Our approach to vulnerable donors

To ensure that we take all reasonable care to protect vulnerable adults, Prisoners’ Education Trust (PET) is registered with the Fundraising Regulator, adheres to the Fundraising Code of Fundraising Practice as held by the Fundraising Regulator, and complies with the Institute of Fundraising’s guidance set out in ‘Treating Donors Fairly: Fundraising with people in Vulnerable Circumstances’.

These guidelines do not cover children and young people under the age of 18, and we do not actively seek donations from them.

PET relies on donations from individuals and grants from organisations to fund our work – without our donors we could not provide essential educational opportunities to men and women in prison. We aim to communicate with supporters in the ways in which they are most comfortable and this includes mail, email, phone and in person.

Every donor is an individual with a unique background, experiences and circumstances – and every interaction between a fundraiser and donor is different. PET does not define vulnerable adults based on broad personal characteristics such as disability or age. We believe that everyone should have the opportunity to donate if they are willing and able to do so, and that denying people the chance to give based on appearance, age or behaviour may be considered discriminatory.

It is inevitable that we will come into contact with people who are vulnerable and not able to make informed decisions about their giving. This document outlines how we take all reasonable care to identify supporters who may be vulnerable, and what action we take if we suspect a person is vulnerable.

- Complying with regulation and best practice

- Identifying vulnerable people

- If PET suspects a supporter is vulnerable

- Who to contact

Complying with regulation and best practice

The Code of Fundraising Practice states in Section 1.0 Key Principles and Behaviours that:

“Fundraisers MUST take all reasonable steps to treat a donor fairly, enabling them to make an informed decision about any donation. This MUST include taking into account the needs of any potential donor who may be in a vulnerable circumstance or require additional care and support to make an informed decision.”

And

“Fundraisers MUST NOT exploit the credulity, lack of knowledge, apparent need for care and support or vulnerable circumstance of any donor at any point in time.”

PET fundraising practice abides by the four key principles of ‘Treating Donors Fairly’ (page 5), namely:

“i) Respect: Always be respectful. This means 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.

ii) Fairness: Treat your donors fairly. This includes not discriminating against any group or
individual based on their appearance or health conditions.

iii) Responsive: Respond appropriately to the individual needs of your donors. The responsibility lies with fundraisers to adapt their approach(tone, language, communication technique)to suit the needs and requirements of the donor.

iv) Accountable: Take responsibility for your actions, ensuring that your fundraising is carried out in line with the Code of Fundraising Practice. Consider what processes and procedures your charity may need in place to ensure this happens and that the needs of people in vulnerable circumstances are met.”

Identifying vulnerable people

As stated in ‘Treating Donors Fairly’, all individuals may, at some stage in their life, be considered vulnerable or require additional care and support, depending on their own personal circumstances, health, bereavements, life events and more. An individual who may need additional care and support, or may be considered to be in a vulnerable circumstance, can still have capacity to choose to donate to a charity.

It is the context and circumstances in which the individual may be at the time of making a decision about whether to donate that are relevant. For example, a recently bereaved person may need additional support, but this may change as time progresses. At the time of bereavement they could still have the capacity to make a donation, but might need additional support to help them make their decision.

Additional support may include: delaying acceptance of the gift to give the donor further time to consider their donation, including a ‘cooling off’ period if the donor changes his or her mind; or suggesting the donor gets advice from family/friends.

The important distinction is whether the individual has a complete lack of capacity to make a decision, or needs more information and support to be able to make a decision to donate. Fundraisers need to be aware of this difference so that they can make a reasoned judgment and act appropriately when dealing with existing or potential donors.

Examples of indicators which could mean that an individual is in a vulnerable circumstance or needs additional support could include:

  • Physical and mental medical conditions
  • Disability
  • Learning difficulties
  • Times of stress or anxiety (e.g. bereavement, redundancy)
  • Financial vulnerability (where a gift from a donor may impact on their ability to sufficiently care for themselves or leave them in financial hardship)
  • English not being the donor’s first language
  • Influence of alcohol or drugs.

It is not feasible to provide a comprehensive set of factors or characteristics which would enable fundraisers to always identify an individual who is in vulnerable circumstances. We therefore use the checklist set out in ‘Treating Donors Fairly’ (page 10) to help identify signs in verbal and written communications that an individual may be in a vulnerable circumstance (it should be noted some signs are more likely to be noted in verbal communication than written):

Is the individual:

  • Asking irrelevant and unrelated questions, or displaying signs of forgetfulness?
  • Unable to read and understand the information they are provided with, and asking for it to be continually repeated?
  • Responding in an irrational way to simple questions?
  • Saying ‘yes’ or ‘no’ at times that it is clear they haven’t understood?
  • Taking a long time or displaying difficulty in responding to simple questions or requests for information?
  • Repeating simple questions such as ‘who are you’, ‘what charity is it’ and ‘what do you want’?
  • Wandering off the subject at hand and making incongruous statements?
  • Saying that they are not well or not in the mood to continue?
  • Displaying signs of ill-health like breathlessness or making signs of exasperation or discontent?
  • Giving a statement such as ‘I don’t usually do things like this, my husband/wife/son/daughter takes care of it for me?’
  • Indicating in any way that they are feeling rushed, flustered, or experiencing a stressful situation?
  • Having trouble remembering relevant information, for example that they are already a regular donor to that charity or have recently donated?
  • Donating an unexpectedly large gift with no prior relationship? (There being no prior relationship before a gift is made does not on its own constitute ‘vulnerability’: many legacy and major donor gifts to charities are given without the existence of a relationship between the donor or charity).

If one or more of these signs are noted, we may contact the donor to assess in more detail whether we believe the donor to be vulnerable. This contact would be made in line with our data protection policies and adhering to any communication preferences the donor has stated.

In some instances a supporter may actively declare their vulnerable status, or a family member or carer will alert PET. Where we have been given this information we will act upon this, by asking the supporter what kind of communication, if any, is acceptable.

When communicating with individuals, particularly those we suspect are vulnerable, we will:

  • Communicate clearly, avoiding words and phrases that may be hard to understand (if communicating verbally we will also avoid shouting);
  • Repeat information;
  • Try to reflect the terminology used by the donor which may help to increase their understanding;
  • Be patient and do not rush or pressure the individual;
  • Provide alternative formats of fundraising materials (e.g. accessible formats);
  • Be upfront and tell the person why PET is communicating with them and check that they are happy to continue;
  • Ask if they would prefer to be contacted in a different way or at a different time;
  • Ask if they would like to talk to anybody else before making a decision; and
  • Check their understanding at relevant parts of the interaction (especially if face to face or on the phone) and ask if there is anything that needs further explanation.

If PET suspects a supporter is vulnerable

If PET believes that an individual may be in a vulnerable circumstance or unable to make an informed decision, we will politely and carefully end our interaction with that individual, and make a file note of the engagement, including time, date, name of supporter, and the name of PET volunteer or staff member who was interacting with the donor.

If PET has reasonable grounds for believing that a supporter lacks the capacity to make a decision then their donation will not be taken.

After the donation, if PET receives evidence that the person lacked capacity to make the decision to donate, then the charity will return the donation because the original donation was invalid.

If a donor is found to lack capacity, PET will put in place measures to ensure that donations are not solicited from them in the future. We will note the circumstances on our supporter database, mark the individual as “no contact” and retain their information in line with data retention and financial control policies.


If appropriate, and as recommended in ‘Treating Donors Fairly’ (page 14), if an individual is expressing signs of being distressed and informs a PET volunteer or staff member that they are in a particular situation (e.g., they are recently bereaved, or have been diagnosed with a medical condition) then part of responding appropriately can be to let them know that there is a charity or service which might help them and passing on a phone number or website address if the individual is interested.

Who to contact if you would like to raise a concern, or would like to discuss this policy

Should you wish to discuss any aspect of this policy, or would like to raise a concern about a supporter of PET whom you believe to be vulnerable, in the first instance, please contact Cassie Edmiston, Head of Fundraising:

Email: cassie@prisonerseducation.org.uk
Telephone: 020 3752 5670
Letter: Prisoners’ Education Trust, The Foundry, 17 Oval Way, London, SE11 5RR

If you would like to escalate your concern, please review PET’s fundraising complaints policy, available on our website and on request (info@prisonerseducation.org.uk).

For reference:

Fundraising Regulator: https://www.fundraisingregulator.org.uk/ 
Fundraising Code of Practice: https://www.fundraisingregulator.org.uk/code-of-fundraising-practice/code-of-fundraising-practice/ 
Institute of Fundraising ‘Treating Donors Fairly’: http://www.institute-of-fundraising.org.uk/documents/treatingdonorsfairly/

PET Vulnerable Support Policy
Drafted: March 2017
Adopted: March 2017
Review date: September 2017