Donations and Ethical Fundraising Policy
1) Purpose
To set out how we accept, refuse or return donations and fundraised income in a way that protects beneficiaries, upholds our values, and complies with law and guidance, including The Fundraising Regulator’s Code, Charity Commission Guidance and UK GDPR legislation.
2) Principles
Public benefit & independence: Donations must further our objects and must not compromise independence.
Integrity & transparency: We fundraise honestly, respect donor intent, and report clearly.
Safety & respect: We protect vulnerable people and handle data lawfully.
Value for money: We seek efficient, proportionate fundraising activities.
3) What we can accept
Unrestricted funds: Preferred; enable greatest impact.
Restricted funds: Accepted where the restriction aligns with our objects and is practical to deliver.
Gifts-in-kind: Including donated tech, services or venues, where safe, legal and useful.
Corporate support: Donations, sponsorship, employee giving, and matched funding that meet this Policy.
4) Conditions for acceptance
We will accept support only if it:
Aligns with our charitable objects and values;
Does not impose undue influence over strategy, operations, or research findings;
Is not illegal, unethical, or high-risk (e.g., linked to criminality, sanctions, modern slavery, serious environmental or human-rights abuses);
Is deliverable within our capacity and risk appetite and policies and procedures; and
Is transparent: donor identity is known to the Charity (anonymous public recognition is allowed for in section 10).
5) Due diligence (risk-based)
Standard checks: Identity, source of funds, Companies House/Charity overview, adverse media.
Enhanced checks (trustee sign-off required) if:
Single gift ≥ £10,000 (individual) or ≥ £25,000 (corporate); or
Cumulative support above these thresholds; or
Higher-risk sectors/jurisdictions; or
Conditions/restrictions attached.
Outcomes: Accept / accept with conditions / decline. Document rationale in a brief decision note.
6) Conditions & restricted gifts
Conditions must be compatible with our objects and not create private benefit or control over governance.
We will document restrictions, budgets and reporting in writing.
If delivery becomes impossible, we will seek donor consent to vary; if not possible, we may return funds or apply to the Commission for a cy-près scheme (as appropriate).
7) Returning or refusing donations
We may refuse or return a donation if it:
Risks significant reputational damage or conflicts with our values;
Is suspected to derive from criminal activity;
Imposes inappropriate conditions; or
Cannot be used for the stated purpose.
Serious concerns will be escalated to the Board and, if necessary, to relevant authorities.
8) Corporate partnerships & sponsorship
Must be arm’s-length and consistent with our values.
Any recognition (logos, case studies) must not imply endorsement of products or unduly influence our independence.
Written agreements will set deliverables, recognition, brand use, and termination rights.
Where the donor is Tech-Takeback Ltd or provides services to us, the Conflict of Interest Policy and independent trustee approval apply; pricing and terms must
represent value for money.
9) Gifts-in-kind (including donated tech)
We accept donated devices and services that are safe, lawful and useful.
For Retail Gift Aid (sales of donated goods), we will operate the HMRC Retail Gift Aid scheme with compliant: donor declarations, proceeds notifications, and audit trails.
For corporate donors, we will provide acknowledgment letters suitable for their tax and VAT records (not tax advice).
10) Anonymity & recognition
Donors may request public anonymity; we still record their identity internally for due diligence and audit.
Recognition will be proportionate and must not suggest undue influence.
11) Fundraising standards & vulnerable people
We follow the Fundraising Regulator’s Code and have procedures for vulnerable circumstances (e.g., capacity, undue pressure).
We do not conduct high-pressure fundraising or targeted asks to vulnerable people.
12) Gift Aid & records
We claim Gift Aid where valid declarations are held and HMRC rules are met.
Records (including Retail Gift Aid) will be retained per our Data Retention Schedule.
13) Data protection
We comply with UK GDPR and PECR; lawful bases are documented; supporters can change preferences at any time.
Data sharing with processors (e.g., email/CRM providers) is governed by contracts and security standards.
14) Roles & responsibilities
Fundraising Lead / COO: Applies this policy, conducts due diligence, documents decisions.
Trustees: Approve policy, oversee higher-risk/threshold decisions, monitor compliance.
All staff/volunteers: Follow the policy; escalate concerns promptly.
15) Complaints & whistleblowing
We operate a Fundraising Complaints process and signpost the Fundraising Regulator.
Concerns about illicit finance or serious wrongdoing may be raised via our Whistleblowing route.
CONTACT US
If you have any questions regarding this Privacy Policy or the practices of this Site, please contact us by sending an email to hello@techtakebackfoundation.org.uk.
Last Updated: This Policy was last updated on 21 January 2026