Children and Vulnerable Persons


Fundraising should be a positive experience for all our existing donors or potential new supporters. It is vital that the relationship we build with our supporters and potential supporters is a positive and well balanced one. This is particularly so for vulnerable people. As an organisation that deals daily with the public it is vital that My Shining Star gets this right. We have now adopted a generic vulnerable person’s policy to assist all those that work with members of the public. My Shining Star will follow the Institute of Fundraising Code of Practice on vulnerable people. The Fundraising Policy on Vulnerable People builds on this to aid any My Shining Star staff, volunteers and agency acting on its behalf to ensure that we continue to treat vulnerable people fairly and with compassion and integrity. This is our statement and framework on assessing vulnerability during fundraising operations and must be used by all staff and agencies working on our behalf.


Definition of a vulnerable person

There is no legal definition of a vulnerable person. My Shining Star defines a vulnerable person on their ability to decide. The Mental Capacity Act 2005 gives some guidance in this area by stating that an individual is unable to decide for himself if “he is unable to understand the information relevant to the decision or to retain that information”. My Shining Star uses this as a framework to define a person as vulnerable if it would be unreasonable to expect them to be able to understand the information being given or retain that information. It is the role of the person communicating with them to try and establish this fact.


Anyone fundraising on behalf of My Shining Star must not exploit the credulity, lack of knowledge, apparent need for care and support or vulnerable circumstances of any existing supporters or potential new supporter at any point in time. We will treat all members of the public respectfully, fairly, and any of the responses we give will be appropriate to their needs.


Implementation: recognising the signs

Vulnerability can be difficult to recognise particularly for some fundraising methods and can alter over time. As the fundraiser needs to make a clear decision quickly on a person’s vulnerability they need explicit guidance.

Whilst it is not possible to draw up an exhaustive list of indicators that show a person may be vulnerable, a precautionary approach should be taken and if the fundraiser has any concerns the conversation should be terminated. Signs that could indicate a person’s vulnerability include confusion, not being able to retain information that has already been given, making irrelevant statements or asking irrelevant questions or taking a long time to answer a question. Assessing if a person is confused could be determined if they repeat simple questions such as who the person is and what charity are they representing and show signs of forgetfulness. Certain statements can be used to assess whether a person lacks the capacity to decide. Statements such as “I don't usually do things like this as someone else makes a decision for me” or if person states that someone else has power of attorney for them or manages their affairs.

Older people, defined as those over 60, may need additional care and support from the fundraiser to ensure that they are making an informed decision but must not be discriminated against due to their age.


Implementation: taking action

Fundraisers need to be patient, clear in their language and transparent in why the communication is happening. If they have reasonable grounds for believing the person is vulnerable then the communication should be curtailed and no donation accepted.

If My Shining Star receives information that a supporter has become vulnerable and has either made a recent decision about their support to My Shining Star or wishes to review their support more generally then My Shining Star will make best efforts to receive evidence of the vulnerability and reverse any decision and return any donations from the date the vulnerability has been acquired in line with the donor’s request and/or the person that has the authority to act for the donor.

My Shining Star will always bear in mind our values, brand and reputation when deciding whether to accept or refuse a donation.

This Policy will be implemented through in house inductions and training for staff, volunteers and agencies, being written into contracts with external agencies. Qualitative measures will be used to assess effectiveness of agencies rather than relying solely on quantitative measures.

Tailoring the policy to the fundraising channel, it is accepted that the indicators above may be easier to recognise in certain fundraising (e.g. face to face) than others (e.g. telephone or direct mail) and this should be considered when devising the fundraising plan and putting in place mitigating procedures.

How this will be reviewed

The trustees of My Shining Star are ultimately responsible for ensuring that the Vulnerable Persons Policy is implemented and enforced. They will endeavour to produce biannual reports on the policy and its effectiveness using several KPIs such as number of donations returned, number of complaints received, and any internal audits of agencies.

My Shining Star will be transparent in how it records this information in its Annual Report whilst meeting the standards required from the Charity Commission and the Inland Revenue.


Produced April 2018 (Reviewed annually).