Commitment to Standards in Fundraising Practice

WALK is a charity that seeks donations from the public for specific projects.

Our pledge is to treat all our donors with respect, honesty and openness.

WALK commits to being accountable and transparent so that   donors and prospective donors can have full confidence in WALK. WALK promises to effectively apply donations and gifts to us for their intended purposes through WALK’s Community Project Fund.

WALK commits that our donors and prospective donors are:

- Informed of the organisation’s mission and of the way the organisation intends to use donated resources.

- Informed of the identity of those serving on the organisation’s governing board, and that the   board will exercise prudent judgement in its stewardship responsibilities.

- Able to access to the organisation’s most recent financial statements.

- Assured their gifts will be used for the purposes for which they were given.

- Appropriately acknowledged and recognised.

- Assured that information about their donation is handled with respect and with confidentiality to the extent provided by law.

- Aware that all relationships with individuals representing WALK are dealt with professionally.

- Informed if those seeking donations are not WALK employees such as volunteers or hired third party agents.

- Easily able to access the agreed procedures for making and responding to complaints.

- Enabled to have the opportunity for any names to be deleted from mailing lists and to be informed if the organisation intends to share the mailing lists with third parties.

- Enabled to receive prompt, truthful and forthright answers to questions they might have of the organisation.

License requirements to run a raffle or Lottery

Some raffles and lotteries will need to be licensed. It is, therefore, important to know what type of lottery or raffle you are planning before you start. Listed below are two common examples:

Small Private Lotteries

These are where the ticket sales are confined to employees of a workplace or a club, often using cloakroom style tickets. There is no requirement for raffles of this kind to be registered.

When running a private lottery, only staff or club members can purchase the tickets. In the case of a raffle in a company branch, customers will not be able to buy tickets.

Raffle tickets sold exclusively at an event (e.g. concert, show, jumble sale) also fall in this category and do not need a license.

Public Lotteries

You may not be able to class your raffle under the heading ‘Private Lotteries’ for example, if you are mailing out tickets to individuals in the post, if you are advertising the raffle to customers, or if the value of the prizes will be more than €4,000.

In this case, you will need to apply for a license to the District Court for the area in which the lottery will be held. This can be done on any given Wednesday. An individual from the organisation would need to act as the license holder on the license application, and comply with the regulations of the Gaming and Lotteries Act, 1956. The total value of the prizes must not exceed €20,000 to be awarded in any one week but an amount greater than this could be awarded at intervals.

Prior to filing with the District Court, you must notify the Gardai 28 days in advance of the license application. This notice period is absolutely necessary.

The Association of Charity Lotteries in Ireland (ACLI), a forum for Irish charitable organisations who depend on the running of lotteries as a means of fundraising, have developed a Code of Practice to promote standards of good practice for the operation of charity lotteries in Ireland. All members of ACLI have signed up to this Code of Practice and promote their lotteries in accordance with the Code

Insurance requirements are an area that often leads to confusion, yet it is of critical importance for WALK to understand what their obligations are in this area. Given the importance of insurance, it is strongly recommended that when planning any fundraising event or activity WALK will consult with their insurers to ensure they are adequately covered for the planned event or activity.

BHP Insurances Ltd Unit 16 Fonthill Business Park Dublin 22 Phone: 01 6202040 E-Mail: info@bhpinsouance.ie

It is of equal importance that third party fundraisers e.g. members of the public, groups or companies organising fundraising events or activities on behalf of WALK are made fully aware of the need to clarify whether their event or activity requires insurance cover and the need to arrange this cover if it is required.

NB Volunteers will assume they are covered under the charity’s insurance. It is WALK’s duty of care to communicate they are not covered for non-produced (third party) events. The insurer will provide guidance on this. Clear communication to all new volunteers will help.

Public Liability Insurance

Public liability insurance protects WALK from loss or damage resulting from a claim for damages by a third party arising from negligence on your part

Produced events (charity run/organised): are events that are organised and managed by WALK. These events will follow all audit and insurance guidelines to ensure cover under your public liability. All produced events will be declared to insurers in advance. Volunteers are deemed staff for produced events or where volunteers are following / carrying out work under the guidance of the organisation once declared to insurers in advance. None produced events (third party events) – are independent events where volunteers arrange the event without direct input from WALK. None produced or third party events are deemed “uninsurable” for WALK to cover as the charity is not in control of the event and therefore cannot protect the event from negligence Employer Liability insurance

Employer liability insurance protects employers from liabilities arising from disease, fatality, or injury to employees resulting from workplace conditions or practices.

This has be extended out to cover volunteers for all produced (charity run/organized) events and volunteers who are carrying out work on behalf of your organisation (e.g. volunteer office staff). This must be declared to insurers in advance. However volunteers may well fulfill some services using their own insurance cover (e.g. a volunteer driver driving their own vehicle). It is important that both parties are clear in these instances about who is providing the cover. Other specific areas to consider:

Hold Harmless: are often requested by venues for large volunteering events. These will always be forwarded to our insurers for review as they, in summary, hold our organisation wholly responsible for any loss or damage at that location. WALK will not agree to any hold harmless, but this may differ from insurer to insurer. WALK will never sign Hold Harmless documents/clauses themselves. Custodial warranties – These are the cash limits per staff / volunteer. It is important to know what your warranties are to ensure cover in the event of theft. It is also important to advise any staff or volunteers handling money what these warranties are. This information is available from the insurer.

Garda Permits for Cash Collections

Under the terms of the Street and House to House Collections Act, 1962 and as updated by the Charities Act 2009, Garda permits are required for the legal collection of cash (and when the relevant sections of the Charities Act 2009 are commenced, non-cash collections) from the public in any public place or places or by house to house visits.

How to apply for a Permit?

An application for a collection permit must be made in writing in the prescribed form to the Garda Division that is local to the proposed collection. Garda permits are handled by the Garda Division rather than local Garda stations. The permit must be sought from the Chief Superintendent of the Garda Division which has jurisdiction over the place of collection i.e. a permit for a collection being carried out in O’Connell Street, Dublin must be sought from the Garda North Central Division, Store Street Garda Station. Example of Form

FORM OF APPLICATION FOR A COLLECTION PERMIT

1. Name of Applicant (in block letters)

2. Address of Applicant

Telephone:

Date of birth: / / DD/MM/YY

3. If applying as the nominee of a body (whether incorporated or unincorporated)

(a) Name of Body (b) Name of Secretary of Body (c) Address of Head Office or Administrative Centre of Body 4. Date(s) of proposed collection

5. Hours

Between

6. Locality of collection

7. Method or manner of collection

In reply to this question the applicant will indicate whether the collection is to be held (a) in streets and public places generally, or (b) only in public places of a specified kind (e.g. outside church gates), or (c) by means of house to house visits. It will also be indicated whether collection boxes are to be used. Any unusual features, such as the wearing of fancy dress by collectors, will be indicated.

“Public place,” as defined in the Act, means any place to which the public have access whether as of right or by permission and whether subject to or free of charge but does not include a Church or building used for public worship or the grounds of a Church or of such building.

8. Maximum number of collectors on each date

9. Object which the collection is to benefit

Signature of Applicant

Date:

To:

Division

What constitutes a public place?

“Public place,” as defined in the Act, means any place to which the public have access whether as of right or by permission and whether subject to or free of charge but does not include a Church or building used for public worship or the grounds of a Church or of such building.

When must you apply?

The application form must be submitted:

Not more than six months and Not less than fourteen days Before the day or the first of the days on which the collection to which the application relates is proposed to be held. (Note: There can be differences depending on the Division so it is best to check with the Garda who is responsible for handling permits)

Additional Information some Garda Divisions may also seek

Certain Chief Superintendents will also need the following information in addition to the completed Form. You will need to check with the Garda Division relevant to the proposed collection if they need this additional information.

Detail of whether the organisation is a registered charity, company, voluntary or commercial body? How are the funds raised from the proposed collection to be used? Will the collectors receive commission or expenses and if so how much? State the relationship/connection between the applicant and the beneficiary. Will the applicant receive a salary/payment from the organisation for his/her services and if so how is this funded? Is the proposed collection connected with any sponsored event, e.g. parachute jump, sponsored cycle, trek, etc? Will any part of the proceeds of the collection be used, either directly or indirectly, to fund flights, accommodation or other travel expenses? Details of whether the proceeds or any part of the proceeds of the collection are going to be used either directly or indirectly to pay for travel expenses or accommodation of the permit holder, the collectors or the members of the body? What if an emergency collection is required?

If an emergency collection is required you can apply to the Commissioner of the Garda Síochána who may if he/she believes the circumstances warrant, grant a permit in response to an application made less than fourteen days before the day or the first of the days on which the collection is proposed

What if you are applying for more than one collection?

Separate forms need to be submitted for each collection date and or location.

Provided you meet the criteria for granting of an application you will receive a permit for all dates and collection locations where permits have not already been granted.

What if two applications are received on the same day for future collections on the same date and or location?

If two or more applications are received on the same day then the successful application will be chosen by the drawing of lots.

Note -If a charity holds an annual collection at the same time each year it has first refusal on its annual date. The Chief Superintendent will contact the charity if they receive an application for the date it normally holds its annual collection giving the charity the opportunity to claim its annual date

What happens next?

The Garda may visit the applicant at their place of residence to interview them to ascertain they are who they say they are and to ensure that the collection proceeds will be used to support the beneficiary charity.

If my application is successful what happens next?

If your application is successful then the Chief Superintendent for that locality will grant a cash collection permit to that person authorising him/her to hold cash collections in that locality.

What Criteria will the Chief Superintendent use when assessing whether to grant a permit or not?

The Chief Superintendent needs to be satisfied:

That the holding of the collection(s) would not result in the public being excessively importuned. That no collection permit has already been granted for a collection for that day and either wholly or partly in the same locality.

Where the applicant held collections previously that they were carried out in accordance with the provisions of the Act.

Note – The Chief Superintendent may attach conditions to the permit concerning:

Locations Limiting the number of collectors Prohibiting the wearing of fancy dress, masks or disguises by the collectors Prohibiting the making of the collection by collectors in vehicles. Can collectors be paid collectors?

A permit will be granted if collectors receive a reasonable commission for their services, from the proceeds of the collection.

Can a permit be revoked?

If the Chief Superintendent believes the applicant acts in opposition to the Act he can revoke a permit. The revocation of a collection permit will be in writing and will contain particulars on the grounds of the revocation

If my application is refused or has onerous conditions can I appeal?

If an application for a collection permit is refused or has onerous conditions attached by the Chief Superintendent, the applicant for the permit may appeal to the District Court.

Full details of appeal criteria are contained in the Act.

What do collectors need to have on collection day(s) to indicate that their collection has a permit?

A collector in a public collection must have a collector’s authorisation granted to them by the holder of the collection permit to show that their collection is being carried out under an approved permit.

A collector’s authorisation shall contain the name, address and age of the collector and the charity that is benefiting from the collection. (Where the collector is over the age of twenty-one years that shall be deemed to be a statement of his/her age).

A member of the Garda Síochána may demand of any person whom s/he sees acting as a collector production by that person of his collector’s authorisation in relation to the collection.

Cash Collection Boxes

The cash collection box into which money is placed must prominently display the charity which is the benefactor of the collection. (Note: when commenced the relevant sections of the Charities Act 2009 set out specific requirements for the conduct of collections including that collection boxes must be sealed unless prior permission from the Charity Regulator has been granted in the case of collections involving the sale of tokens)

Is there an age limit for collectors?

A person under the age of 14 years cannot act as a collector in a collection.

Notes:

If the proposed collection is connected with a sponsored event within the area of the collection then a safety statement may also be required to be lodged at least 21 days before the proposed event to an associated Garda Sergeant at the same Garda Station. The owner of any public place at which an event is taking place and to which the public have access on payment for admission or the promoter of the event shall not knowingly allow an unauthorised collection to be made. The owner or promoter will be charged with an offence under this section of the Act, however, (s)he can use as defence that (s)he took precautions that were reasonable in the circumstances to prevent the making of unauthorised collections in that place or that (s)he could not reasonably have known or suspected that the unauthorised collection was likely to be made.

If you do have a comment about any aspect of our work, you can contact WALK in writing or by telephone. In the first instance your comments will be dealt with by our Quality Development Manager.

Please give as much information as possible and let us know how you would like us to respond providing relevant contact details.

Write to:

The Quality Development Manager Sandra Burke 1 Long Mile Road Walkinstown Dublin 12. Tel: 01 4650388 Email: sandra@walk.ie

We are open 5 days a week from 9.00am to 5.00pm and closed between 1.00pm and 2.00pm each day.

Data Protection Good Practice Note

This document explains what WALK need to do to comply with the Data Protection Act 1988 as amended by the Data Protection Amendment Act 2003 (hereinafter collectively referred to as the Acts and statutory Instrument Number 535 of 2003 European Communities (Electronic Communications Networks and Services) (Data Protection and Privacy) Regulations 2003 (“SI 535/2003”, as amended by SI 526 of 2008) in addition to wider European directives.

WALK must become fully aware of Data Protection. We must comply with the law and be transparent and accountable for how data is processed. To do so we must ensure that staff, clients and volunteers understand their responsibilities thus affording them and WALK protection from liability.

Registering with Data Protection Commissioner

While certain categories of data controllers are obliged to register with the Data Protection Commissioner, there is no requirement for not for profit charities to register, however just because WALK is not required to register this in no way obviates our need to comply with all the requirements of the Act.

Direct Marketing

Underlying Principles

WALK may engage in a range of activities that could be described as marketing or that requires marketing based activities to achieve further objectives. Therefore WALK will observe good practice which suggests that all unsolicited direct contact with individuals will be treated as marketing. This would include seeking donations, marketing goods and services, promoting sponsored events, raffles etc.

Opting Out

Data Subjects have the right to require that their data not be used for marketing purposes. It is therefore required by law to make it clear to data subjects when there is an intention to use their data for marketing and to offer them an opt-out (via a tick-box or an easy to use alternative) at the earliest opportunity.

“Opt-in” means you can only market to an individual where you have their explicit consent to do so.

“Opt-out” means that the Data Subject has exercised their right under the legislation, and opted to be removed from future marketing or mailing campaigns. It is a breach of Data Protection legislation to continue to use their data for marketing purposes once such an opt-out request has been received.

It is good practice with initial fundraising communications to donors, volunteers and others to include an opt-out clause and therefore give the data subject the opportunity to consent to WALK’s communicating with them on fundraising matters on an ongoing basis or for specific activities. A failure to do so and a subsequent communication may result in a breach of the Acts.

Sharing Lists

WALK must not share data with other organisations in order to carry out their own marketing-type activities. WALK must only obtain lists where it can be guaranteed that those on the list have been given an opportunity to opt out, and also lists which can be guaranteed to be sufficiently up to date. When using a purchased list, WALK must inform the recipient how their details were obtained and provide the required direct marketing options. Purchased lists will not be used to send electronic communications i.e. emails and texts to individuals.

A failure to respond by a data subject will be taken to mean they have not opted in to receive further marketing communications.

Any list of groups or contacts held by WALK even if they are in the public domain cannot under the laws of Data Protection be sent to other parties for their own use.

Electronic Contact

Under Data Protection and Telecommunications legislation all electronic marketing (by phone, fax, e-mail or text message) requires consent (opt-in) in all cases. This aspect of Data Protection comes under tighter controls and scrutiny.

Further guidance is available at http://www.dataprotection.ie/d... GENERAL_GUIDE_FOR_DATA_CONTROLLERS/905.htm

In accordance with the relevant legislation, electronic contact with individuals must be on an ‘opt-in’ basis and every such communication must contain the means to opt out.

Data Retention

WALK have certain key responsibilities in relation to the information which you keep on computer or in a structured manual file about individuals this includes information that WALK may keep on staff and volunteers as well as donors. The Acts are designed to protect an individual’s right to privacy and ensure that the data held on them is accurate, lawfully obtained and that there is no unauthorised disclosure of personal data. This equally applies to the personal information held on staff and volunteers.

In relation to retention of personal data, the Acts state that personal information held by data controllers will be retained for no longer than is necessary for the purpose or purposes for which it was obtained. If the purpose for which the information was obtained has ceased and the personal information is no longer required, the data must be deleted or disposed of in a secure manner. However, the Acts do not stipulate specific retention periods for different types of data, and so organisations must have regard to any statutory obligations imposed on them as a data controller when determining appropriate retention periods

Key Risks

There are key risks for WALK that may lead to data breaches:

Through lack of knowledge and training, data may be inadvertently used without clear consent of the data subject. Through poor security and access controls, data may get into the wrong hands. Individuals may be distressed by inappropriate disclosure or by inaccurate or insufficient data. Breaches may occur because clear boundaries may not exist between departments on what data can be shared. Data may be used for purposes other than the specific purpose or purposes for which the data was acquired. Failure to comply with Data Protections rules may lead to heavy penalties.

Definitions

Under the legislation the following definitions are important:

Data

Under the Acts, ‘data’ means information in a form in which it can be processed. Data in this context refers to both automatic and manually processed data. Under legislation there are different classes of data. They include;

Automated Data refers to information that is processed by means of equipment operating automatically. Manual Data is defined as information that is recorded as part of a relevant filing system or with the intention that it will form a relevant filing system. Personal Data means data relating to a living individual who can be identified either directly from the data or from other related information in the possession of the data controller. Under the Acts, Sensitive Personal Data is defined in specific ways as set out below: racial or ethnic origin, political opinions of the data subject religious or philosophical beliefs of the data subject trade union membership or affiliation of the data subject physical, mental health or condition, sexual orientation of the data subject commission or alleged commission of any offence or offences by the data subject any proceedings for an offence committed or alleged to have been committed by the data subject to the disposal of such proceedings or the sentence of any court in such proceedings Processing

DPA 2003 “processing”, of or in relation to information or data means performing any operation or set of operations on the information or data, whether or not by automatic means, including:

Obtaining, recording or keeping the information or data. Collecting, organizing, storing, altering or adapting the information or data. Retrieving, consulting or using the information or data. Disclosing the information or data by transmitting, disseminating or otherwise making it available. Aligning, combining, blocking, erasing or destroying the information or data. Blocking

It means marking data to the extent that it is not possible to process it for purposes in relation to which it was marked.

Direct Marketing

Direct marketing includes direct mailing other than direct mailing carried out in the course of political activities by a political party or its members, or a body established by or under statute or a candidate for election to, or a holder of, elective political office.

Data Subject

The Act defines a data subject as a ‘living individual’ who is the subject of personal data

Data Controller

The Acts defines a ‘Data Controller’ as a person who, either alone or in conjunction with others, controls the contents and use of personal data. By person it does not necessarily mean a ‘living individual’ – but refers to a ‘legal person’ i.e. an organization or a nominated representative. It is the intangible being that controls the organization even though administered and decided upon by the individuals (the Board).

The Act states that a Data Controller, shall, as respects personal data kept by him, comply with the provisions of the Act. Data Controllers have a vast amount of serious legal responsibilities placed upon them by virtue of the Act. The provisions are the rules which are imposed surrounding good information handling to direct the Data Controller to act, in relation to personal data held, in such a way that has the best interests of the Data Subject at hand.

Data Processor

As defined by the Acts refers to a person who processes personal data on behalf of a Data Controller but does not include an employee of the Data Controller who processes such data in the course of his employment.

The Data Processor processes personal data on ‘behalf’ of the Data Controller, thus this provides that the Data Controller cannot abdicate his responsibility to the Data Processor. All of the legal obligations and responsibilities lie with the Data Controller; therefore the Controller still remains liable

The Act states that where the processing is conducted by a Data Processor, the Controller must ensure that the processing is conducted in the pursuance of a contract which is in evidence in writing or another equivalent form. It goes on further to state that the contract must contain clauses that the Processor shall only act on the instructions of the Controller and shall comply with the obligation equivalent to those imposed by the Data Controller with respect to the security of the data being processed.

Data Protection Commissioner

The Commissioner is responsible for upholding the rights of individuals conferred on them by the Acts. He is also responsible for providing enforcement action upon Data Controllers who breach or commit offences against the Acts.

Data Protection Officer

The Data Protection Officer is responsible for ensuring that the WALK complies with the requirements of the Act, raising awareness among staff of their data protection rights and responsibilities.

Ownership groups

Ownership groups are defined as those groups who will use common data. Ownership Groups are a way of controlling access to Contact and Organisation records in a more flexible manner than just departments. Ownership Groups group records together and assign access to them to groups of users or individuals. Access given is not restricted to members of a department. In addition access can be limited to an individual record. This means that individuals across multiple departments can be given differing levels of access to any one or more records.

For further information

Data Protection Commissioner

The Commissioner is appointed by Government and is independent in the exercise of his or her functions. They can be contacted at: Canal House, Station Road, Portarlington, Co. Laois. Ph 1890 252 231 or www.dataprotection.ie

Na... Directory Database

The National Directory Database lists all phone numbers printed in public telephone directories or available through directory enquiries. It also records whether the subscriber has expressed a preference not to receive marketing calls. It applies to voice calls for residential subscribers and to both faxes and voice calls for business subscribers. All ex-directory numbers are automatically placed on the opt-out register. The NDD does not take instructions from individual subscribers, only from line providers

The Irish Direct Marketing Association (IDMA)

DMA advocates industry standards for responsible marketing – both online and offline. www.idma.ie

1. Handling Cash Donations

The Key principles governing cash handling are:

All cash (including cheques, postal orders, drafts, and credit card and gift card donations) is recorded at point of entry and will be capable of being traced through to WALK’s bank account. All cash is banked and acknowledged at the earliest possible opportunity Cash is at all times to be counted by two staff members, one of which will be a staff member authorised by WALK’s accounts department to do so. Cash handling procedures are important to protect the organisation from fraud, theft or embezzlement, to protect staff or volunteers from accusations of dishonesty and to assure donors that their donations and gifts are used for the purpose for which they were given.

1.1 General

Cash received is to be collected, counted and recorded by two WALK employees one of which will be from the accounts department. Cash is counted in a secure environment and held in a secure place until it is possible to bank it. Income summaries ought to be made at the point of counting for reconciliation with banking details at a later stage. Deductions must not be made from cash received. Expenses must be met (where previously agreed) by WALK after receipt of the cash. A receipt is given to the donor recording the amount of the donation, the donor’s details, the source of the donation and the purpose for which the donation is being made (if relevant). If the total amount is not known at the point of handover, this will be recorded on the receipt as an estimate or noted as ‘not yet counted’. Acknowledgements are issued, where requested and where practical, to third party donors e.g. a coffee morning participant, fundraising event sponsor etc. This serves to ensure that the donor receives official confirmation that their donation arrived and will be used for the purpose the donor intended. Records are made of all donations including taking note of those made for specific purposes to ensure donors’ wishes are met Where WALK is unable to apply the donation for the specific purpose nominated by the donor WALK immediately communicate with the donor and to deal with that donation in a manner satisfactory to the donor which may include returning the gift. In principle WALK acknowledge all donations however it may not be either practical or cost effective. A decision can be made as to the level of donations above which an acknowledgement to the donor is practical. All cash handlers have suitable banking bags for counting and bagging up the money. 1.2 Banking

Wherever possible, cash is banked immediately. Night safe facilities will be considered for large amounts banked outside working hours. Counterfoils are retained by WALK by the individual responsible for banking. Cash not banked immediately is placed in a sealed container in a secure place. If cash cannot be banked immediately then it will never left unattended or in an unattended environment.. For security two people will bank the cash, where practical. 1.3 Reconciliation

At the earliest possible date reconciliation is made between cash banked and income summaries. Where practical, this is undertaken by a person other than those involved in the counting and cashing up of the money. 1.4 Petty Cash Floats Where a petty cash float is to be used on an ongoing basis, it is advisable to operate an ‘Imprest’ system (see below). Where possible, draw the float cash on the day it is required and ensure it can be reconciled to the total drawn from the bank. Issue sensible levels of floats that are signed for by a nominated individual. Where petty cash expenditure is paid from the float, this is recorded separately and receipts kept. Floats and any sale monies received are kept separate from the cash handler’s personal money. No float is left unattended or in view at any time. 1.5 Petty Cash Imprest System This system requires that any petty cash spent is documented with petty cash dockets written for each amount issued. When all of these dockets are totalled at the end of the period and deducted from the opening petty cash float, the calculated value must agree with what is left in the petty cash float. Under this system, only that which is recorded as spent is replenished. For example, if there is €40 in the float and €30 of that cash is spent; an amount of €30 will be then placed in the float to bring the balance back to €40. 1.6 Cash Handling and Events

Planning Endeavour to sell any tickets prior to an event to reduce the need for cash collection on the day of an event. Make pricing of tickets or goods for sale sensible (for example, 50 cent, €1,€10, €100 etc) in order to minimise cash handling. All tickets for sale are pre-numbered and sales and takings reconciled. Nominate one individual with overall responsibility for overseeing cash handling. Consider ways in which cash can be held securely, for example, through the use of money belts. At the Event WALK will Issue round quantities of tickets or programmes with sellers signing for the quantity received. Unsold tickets or programmes are returned and reconciled with the record of cash received from each seller. Discrepancies will be investigated without delay. To avoid sellers accumulating significant amounts of cash, pre-designated collectors will collect cash. Alternatively, secure cash-receiving locations will be available to sellers. Collections are recorded on a summary with a signature from the sellers signifying the amount of cash collected. In certain circumstances it may not be practical for cash to be counted at interim stages during the course of an event, however, a record that a collection has been made will be evidenced by signatures from both collectors and sellers. All final amounts including floats are collected and recorded from all locations at the end of an event. 1.7 Relations with Stakeholders

Relations with Donors Donors are encouraged to make donations by cheque made payable to WALK or by credit card where practical rather than cash. Donors are instructed never to make a cheque payable to a named individual. Donors will be discouraged from sending cash donations through the post. WALK makes it clear that donations will be sent to the charity’s offices rather than to the fundraiser’s home Fundraising on behalf of charities Anyone considering fundraising on behalf of WALK will let WALK know in advance as the charity will be able to provide support and assistance. It is the responsibility of the event organiser to ensure that they have the appropriate insurance cover for their event. Where a donor has conducted a fundraising event without prior notification to the WALK, they will be informed of the value of informing WALK in advance for any future activities. Relations with Volunteers Volunteer cash handlers are given clear instructions from which to work. All volunteer cash handlers have appropriate documentation from WALK authorising them to handle cash (such as an ID card, letter of authorisation). Volunteer cash handlers will be supervised by WALK staff member where possible. WALK will try and verify the competence and integrity of volunteer cash handlers in advance; where possible take up references. Where children are collecting money (for example, sponsored swims, bag-packing etc.) they are accompanied at all times by an adult, and the relevant documentation (sponsorship cards) in regard to pledged monies will be available for inspection by the sponsors. It is illegal for children under 14 years to take part in cash collections (Street and House to House Collections Act 1962 as amended). WALK will ensure that adequate insurance cover is in place and that cash handlers understand and follow the conditions of that cover. 2.1 Promises of Money

Where non cash collections comprise the collection of ‘promises of money’, such as Standing Order or Direct Debit mandates this is known as ’Direct Recruitment’ fundraising. This form of fundraising is supported by a Code of Practice devised by the Irish Forum for Direct Recruitment (IFFDR), a charity-led initiative established by participating charities in 2003. Under the Charities Act 2009 this form of fundraising will require a Garda permit in the future.

The key points of the IFFDR Code are set out below. See www.iffdr.org for a full copy of the Code of Practice. Outlining the Responsibilities of the Charitable Organisation when engaging in Direct Recruitment Fundraising

If WALK is carrying out the fundraising activity (either on its own behalf or via a third party) must be responsible for all aspects of the fundraising activity as it is implemented. WALK must:

Ensure that all fundraisers wear identification badges at all times so that any potential donor can verify who they are, who they are working for and on whose behalf they are fundraising. Ensure donor information and charity-branded material is kept secure at all times. Ensure that all fundraisers have agreed and appropriate support materials at all times. Provide a clear point of contact for supporters and the general public, including an initial point of contact with regard to any complaints or queries in line with IFFDR complaint procedures. Deal sympathetically, courteously and promptly with any questions or complaints in line with IFFDR Complaint Procedures. Manage the fundraising activity to ensure that approaches are undertaken in an appropriate manner. It is recommended that, where paid, fundraisers will be remunerated on such a scale that will avoid the incidence of pressure on the potential donor to donate. Charities must make themselves aware of how fundraisers are paid (this applies where a charity engages a third party organisation to fundraise on its behalf). Be responsible for ensuring that compliance, in full, with the minimum standards of this Code of Practice, is maintained by the charity and/or its fundraising agents as applicable. Encourage continuous monitoring of compliance with this Code of Practice through anonymous participation (sometimes called “mystery shopping”), and by quality control calls, conducted by the charity and the organiser. In relation to door to door activity, monitoring can also be conducted by the use of comment cards bearing the contact numbers of at least two of the following: the organiser, the charity and the IFFDR. Be responsible for the recruitment, training and adequate supervision of all fundraisers. Ensure training is provided in person by an authorised and suitably qualified appointee of the organiser of the fundraising activity. 2.2 Non Cash Collectors–Promises of Money

Training for non-cash collectors must include measures to ensure that all Direct Recruitment Fundraisers orally disclose to each donor who they are employed by, who they represent and that they are paid. This must be done by the fundraiser before the donor fills out the form and during the conversation (unless the conversation is terminated by the member of the public). WALK will also include this information on the printed form given to the donor.

2.3 Other Non-Cash Donations

Non cash collections may also comprise cheques, postal orders, credit card details, gift cards or other means. They may be handed over in person at events or received through the post (see Handling Postal Donations below).

3.0 Handling Postal Donations

All post is opened in the presence of two staff members who are independent of the staff responsible for banking the cash. All post is recorded at point of entry with any cash evidenced by two signatures (cash includes cash, cheques, drafts, postal orders, credit card or gift card donations). Any cash donations are removed and held in a secure location until they are banked. All donations are acknowledged within an agreed timeframe, for example within 48 hours (with an exception during particularly busy periods)