partners want to see the numbers, the stories, the videos and the pictures of ‘their’ project. So if that information is going to be hard to collect because your field office is hard to reach, because you need special permission to use this or that photo, or because the impact report is still being compiled, then either find alternatives, or wait until the material is sorted out.

So that’s why it takes 18 months

Because you need to get all of this moving at the same time, involving players right across your organisation, from the chair of the board to the lab technician or assistant field worker. In amongst all of these threads of action is a critical path, the line you must follow in order to achieve your goal. But when you are new to the organisation, you simply cannot know where that path lies, nor where the potholes are that are going to slow you down. You have to learn, to listen, to find all this out. And that takes time.

Inside, not Outside

None of this is the market, or the culture of philanthropy – the reasons most commonly cited for the time it takes to get a programme to maturity. These are all internal reasons – stuff inside the organisation, combined with your own character traits, that limit your speed of action.

Faster?

Are there shortcuts? Could we be working faster? In hindsight, you can see that there are. But the problem is that you can’t get to the hindsight until you have put time behind you. Getting leadership onside early certainly speeds up the process, in part because it opens doors to stakeholders in technical, financial and communications departments. Quick work with the case – especially, building and testing case documents internally to get buy-in – is also a help. But neither of these routes is going to shave a lot off your timescale.

So I have learned to set expectations, right from the start. To say ‘eighteen months’ in the knowledge that that is how long it will probably take, but also in the hope that the break-through will come sooner.

Chris Carnie is the author of ‘How Philanthropy is Changing in Europe’, published by Policy Press.

New power, new conversations: the IFC report

The International Fundraising Congress is – I declare my interest as a volunteer – the world’s best fundraising conference. Each year in October around 1,000 people from over 60 countries gather in a conference centre just back from the beaches of the North Sea, west of Amsterdam. It’s a buzzing, active gathering of leaders, new thinkers, experts and innovators…and runs the best end-of-conference dance party I’ve ever attended.

This year’s theme was ‘A New Conversation’. It was about linking fundraisers with the social and environmental causes they promote, about activism and about participation.

Participation, and the ‘new power’ were the themes of Jeremy Heimans’ opening plenary. Jeremy, one of the founders of Avaaz, compared ‘new power’ with ‘old power’ using the tools he describes in a joint paper with Henry Timms, founder of Giving Tuesday. In his view, organisations must adapt to a world in which people want to move from consumers to shapers and designers of ideas, to crowdfunders and eventually to co-creators and co-owners of ideas and product. People want to participate. That participation may be short term – he described the short life of the Occupy movement – and it is certainly not loyal: people switch in and out of their membership of social media groups.

Old power is characterised by hoarding and controlling power, influence and ideas. We buy a car, a frozen pizza or a magazine, but have very little say, often no say at all, in what they contain or how they are produced; we are merely the consumers, buying the product, or not. When we don’t, the old power business rethinks the product and offers us a new one, until they produce the car/pizza/magazine that people are willing to purchase.

New power is, in Jeremy’s words, a ‘current’, like electricity or a fast-flowing stream. We can’t hoard it, but maybe we can channel it. It’s the fast-flowing current of knowledge that is filling the encyclopaedic sea of Wikipedia. It’s the brains behind Linux and open-source software. It’s the million people on the streets of Barcelona to protest police brutality, or the signatories on a campaign website.

Great, Jeremy, but how can we use this in major donor fundraising?

The clue came in another session at the conference. Led by Dr Max Martin, Global Head of Philanthropy at Lombard Odier bank in Geneva (and one of the most brilliant people working in philanthropy in Europe), the session was about innovations in finance for Social Purpose Organisations (SPOs). During the session we heard from the CEO of the Womanity Foundation about a cleverly designed funding model involving UBS Optimus and CIFF in which Optimus provide initial funding for an educational project, with CIFF paying the foundation back for each measureable outcome from the project. And from the International Red Cross and Red Crescent (ICRC) about the first Humanitarian Bond, a CHF26m bond issued by ICRC in conjunction with Lombard Odier and including, amongst others, Fundació LaCaixa, the formerly Catalan banking foundation.

Developing the bond was a long and arduous process for ICRC. But it started with a clever move; before they had gone any further than having the idea of a bond, ICRC involved the bank. That meant persuading board members of ICRC, a very venerable organisation, to sit down with bankers and work out what they wanted to do, and how they would do it. The donor – in this case the leading financier – was involved right from the start of the project.

And that’s the connection with Jeremy Heimans. Because although ICRC and Lombard Odier are both, most definitely, ‘old power’ organisations, this CHF26m project worked in part because ICRC gave up their power, opened up to a donor and shared the process of development with them. Together they came to a bigger, better solution than each player could have managed on their own.

So although crowdsourcing and ‘new power’ sound like the antithesis of the kinds of understated high-level philanthropy that result from our relationships with strategic donors, the same underlying force occurs in both; involve your donors, your investors and your stakeholders RIGHT FROM THE START. Share your power of project- and programme-creation with them, and you could win, big-time.

Professionals, in Fundraising

The team at the University of Barcelona Postgraduate Certificate in Fundraising – on which I teach – have produced a new video promoting the profession of fundraiser and, yes, our course.

If you have friends or colleagues in Spain or Catalonia, pass them the link!

It ends with Google

On Tuesday I spent the morning at the Ship2B Foundation in Barcelona. Ship2B brings together social change organisations – charities and social enterprises – with grant-making foundations, companies, family offices and venture philanthropists. The social change organisations work on themes in ‘Laboratories’ where the foundations, companies and philanthropists provide advice, contacts and money to accelerate their growth, to ‘scale.’

I sat in on a presentation by the Water4Life lab group. Here were a range of projects on water use and water management. One project was using data from Aigües de Barcelona, the Barcelona water utility, to pinpoint areas of poverty in the city based on how much water each household was using. The project was analysing mass data gathered for one purpose (water supply bills) and using it for another (mapping and understanding poverty).

Which led me to think about the Information Commissioner’s current focus on public domain information collected for one purpose, being used for another.

The ICO have told charities that “publicly available data…is not fair game.” It is not enough to claim that you have a “legitimate interest” in using data from public registers such as Companies House, and news and press reports; you “must balance this against the prejudice to the rights and freedoms of individuals.”

The team at Factary is working hard to ensure we are fully compliant with this new emphasis from the ICO. So this week we contacted one of our suppliers to check that their data was fully compliant. They told us that “…in light of the new GDPR legislation we are currently in discussions…” with suppliers. This is a leading data house that provides data drawn from Companies House. Their end supplier is Companies House.

The Supply Chain

Factary – and any prospect researcher who uses UK companies information from one of the large data houses – is in a supply chain that starts at Companies House. At some point, someone is going to knock on the door of Companies House and ask “are you compliant?”

Before they made their data freely available to anyone, Companies House earned £8.7m in a year, selling it to data users. I have been registered at Companies House as a director since 1990. I have never, ever, had a letter from them asking me if it’s OK to publish my name and address in their register, and then to sell that data on to the big data houses.

I was never asked, because Companies House had a duty in law to gather my personal information and publish it. They turned my private information into public information. They promoted my private information “to power a great range of products” and to encourage “even more people to explore and use [the] data.”

Companies House represents the contradictions at the heart of the legislation that ICO is forced to apply. Data from Companies House that we all believed to be publicly available, and in which we all had a legitimate interest, is no longer “fair game.”

So who is the biggest supplier of publicly available data?

Google, of course.

A Little Light Googling

Every day, millions of people in Britain type the name of a person – a celebrity, a footballer, a friend, a company owner – into Google. Google returns thousands or millions of results; “Theresa May” returns 24 million publicly available results this morning, ranging from press reports to biographic reference sites.

I did not ask the Prime Minister if I might check her name in Google. I am certainly prejudicing her right to privacy by putting her name into Google, because thanks to Google I can see all sorts of scurrilous, unrepeatable stuff about our glorious leader.

Google is a massive re-purposer of publicly available data. Data gathered for one purpose (selling newspapers, or adverts in scurrilous blogs) is re-purposed every single day by Google on behalf of its millions of users.

This is where the contradictions in UK privacy legislation are crystallised. This is where the ICO is heading in its search for the right balance between legitimate interest and the rights and freedoms of individuals.

I want to be a fly on the wall when the ICO knock on the door of number 6, Pancras Square, London N1, the UK headquarters of Google. That battle – between the ICO and Google – will be one to watch.

Thanks, Alastair

I have just had this lovely email from Alastair James, Senior Consultant at Global Philanthropic. He read my book, ‘How Philanthropy is Changing in Europe’ and wrote:

Dear Chris

I just wanted to say what a wonderful book you have written.

It is a fascinating volume, full of interesting and well-researched material, and I have learned a lot by reading it. You have approached the subject with the rigour of a true academic, but you have written it in a very engaging and accessible style.

I have come away with an overwhelmingly positive impression of philanthropy in Europe from reading your book, although you have also been very clear about the lack of information available in the sector. The fact that foundations are starting to be more open is a very good sign.

I also think that, in the current difficult climate, the book provides a lot of encouraging messages for fundraisers – not least the fact that fundraising has been going on for a long time in Europe, and will, for sure, continue to do so.

My warmest congratulations to you on this superb book.

Best wishes.

Alastair

Alastair James
Senior Consultant
Global Philanthropic
a.j@globalphilanthropic.com

 

Chris Carnie is the author of “How Philanthropy is Changing in Europe”, published by Policy Press. He writes in a personal capacity.

Mind the Gap

Thank you for your comments in the Factary blog over the last few weeks. Even the ones we disagree with.

Really.

Because your comments – Adrian, Charlotte, Elizabeth, Finbar, Gareth, Jay, Jeremy, Jon, Julie, Luke, Nicola, Oliver, Peter, Philip, Sarah, Tim, – show the size of the gap between two camps.

In one camp are the people who work with philanthropists in charities, universities, theatres and museums. These people know that in order to manage a relationship with a customer – in this case, a philanthropist – we need to do what the banks, the supermarkets, the accountants, lawyers, architects and many others do. We need to be able to access public domain information in order to understand our customer, and we know that we have a legitimate interest in doing so. Sometimes we are required to do this research – for example by our supervisors at the Charity Commission.

Sometimes, we need to do this research before we have met the person. Which is why we have a range of controls, including legal controls and codes of conduct that set limits on this type of research.

In the other camp are the people who believe that precisely this type of research is an intrusion into an individual’s privacy. That searching for a named individual in Companies House fundamentally affects the rights of that person.

This is out of our hands now. The Fundraising Regulator and the Information Commissioner are putting together guidance that – we hope – will resolve this difference.

So we are closing, for now, this thread of conversation. We are not going to take any more comments in this area, for now. The debate needs much more hallowed halls than Factary can offer – it should be taking place in Parliament, or at the NCVO, not in our blog.

We have a job to do – to provide ethically sourced public domain information for our many non-profit clients, and we’d better get back to that.

The Future of Philanthropy, in 1 Question

You are at a board meeting of your charity. Board member Jane mentions her friend Peter, and says he might be interested in making a donation. Peter, she says, is the owner of a large software company.

Peter, to be clear, is NOT A CURRENT DONOR. He has not opted in or opted out or opted for anything at your charity.

Back at the office you put Peter’s name into Google. It’s in your legitimate interests to do so, and Peter would expect you to do this.

Turns out that Peter’s business is based in Newcastle.

You are in London, so there is time and travel cost to consider if you are to visit him. You use Companies House to find out about Peter’s shareholding and the company’s profits. These figures help you estimate Peter’s gift capacity. Again, it’s legitimate for a charity to estimate the size of a potential donation before it decides to spend money on a visit to Newcastle.

At an invitation-only event on the 21st of February, the Information Commissioner’s staff will tell charities and the Fundraising Regulator whether or not they can do this search.

The future of philanthropy in the UK hangs on the ICO’s reply to this one question.

Can a prospect researcher do the search outlined above?

If the answer to the question is “No”, then high-value philanthropy in the UK will change dramatically.

It will no longer be possible to use public-domain information to identify or understand potential donors. Charities, universities, museums, hospitals and theatres will have to stop, immediately, all proactive forms of reaching out to new high-value supporters.

How will high-value philanthropists react? They will give less. When charities stop asking, people of wealth will stop giving, or give less and less often.This is not just an assertion – it is demonstrated by research. In “Richer Lives: why rich people give”, Theresa Lloyd and Beth Breeze report that 69% of rich donors give ‘If I am asked by someone I know and respect.’ Charities, from cancer research to the lifeboats, will have to adapt to a dramatic cut in their income.

Some philanthropists will respond by setting up their own foundations. We know from Factary’s New Trust Update that they are already doing this in some numbers. They will manage their own projects via these foundations, meaning less money for mainstream charities.

If the answer to the question is “No”, then the ICO is taking on not just the charity sector, but pretty much every business in the UK. Because every day hundreds of thousands of secretaries, assistants and marketing people do this exact search to check up on potential customers. Can that really be the ICO’s intent?

If the answer is “Yes”, then the ICO is affirming prospect research. We CAN continue to research, understand, and evaluate potential donors and, with permission, actual donors.

We will know the future of philanthropy in the UK on the 21st of February.


Chris Carnie is the author of “How Philanthropy is Changing in Europe”, published by Policy Press. He writes in a personal capacity.

Have I Mentioned…?

Have I mentioned my new book? (It’s the vain author’s constant refrain.)

Yes, I know I have. But that was pre-publication. Now I have an actual copy in my hands, so that means that the orders have started shipping from Policy Press.

This is a book for practical people. It’s about how high-value philanthropy is evolving across Europe, so practical people in fundraising, in prospect research, in social investment, in policy making and in education will all find – I hope – useful information here.

If you are a major donor fundraiser interested in why your donors keep asking about impact, you’ll find an answer here.

If you are a private banker or wealth adviser who wants to understand why your clients keep on asking about foundations in France, you’ll find out why, here.

If you are a policy maker wondering whether to recommend further tax relief for donations, then you’ll find the arguments here.

If you are a prospect researcher, wondering where to look for potential supporters in Switzerland, you’ll find some answers here.

And if you are the director of an NGO, wondering what your strategic priorities should be, you’ll find some suggestions here.

The book includes case studies, detailed research, some how-to, and a bibliography of more than 300 sources and references in (count ’em, ladies and gentlemen) seven languages. Its focus is Europe, meaning that this is not about the UK + the Continent + Ireland – it’s about the Continent + Ireland, plus the UK.

I hope you find it useful.

 

Order “How Philanthropy is Changing in Europe” directly from Policy Press, here.

Divided Rules

Prospect researchers are at the nexus of a storm between five government agencies. Thanks to the monetary penalties imposed by the Information Commissioner in December 2016 on two leading charities we can now see the extent of the battlefield.

In one corner is the Information Commissioner’s Office, ICO. In its press release announcing fines for the RSPCA and the British Heart Foundation, ICO condemned the use of “information from publically[sic]-available sources to investigate income, property values, lifestyle and even friendship circles.”

This appears to put the ICO in direct opposition to the Charity Commission. In a series of papers entitled ‘The Compliance Toolkit’ the Commission reminds charities that they have a duty to check on donors and potential donors. Tool 6 in the suite is called ‘Know Your Donor’, and here the Charity Commission asks;

“Have any public concerns been raised about the donors or their activities? If so, what was the nature of the concerns and how long ago were they raised? Did the police or a regulator investigate the concerns? What was the outcome?”

How would you find out whether “public concerns” have been raised, if you did not use “publically-available sources”?

You simply have to use newspapers, government sources, and a search engine if you are to find out whether public concerns have been raised. There is no other way. And of course the Charity Commission says so, recommending that “full use should be made of internet websites” to check donors.

Your duty

The Commission goes further, and reminds trustees that “…if the trustees have reasonable cause to suspect that a donation is related to terrorist financing, they are under specific legal duties under the Counter-Terrorism Act to report the matter to the police. In the case of money laundering, reports can be made to the police, a customs officer (HMRC), or an officer of the National Crime Agency.” The Commission suggests a threshold for reporting – donations of £25,000 or more.

But we are not done yet. Because if you have the slightest suspicion that the donor may be a bit iffy, the Charity Commission requires you to “…check the donor against the consolidated lists of financial sanctions targets and proscribed organisations.”

Gosh.

That means this list.

The list contains 8,885 names of individuals who are under sanctions. It includes their date and place of birth, their passport or ID number, and a biographic note such as “Manager of the branch of Syrian Scientific Studies and research Centre.”

That is personal information held in the public domain, that the Charity Commission requires us to review.

The Libya Connection

Why are four government agencies – the Police, HMRC, the National Crime Agency and the Charity Commission – interested in these checks?

In part, the story is linked to the London School of Economics, and the controversy over a gift from Libya. The result of the controversy was the Woolf Inquiry, which published its report in October 2011.

After a detailed study of the history of this gift, Lord Woolf made a series of recommendations on accepting funds from “less well known” high-value philanthropists including an inquiry into the sources of their funds (p. 69) and a thorough due diligence assessment (p. 22).

These searches are only possible with public domain information.

Catch-22

Under questioning at last year’s CASE conference, ICO spokesperson Richard Marbrow did allow that we could use public domain information for due diligence purposes. But he went on to say that this same information could not be used for assessing gift capacity because that would be an “incompatible purpose” for the use of data.

But that leaves us prospect researchers in Catch-22.

I cannot carry out full due diligence on all my prospects. To do so would be a scandalous waste of charity resources. The Charity Commission suggests that the threshold should be £25,000. So if I am to decide that Mrs A or Mr B must be checked via due diligence…I have to assess their gift capacity.

To do that, I need the help of a fifth government agency, Companies House.

Open for Business

Mr Marbrow cited Companies House various times during 2016, telling fundraisers and prospect researchers that because the information in Companies House was collected for one purpose – regulation – it could not be used for another – prospect research.

What does Companies House say? Here is their July 2014 press release*

“Companies House is to make all of its digital data available free of charge. This will make the UK the first country to establish a truly open register of business information.
As a result, it will be easier for businesses and members of the public to research and scrutinise the activities and ownership of companies and connected individuals. … This is a considerable step forward in improving corporate transparency…

It will also open up opportunities for entrepreneurs to come up with innovative ways of using the information.”

So, Companies House wants us to “research and scrutinise the activities and ownership of companies and connected individuals,” and to find “innovative ways of using the information.”

The Battle for Philanthropy

Prospect researchers are caught in the centre of a battlefield between government agencies, between “innovative ways” of using information, terrorism legislation, due diligence and privacy.

We must defend our corner of this bloody battlefield.

We need our friends in fundraising and philanthropy, in Parliament and in civil society, to support the sensible, ethical, managed use of public domain information in the search for philanthropists.

 

 

*I am grateful to a colleague at a leading University for pointing this out.

Chris Carnie is the author of “How Philanthropy is Changing in Europe”, published by Policy Press. He writes in a personal capacity.

In Defence of the Public Domain

A university, a museum, or a charity does not raise £10m or £50m or more by accident. An alumna did not wake up one morning thinking “I must give £1m to my alma mater.”

This happened because a dedicated group of professionals managed a process that led to the alumna being asked for a very large philanthropic gift.

At the heart of that process was, and is, the prospect research team. The team used – like we all do – public domain information to identify and understand potential supporters.

But now one government agency, the Information Commissioner’s Office, wants to stop us using public domain information. In the emotionally-worded press release that accompanied the penalties for the British Heart Foundation and RSPCA, the ICO says that “companies used other information from publically [sic]-available sources to investigate income, property values, lifestyle and even friendship circles.” ICO staff members at fundraising and research conferences throughout 2016 told us that the information on directors held by Companies House is compiled for one purpose (regulation of business) and therefore cannot be used for another (prospect research.)

So perhaps we cannot use public domain information to identify and understand potential supporters.

Purposes

But think for a moment.

Why do I have my profile in LinkedIn? What is my ‘purpose’? Is it just a marketing tool, showing potential clients what a clever chap I am? No! I had all sorts of purposes in mind when I created my profile in LinkedIn. I wanted to reassure clients that I was, and am, a decent person. I am proud of what I have done and wanted – sorry folks, this gets personal – to boast a wee bit about setting up Factary, about the books I have written and the languages I speak. I wanted access to the profiles of other people with whom I might work or even play. I wanted to explain who I am and how I got here – it’s cathartic. And I wanted a useful depository for my lifeline – to remind me of exactly when I went to school or which year I started in fundraising.

I had a whole variety of ‘purposes.’

Expectations

As a result, I have a very wide variety of ‘expectations.’ This word is important, because the ICO believes that “millions of people who give their time and money to benefit good causes will be saddened” by the news that charities targeted them for more money; in other words, this is about what people expect. With my profile in LinkedIn I expected that people would look at my personal story. I expected that Southampton Uni, my alma mater, would contact me about a donation (they did.) I expected that I would be networked to, and with (and indeed welcomed that opportunity.)

The person who has her biography in Who’s Who, or who gives a personal interview in the Times, or who is listed as the director of a company, or as the trustee of a charitable foundation has the same wide range of expectations.

The ‘purpose’ of a personal interview in the Times is to sell advertising space on the facing page of the newspaper; “All the papers that matter live off their advertisements,” said George Orwell, in Why I Write*.

But that is not the ‘purpose’ that the interviewee had in mind when she was approached by the journalist. Nor is it the ‘expectation’ of the interviewee. She knows, when she agrees to give the interview, that her warts-and-all will be exposed to public view. She expects that she will receive praise, opprobrium, investor pitches, car sales teams and an approach from a headhunter as the result of her interview.

The Public Domain

Information on company directors in Companies House – the Registrar of Companies for England and Wales – is made public for various purposes. The Registrar was created by The Joint Stock Companies Act of 1844. In the debate of the Bill that would create the Act (3rd July 1844), Mr Gladstone said “The principal object of the Bill was, that there should be established a public office, to which all parties soliciting to take part in Joint Stock Companies might repair, in order to know the real history of these companies.” Mr Gladstone was talking very clearly about corruption; “…it was most important that the Legislature should put a stop to the system that had been so long carried on of attaching the names of hon. Members, and men of importance and property, to schemes in order to entrap the unwary.”

So here again, at Companies House, we have a variety of purposes for information in the public domain. It is right and proper that prospect researchers use Companies House information to establish the “real history” of “men of importance and property”, and, 172 years after Mr Gladstone’s speech, of women of importance and property too.

All the universities that are engaged in raising funds, along with our theatres, museums and charities, manage a process that results in high-value philanthropy. At the heart of that managed process is prospect research. And alongside every prospect researcher is public domain information.

People in the public domain – in Who’s Who, or LinkedIn, the Times or Companies House – are there for a variety of ‘purposes.’ They expect that the information will be used in a variety of ways – including, yes, by people who will lead them into great philanthropic acts.

We prospect researchers do great works with public domain information. It is wholly legitimate that we use public domain information for this purpose. We must defend our right to do so.

Chris Carnie is the author of “How Philanthropy is Changing in Europe”, published by Policy Press in January 2017. He writes in a personal capacity.

*The fuller quote, given here is:

“Is the English press honest or dishonest? At normal times it is deeply dishonest. All the papers that matter live off their advertisements, and the advertisers exercise an indirect censorship over news.”