Our Vulnerable Person's Policy
Summary - key points

1. The policy aims to ensure that donors are treated fairly and with care, and that they make informed decisions about their donations and support of The Haven.
2. The policy is in line with the Fundraising Regulator’s Code of Fundraising Practice.
3. Vulnerability refers to individuals who have difficulty making informed decisions about supporting or donating to the charity.
4. Vulnerability indicators include physical and mental medical conditions, disabilities, learning difficulties, stress or anxiety, financial vulnerability, lack of understanding in the English language, influence of substances, and individuals under 18 without consent.
5. The Haven assesses vulnerability through various communication channels and encourages fundraisers to consult their managers if they are unsure.
6. If a supporter is vulnerable, we take appropriate actions, such as being patient, offering alternative communication methods, checking understanding, and respecting their decisions.
7. If vulnerability is disclosed by a family member or carer, The Haven assesses the situation on a case-by-case basis and acts in compliance with GDPR.
8. The Haven does not accept donations if a donor is believed to lack capacity, and they take steps to return donations made by a vulnerable individual.
9. Measures are put in place to prevent future solicitations from vulnerable donors.
10. Age alone is not an indicator of vulnerability; vulnerability is assessed individually.
11. Supporters under of 16 are immediately excluded from receiving fundraising marketing.

If you are acting in a voluntary fundraising capacity we encourage you to review the policy in full to protect vulnerable individuals and ensure best practice. The policy takes approx. 3 minutes to read.

General purpose of policy

We believe that giving to The Haven Wolverhampton should always be a positive experience; whether you are a new or existing supporter. The Haven Wolverhampton are committed to fundraising in an open and honest way and strive to ensure that donors are treated fairly and with care. We will always do everything we can to ensure supporters are making informed decisions about their donation and support of the women and children at The Haven Wolverhampton.

Our fundraising team communicate with supporters through a variety of communication channels, including in person, mail, email, social media and telephone. It is inevitable that we will encounter vulnerable people through the course of our fundraising and some of these individuals may not be able to make informed decisions about their giving.

This policy outlines how we identify vulnerable donors and ensure they are treated fairly; as well as what action we take if we suspect a supporter is vulnerable.

Fundraising regulator

The Haven Wolverhampton are registered with the Fundraising Regulator and abide by rules and regulations set out in the Code of Fundraising Practice. We commit to the high standards of the Regulator and our Fundraising Promise to all donors in line with the regulator can be found on our website.
This policy has been written using guidance from the Code of Fundraising and the Institute of Fundraising; specifically, ‘Treating Donors Fairly’.
The Fundraising Regulator Code of Practice states in the General Principles that:
i) “Fundraisers MUST take all reasonable steps to treat a donor fairly, enabling them to make an informed decision about any donation. This MUST include considering the needs of any potential donor who may be in a vulnerable circumstance or require additional care and support to make an informed decision.
ii) 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”
iii) If a fundraiser knows or has reasonable grounds for believing that an individual lacks capacity to decide to donate, a donation MUST NOT be taken.
iiii) A donation given by someone who lacked capacity at the time of donating MUST be returned.

    What is a vulnerable person?

    By ‘vulnerable’ we mean any individual who finds it difficult to make an informed decision about supporting or donating to the charity. There are several factors which can indicate vulnerability. It is not feasible to provide a comprehensive set of characteristics which would always identify vulnerability. However, we follow best practice as laid out in this policy and the bullet points below cover main indicators. We have faith in our fundraisers to identify vulnerability beyond or outside of these bullet points. Characteristics include (but are not limited to):

    • 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)
    • a lack of understanding/fluency in the English language
    • influence of alcohol or drugs
    • any person under 18 years of age without parental/adult consent/presence
    How we assess vulnerability

    The Haven Wolverhampton value our supporters and want to ensure that those who choose to donate and support us are treated fairly and with care. All staff and volunteers involved in fundraising and marketing will read a copy of this policy demonstrating an understanding surrounding vulnerability and understand the actions taken by the organisation in given circumstances. Fundraisers will also keep up to date with the Code of Fundraising to ensure we always fundraise within best practice.

    The Haven Wolverhampton recognises that it may sometimes be difficult for fundraisers to assess the vulnerability of a supporter. In cases where a fundraiser is unsure, they must consult their line manager before accepting any donation. The team as a whole will always err on the side of caution when assessing vulnerability.

    If a member of the team believes they have interacted with a vulnerable supporter and is concerned about their welfare, they must follow The Haven Wolverhampton’s Safeguarding Adults, or Safeguarding Children’s Policies.

    There are several indicators which can help to identify vulnerability through the different communication channels used by The Haven Wolverhampton’s Fundraising Team using REAL:

    • Retain – are they able to retain and repeat the information given?
      • Do you have to repeat what you have said over and over again?
    • Explain – able to properly explain or communicate the decision they have made?
      • Are they joining in the discussion or just agreeing with what you are saying?
      • Are they asking questions that aren’t related to what you are saying?
    • Able – to understand what they are being told?
    • Listen – able to listen, follow and understand the discussion taking place, or are they just repeating what you say?

    Further examples of identifying vulnerability through different types of communication are given below:

    Communicating via phone or face to face

    Indicators that a person may have a mental health vulnerability include:

    • Asking irrelevant and unrelated questions
    • Responding in an irrational way to simple questions
    • Asking for questions or information to be repeated
    • Taking a long time to respond or finding it difficult to respond
    • Repeating questions they have asked
    • Wandering off the subject
    • Displaying signs of forgetfulness

    Indicators of physical vulnerabilities:

    • Unable to hear or understand what is being said
    • Unable to read and understand the information provided to them
    • Displaying signs of ill health e.g. breathlessness or discontent

    Communicating via letter or email

    We can at times identify vulnerability through written communications:

    • A supporter who has emailed or written to us to tell us they are vulnerable
    • The supporter’s family member or carer has indicated that they are vulnerable
    • Someone whose handwriting is particularly shaky and hard to read. This is an indicator that the supporter is frail and to be cautious
    • Sentences that don’t make sense or trail off
      How The Haven Wolverhampton will respond to an individual who needs additional support or who is in a vulnerable situation
      • We will be patient and won’t rush the conversation – it’s better to have a longer conversation than cut this short and leave the person confused or agitated in any way.
      • We will ask if the person would prefer another method of communication e.g. offer to send information in the post or via email, so they have time to take in the information.
      • We will ask the person if they need to speak with anyone else before deciding.
      • We will check their understanding of what they have agreed to – for example, ask them to repeat this information back to us.

      All of the above will help to make sure that the person comes first, and we give them time to make an informed decision, if they are capable of doing so.

      Family member or guardian / carer contacting The Haven Wolverhampton to disclose vulnerability

      • If we are alerted to a vulnerable supporter by a family member or carer, we will assess on a case-by-case basis to ensure compliance with GDPR as well protecting the vulnerable person.
      • Where we are provided with information, we will act upon this, reviewing any donations previously made, returning these donations where appropriate, and we will ask what kind of communication, if any, is acceptable.
      • Our database is updated to reflect wishes using the critical info box; ensuring the pop-up option is ticked. If the donor / carer wishes, they are removed altogether from our database. We cannot disclose any information to the family or carer regarding the supporter unless they have power of attorney.


      What we do if we suspect a supporter is vulnerable

      The Haven Wolverhampton does not accept donations if we have reason to believe that a donor is vulnerable and lacks the capacity to make an informed choice about donating. We will not accept any donations where we feel that accepting the donation would be ethically wrong and/or harmful to the donor.

      Should a situation arise where The Haven Wolverhampton becomes later aware that it has unknowingly accepted donations from an individual during a time that he or she was experiencing vulnerable circumstances, The charity will take all reasonable steps to return all donations accepted during this period.

      If a donor is identified as vulnerable, the organisation should put in place measures to ensure that donations are not solicited from them in the future in the following ways through the database:

      • use the critical information section, ensuring the pop-up option is ticked
      • tick the donor as no correspondence
      • update indictors to say ‘no fundraising marketing’ ‘no newsletter’
      Is age an indicator of vulnerability?

      Age does not indicate whether a person is vulnerable or not. There are many older people who are active and leading comfortable lifestyles. Equally a much younger supporter could be in a vulnerable position. Therefore, The Haven Wolverhampton will not make a judgement based on age; vulnerability is assessed on individual circumstances.


      However, if a supporter is identified as being under the age of 16, then we will immediately stop them from receiving fundraising appeals and calls.


      If you would like to speak to us about this policy or if you have any feedback, please contact the Fundraising Manager. You can do this in one of the following ways:

          • Via telephone 01902 599109
          • Via email give@havenrefuge.org.uk
          • Or in writing to Fundraising Manager, The Haven Wolverhampton, 18 Waterloo Road, Wolverhampton, WV1 4BL

      Updated: June 2023
      Revision date: June 2024