The consultation allowed the public and key stakeholders to provide their views on a draft version of the guidance that I’ve been responsible for writing, developing, and reviewing over the past 10 months.
At the Commission, we work hard on developing our guidance and take pride in it. It should be clear, balanced and easy to follow and use. Work on our CC series, and our other key guidance, is usually led by our policy team – although we always involve a variety of expert commission staff in different roles to ensure we create the best product possible.
Seeking external views
However, consulting on our guidance and seeking external views is just as valuable. Outside input ensures that the guidance is relevant, useful and grounded in the context within which charities operate. Is our description of the law clear? Have people understood our messages in the way we intended? What’s working and what isn’t? The consultation process is something I, and the rest of the team, find extremely useful.
It also keeps us alert to important factors such as what readers make of our tone of voice, and whether the format and language functions well for busy trustees and other users. Feedback isn’t always easy to hear, but when a team manages a document over a significant period of time blind spots – both small and more significant – can creep in. The consultation process helps us to expose issues that a careful internal review might not.
Our guidance needs to work equally well for the trustees of very large and much smaller charities, so respondents quite rightly use the process to tell us if our proposals could lead to implementation problems in their part of the sector. For CC20 for example, we received valuable input about the role of staff in larger fundraising charities and as a result made key changes to the guidance, such as including more information on the role of delegation.
The consultation process
There were 13,982 visits to our webpage during the consultation period for CC20 and we received 74 responses, mostly through our online survey. However, these numbers are deceptive. These are respectable numbers for this type of consultation but certainly don’t do justice to the 100 pages of considered and thoughtful comments we received and to the conversations, membership meetings and working parties that were set up by respondents to discuss and compile views. I was particularly pleased that 85% of the responses we received from larger fundraising charities had been discussed or agreed with input from their trustees. That’s so important; after all, the principal audience for this guidance is trustees.
Before, during and after the consultation, our team was able to attend events to talk about our proposed approach. We also participated in some structured conversations with charities and others, as well as some less formal ones. These helped us to understand and find solutions to some of the key issues raised with us by stakeholders. For example, we redesigned the guidance checklist so that it is now more adaptable to the needs of charities of different sizes, and changed key language and expression where we agreed with respondents that it gave the wrong emphasis.
Of course we have to decide which suggested changes to run with and where to maintain our regulatory approach and presentation. We thought very hard about those decisions with this guidance and we know that the end result can’t – and won’t - please everybody. We often find that with guidance, people have become very familiar with the existing version and would prefer to keep it. But CC20 had to change and we think the changes made will make a real difference. Whilst we recognise that responding to our consultations takes time and commitment from people who are already stretched, these contributions are essential to the creation of effective guidance. Thanks to the ideas and insight we received on the draft version, CC20 has been strengthened in key ways and we are very grateful to everyone that participated in the process.