Small Charitable Donations Bill

Memorandum submitted by Camphill Scotland (SCD 02)

1. Camphill Scotland promotes the development and wellbeing of Camphill communities in Scotland. Scotland is home to 12 Camphill communities, where people with learning disabilities and other support needs live and work alongside those who support them. All Camphill communities in Scotland are registered with the Office of the Scottish Charity Regulator, and participate in a range of fundraising activities.

2. Camphill Scotland welcomes the intention behind the Small Charitable Donations Bill to enable charities to claim a gift aid style payment on cash donations up to £20. We are concerned, however, that some of the measures in the Bill as drafted will exclude small charities, who could most benefit from this additional income, from being able to participate, and unduly limit the opportunities for all charities to make use of the scheme.

3. We have been made aware of the Bill by the Institute of Fundraising, and share their concerns about the Bill. We only became aware of the Bill in August 2012 and did not submit evidence to previous consultations on the Bill. We did submit comments during the public reading stage of the Bill.

4. Our primary concern is that the principles of the Bill should not be restricted to cash donations. Camphill communities are starting to explore the possibility of new ways of enabling donations, such as by text message, and the Bill as drafted would either 1) discriminate against those choosing to use this technology or 2) discourage charities from making use of this technology, which could be used to target new donors. In addition, Camphill communities still receive some donations by cheque. While this should enable donors to be traced and a Gift Aid declaration to be put in place, it is worth noting that the administration required to arrange this for, for example, a donation of £10, would cost more than the Gift Aid reclaimed. We believe that the Bill should not restrict the Small Charitable Donations Scheme to cash donations.

5. In addition, we believe that the requirement to have claimed Gift Aid for 3 of the last 7 years is unnecessary. While it is clear that charities will need to be registered for Gift Aid to be eligible for this scheme, it seems unfair to exclude charities who have only registered for the scheme within three years. This is particularly the case for small charities, who may not have previously registered for Gift Aid as they mainly received small donations, and would have to wait three years to benefit from the scheme.

September 2012

Prepared 16th October 2012