DCH 73 Acorns Children's Hospice
Acorns Children's Hospice submission
to the Joint Committee considering the draft Charities Bill
Summary
We are a medium sized charity in the
Midlands with 35 shops and 50% of our stock is obtained by collections
made house-to-house. As well as raising funds for our charity
we also help recycle unwanted goods and we feel we deliver a vital
social benefit to those on low income including the unemployed,
students and pensioners.
As we originally made a submission
concerning the regulation that should apply to the collection
of goods for charity shops we are pleased that the representation
that such collections do not pose significant issues of public
trust, confidence or capacity has been accepted. The removal of
such collections from the licensing regime is very welcome.
However, the benefit of this de-regulatory
measure has been totally negated by the specific notification
requirements set out in section 66 C (2) of the draft Bill. The
requirement to notify the precise day or dates and locations of
each collection to local authorities at least 14 days and no more
than 6 months in advance takes no account of how these collections
are organized and is totally unworkable.
Such a requirement would cost us very significant sums of money
in administration and result in shops running out of stock, suffering
reductions in sales and the sums they raise for our charity. There
is no proportionate benefit from such a detailed
notification system.
A change to this requirement in the
Bill is therefore vital if our charity shops are not to be placed
under a disproportionate and potentially threatening notification
regime the penalties for breaking which would be severe (the new
penalty of a fine of up to £1000 for failure to notify for
each offence). As the Standing Committee is particularly reviewing
whether or not the draft Bill introduces proportionate regulation
and whether the proposals for the regulation of fundraising are
workable, we seek the Committee's support
for an appropriate amendment to be made to the notification requirements
for the collection of goods and set out in more detail our arguments
and alternative proposal in support of this below.
How we collect our goods
Our charity shops are relatively small
in area on average less than 1000 sq.ft. Stock is donated
directly to the shop and cannot be gauged
in advance and in addition our charity collects house-to-house
by the dropping off of collection sacks through letterboxes and
subsequently collecting from doorsteps. This activity is largely
impersonal and there is much evidence to show that donating to
charity shops in this way is strongly supported by the public
(see the Charity Shops Association's earlier submission to the
Home Office). This activity also contributes significantly to
environmental targets for the reuse and recycling of clothing,
books etc.
Because our shops are small, the
space allocated for the receipt and sorting of stock is restricted
to approximately 300 sq.ft. Stock received is sorted, priced,
put on the shop floor or removed for recycling or for rubbish
on a daily basis. Maximizing sales is dependent on maintaining
good stock levels and regularly refreshing the stock on sale.
As the collection of goods house-to-house is approximately 50%
of our stock received it is vital to our success. Our Merchandise
Manager organises the collections for our group of shops and makes
the decisions on when and where the collections take place and
these are based on stock levels, anticipated needs, the availability
of collectors and vehicles on a regular and continuing (weekly)
basis. Consideration is also given to health and safety and other
management information on stock quality, rates of return and the
good practice requirement of the Charity Shops Association's own
Kitemark scheme to which we have signed up to avoid overlapping
collections with other charities.
We organise collections for around
25 of our shops in 10 different local authority areas currently
and apply for licenses to collect from each and receives permission
for periods of up to a year on the basis that we will be collecting
between once a month and once a week for each for our shops. It
is worth noting that specific date notification is currently not
required by local authorities granting licenses to collect; instead
a generic description of the frequency and general location of
the collections is accepted in granting licenses. Although
our charity will be relieved of the burden of applying for these
licenses - we would have a far heavier burden to carry in notifying
exact collection dates and locations to each of the local authorities
for each collection at least 14 days in advance. So whereas we
currently make 10 applications and 10 reports in a year - we would
be faced with attempting to make a notification for each collection
carried out by each shop to each local authority. On an average
of one collection per shop per week this would amount to a minimum
of 25 x 50 (operating weeks in the year) = 1250 notifications
a year assuming that no one shop collects across more than one
local authority area (which is not the case). The bureaucratic
burden on our charity will significantly raise our operating costs
and decrease what our shops raise for the hospice's vital work.
And this assumes that the date or dates of the collections and
precise locations can be specified accurately in advance, which
we cannot do because collections are carried out continuously
as and when the need for stock arises, when vehicles and drivers
are available and in the light of other management information
such as response rates, quality of stock and where other recent
collections have taken place.
We hope it is clear from our example
that there is an urgent
need to modify the notification requirements set out in the
draft Bill for the collection of goods in order that an unworkable
level of regulation is not introduced as part of the new Bill.
Amendment sought
We therefore believe that paragraph
66 C (2) of the draft Bill should be amended so that the notification
required for the collection of goods house-to-house by charities
to local authorities should be made only on a periodic basis (e.g.
annually) and in more general terms as regards timing/frequency
and location. It should not be required for every
individual collection. This is currently the type of information
submitted to local authorities when applications for local licenses
to collect goods house-to-house are made. Such a general notification
system would continue to provide local authorities with the information
necessary to enable them to monitor and control unauthorized collections
whilst enabling us to continue to successfully collect stock,
raise vital funds for our charity and play our role in maximizing
reuse and recycling. In addition appropriate guidance should be
issued to local authorities as to the required format of the notification
information.
We are happy to provide further information
in support of our submission if required and are grateful for
the Committee's active consideration of our concerns.
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