Among the Third Sector it appears common practise to utilise the National Change of Address database managed by Royal Mail to ascertain new contact details of their supporters.
However, after a recent paper published by the Information Commissioner’s Office on ‘Fundraising and Regulatory Compliance’, confusion has arisen within the industry as to whether this actually goes against the Data Protection Act.
The paper discussed all aspects of the DPA relevant to charities and fundraising organisations covering everything from its stance on wealth screening to re-using publically available information.
Cause for confusion arose around the section dedicated to Data Matching and Teleappealing which are activities involved in “obtaining personal data from other sources which individuals did not give you when you initially collected their personal information.”
This leads to believe that using a third party, such as Royal Mail, to ascertain a supporter’s new address after they’d moved house would be going against the DPA.
The paper goes on to provide examples of wrong doing:
After contact with the Fundraising Regulator, clarification has been made.
“If the individual, of their own volition, instructs Royal Mail to redirect all of their personal mail via this service, there is no problem with a charity acting on this request and using the new details”
In summary, they can use data for Data Matching and Teleappending if they are satisfied that the source is legitimate and the supporter has made it clear, by ticking a box or some other positive action that they wanted to inform third parties of the change of address.
To conclude, charities and other fundraising organisations can utilise Royal Mail’s NCOA service to ascertain new contact details of the supporter, if they have opted-in for you to do so via a third party when submitting their new personal information.