Charities complete an Annual Return which requires them to submit information about their activities and finances to the Charity Commission. As the Commission improves and rolls out new digital services, it is consulting on a new system which would see charities updating the information they provide on a more frequent basis so that a more accurate picture of the charity can be maintained, reflecting changes that occur throughout the year. DSC give their response to this.
Summary of key points
Obligation to update data – While it may be a good idea to give charities the option to update more regularly, it is unclear whether the Commission would expect every charity to update information more often than annually. Will it be a requirement (‘must’) or best practice (‘should’)? What does ‘should’ mean in this context?
Frequency of updating data – It is unclear how often the Commission would expect information to be updated. While some charities may be able to update information as soon as it changes, other charities may find it more difficult – for example smaller charities or those whose trustees only meet a couple of times a year.
Maintaining data quality – Will the process of updating information include any scrutiny by the Commission of Annual Return information that is supplied by trustees? If not, there may be errors and inaccuracies introduced into the data.
Relevance of self-disclosed Annual Return information to risk priorities – While it may be appropriate to structure and segment future Annual Return questions around some of the Commission’s risk priorities, it is difficult to see how this would work with others. Any targeting of particular charities with questions themed around the Commission’s risk priorities must be done on the basis of a fair, consistent, evidence-based framework, to ensure particular types of charities are not unfairly burdened. For example, how would a question on the Annual Return provide meaningful data about potential terrorism or extremism risks?
Consultation process – Given that the information that is collected in the Annual Return may change after this review, the logic of conducting the present consultation isn’t completely clear and makes it difficult to comment on the implications of the Commission’s proposed changes.