Further memorandum from the Association
of Charity Shops (DCH 291)
The Association of Charity shops has noted the
Institute of Licensing's submission to the Committee highlighting
the problems of "bogus" collections of goods from householders
and wishes to reiterate our concerns about this issue. The Association
has spent years highlighting the need for something to be done
to address the problems of "bogus" collections of goods
and raised this as a major concern in our responses to the Strategy
Unit in 2002 and the Home Office in 2003 as well as in our first
submission to this Committee. These collections deceive the public
and reduce the level and quality of donations in collections undertaken
by genuine charities in support of their shops. We have regularly
brought these activities to the attention of the Charity Commission
and the Home Office over the past five years or more. This remains
an area that is not adequately regulated.
We are in full support of the Institute of Licensing
in their call for arrangements under the new Charities Bill to
tackle this problem area. However, there is a danger that their
solution will lead to a tough, costly and unworkable regulatory
framework for collections by charity shops.
Everyone accepts that genuine charity shop collections
pose few issues of capacity and raise no questions of public confidence,
nuisance or fraud. There is evidence showing that giving to charity
shops is the most popular way of supporting charity. The Association
has therefore consistently argued for a "light touch"
regulatory framework for the collection for goods by charities
for their shops. As a result the draft Bill proposes to substitute
applications for licenses for the collection of goods with a simple
notification arrangement (albeit the notification requirement
as currently drafted is unworkable as highlighted in our earlier
submission to the Committee).
In its response to the Strategy Unit consultation
in 2002, the Association called for measures to be put in place
to require all commercial organisations (and non-registered charities/voluntary
organisations) to be actively licensed if they wish to collect
goods house-to-house whilst the regular, well-supported and relatively
low risk collections for charity shops should be subject to a
simple notification system that will enable local authorities
to know which of these collections are taking place in their areas.
The Association therefore suggests that the
Bill be suitably amended to allow for a simple annual notification
system for collections of goods by registered charities with an
active individual licensing procedure for collections by other
organisations. Such a system would allow local authorities to
focus their efforts and time on dealing with bogus collections.
Past experience in England has seen charities struggle to gain
the interest of the police and local authorities in taking any
action against illicit collections. These are often organised
by commercial companies who are purporting to be "doing good".
This lack of action remains a problem even where there is evidence
that they are flouting the law.
We are pleased that the issue of cracking down
on bogus collections is now being taken more seriously. However
whatever measures are introduced to properly control such fraudulent
activity should not be at the expense of collections undertaken
by genuine charities for their shops.
July 2004
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