Guide Dogs — Written evidence (CHA0109)

Guide Dogs provides mobility services to increase the independence of people with sight loss in the UK. Alongside our mobility work we campaign to break down physical and legal barriers to enable people with sight loss to get around on their own terms.

The role of charities in civic society

Charities fulfil an important function in civil society in England and Wales. Charities give support to those in society who need it most. Charities’ work spans a range of areas: medical research, supporting hospitals and hospices, supporting disabled people, protecting vulnerable children, protecting animals and the environment and providing life-saving support during emergencies overseas.

Guide Dogs is unique and we are not aware of any private, public or third sector organisations providing a similar service. We are the largest breeder and trainer of dogs in the world, supplying approximately 850 guide dogs per annum to people with sight loss. We support 5000 active guide dog partnerships and we provide services to over 10,000 people in the UK.

The Government rightly respects the voluntary sector as partners in securing a transformed, sustainable health and care sector. The provision of guide dogs and other mobility services is crucial to the physical and mental health of the people we support. We promote independence and wellbeing, reduce loneliness and isolation, and in doing so, contribute to local and national health priorities. Working as Blind Children UK (part of the Guide Dogs group) in a year we provide habilitation mobility and lifeskills training to over 1,300 children with sight loss and work with over 850 families with a child with visual impairment.[1]

In the words of our beneficiaries themselves:

“Getting a guide dog … completely changed my life. I had tried to learn how to use a white stick, but it made me feel so isolated. It’s been eight years since I lost my sight, but with my lovely guide dog Twiggy by my side nothing can stop me!” Sally

“Now it’s like I have a whole different life.  Before [guide dog] Hattie I was nervous and I wouldn’t leave the front door, now I’m everywhere.” Becky.

"Guide Dogs made a huge difference to my life. It means I can be a Mum again and take my children to school, without having to rely on anybody else. That means so much to me". Diane

In addition to the services that charities like Guide Dogs provide, charities add more value to the economy than the arts and agricultural sectors. They employ an estimated 765,000 people in total and the sector is a major employer of disabled people (around 20% of its employees).[2] Guide Dogs is a proud “two ticks” employer and promoting diversity within our workforce is a core organisational objective.

In addition to our 1,400 paid staff, we have around 16,600 active volunteers filling 26,000 roles. Volunteers give more than 16.7 million hours of their time to us each year and we couldn’t provide our services without their support. Around a third of volunteers work in dog-care roles, a third in fundraising and a third in providing services such as driving or sighted guiding. Around 800 of our volunteers are also service users, which is higher than the sector standard for volunteers.

Our volunteer demographic is mostly older people in dog and fundraising roles but we attract younger volunteers through initiatives such as our “A Million Hands” Scouts Association partnership through which we reach out to 500,000 young scouts.

The number of our volunteers increases by around 1,000 each year, many of whom are younger people who join our sighted guiding service MyGuide.

Guide Dog volunteers get a lot out of their work with us through “giving back” to society and learning new skills. A recent volunteer survey found that wanting to learn skills was a strong reason motivating volunteers and we spend time and resources in developing volunteers: many of our volunteers said that they had been “trained” by Guide Dogs and a large number of volunteers strongly recommend the experience of working with us.

Pressures and opportunities

We are constantly under pressure to meet demand. We currently have around 750 people on our waiting list, split almost equally between people waiting for a first dog and those waiting for a successor. We make a lifetime guarantee to all guide dog owners that we will provide them with a guide dog for as long as they need one. We pay for all breeding, training, food and veterinary costs of a dog during its life and the total cost of a guide dog is almost £55,000.

The ability to fundraise presents a significant challenge for Guide Dogs as well as the rest of the sector. Forty-six per cent of the sector’s income comes from individuals, compared to 33% from government grants and contracts.[3] Individual giving is therefore extremely important and British people are ranked as some of the most generous in the world,[4] with around 22.9 million adults donating money to charitable causes in a typical month.[5] Guide Dogs receives only minimal government funding (such as the recent allocation of LIBOR fines to provide services to veterans with sight loss) and so, to fulfil our lifetime promise to guide dog owners, we depend on donations from members of the public more than others in the sector.

Media reports in 2015 showed some charities engaged in poor fundraising techniques, some of which were truly shocking. However, the vast majority of charities operate ethically and responsibly. The Public Administration Select Committee found “most of the charities in the UK do not engage in [poor fundraising] practices”[6] and evidence submitted to the committee showed that most fundraising “happens to a high standard”.[7]

Guide Dogs hugely values our supporters and we want our fundraising to match their expectations. We don’t share supporter details. We closely monitor fundraising and adhere to a strict contact strategy to limit frequency of contact. In 2014 our overall complaint ratio was 0.000039% (over 6 times lower than the industry standard).

It is essential for the sector to regain the trust of the public and we support safeguards to protect donors. At the same time, regulation needs to get the balance right to avoid unintended consequences and serious harm to the sector.

The two main proposed reforms to fundraising regulation are the Fundraising Preference Service (FPS) and the EU General Data Protection Regulation (GDPR) which will require charities to obtain “unambiguous informed consent” from their contact. If calibrated wrongly, the FPS and GDPR could wipe out years of positive relationships with donors and potential donors, and put our service users at risk.

It is unclear how the FPS and GDPR will work together and fit with existing legislation and reforms already made. The holistic impact of all reforms have to be considered to measure the effect on the sector and to reduce conflicts between the FPS and GDPR and confusion for the public. For example, the FPS requires individuals to “opt out” of receiving charity communications, whilst the GDPR may require people to “opt in”. The risk is that this causes confusion rather than empowerment for the public.

Further confusion may arise from the FPS’ duplication of function with existing preference services. Indeed, the Information Commissioners Office has stated:

“The new service would both duplicate some features of the already existing Telephone Preference Service and would confuse the public.”[8]

The Opt-in Working Group, which is tasked with making recommendations based on implementation of the GDPR, have made a number of recommendations which go beyond the original scope of the GDPR. We are concerned that the group’s recommendations mean that charities will be held to more restrictive and limiting codes of practice than the commercial sector. For example, the Working Group recommended that charities should not mail individuals more than once a year. There is no comparable recommendation for commercial organisations, who can contact people as much as they want which means that the problem of individuals receiving too much unsolicited mail will not be properly addressed. 

If a member of the public uses the FPS reset option, it will override existing instructions they have given to charities about contact and the latest proposals suggest charities will only be given one opportunity to contact the supporter again. We believe this kind of blanket approach is unnecessary, especially with the safeguards already introduced around the buying of data in the Institute of Fundraising Code of Practice which means that mailing volumes should have already decreased substantially. The FPS could lead to many people unwittingly opting out of communications from charities that they support. The PACAC found that the FPS would place limitations on charities’ activity that do not exist for any other sector, leading the Committee to conclude in its report:

“We are not persuaded of the case for a new Fundraising Preference Service.”[9]

The FPS Working Group recommendations were published on 24 August and we are in the process of digesting the proposals. The design of FPS is critically important to the future of the charitable sector and so public and charities must be fully involved in shaping its development. A well-developed FPS should allow individuals to stop unwanted communications without disrupting correspondence from charities they support. A less sophisticated system would damage longstanding relationships between individuals and charities.

We support the need to restore public trust in fundraising but it is important that beneficiaries of charities do not lose out as a result. We therefore urge Government to undertake a thorough and holistic impact assessment of proposals to regulate giving across the UK.

Innovation

The smart cities agenda provides opportunity for innovation and we are working to make this as inclusive as possible. Building on our four-year collaboration with Microsoft on the Cities Unlocked project,[10] Guide Dogs is working towards a future where interaction between people and their physical or virtual environments allows them to get around safely and confidently. Smart cities should combine the built environment, transport and public services (such as health, education, retail and entertainment) with new digital technologies to deliver consistent customer experiences that transcend a single service provider’s remit. Interoperability requires government support and facilitation to seed a new approach to delivering positive services.

Government and city administrations can help promote accessible innovation by:

• Including formal requirements in smart city tendering to proactively increase social inclusion, including requirements to work with disabled people.
• Funding smart city projects with a specific focus on cross-sector collaboration to improve inclusion.
• Introduce inclusion metrics and a requirement for initiatives to report progress against inclusion targets set by Government in consultation with stakeholders.
• Encourage standards organisations to focus on inclusion in Smart Cities standards and guidance documents, with an emphasis on interoperability.

Digital mobility solutions will soon be as important as other traditional mobility aids such as wheelchairs, guide dogs and hearing aids. This needs to be recognised by national and local government, designers and technology providers so that inclusive design is at the front of the smart city and digital revolution.

Charities can assist in designing and testing new digital solutions, however they struggle to get digital innovations out of the research and prototype domains. Government support is therefore required to achieve scalability.

Mainstream digital technologies are still not fully inclusive, often requiring additional software or hardware, which increases the cost for the end user. The cost of digital equipment, and training to use it, is beyond the means of many disabled people. The best solutions run on mainstream tablets and phones, but currently these devices are not exempt from VAT as they are not designed solely for disability purposes.

Governance, leadership and trustees

The skills required to lead a charity are dependent on the charity’s strategy and. In general, the high level requirements for charity leadership are:

• Leadership skills                                          
• Financial competence
• Understanding of governance             
• Empathy with the charity’s purpose
• Strategic thinking                                          
• Strong interpersonal and communication skills

Charities can ensure these skills are secured through carrying out a skills gap analysis to identify requirements and then recruiting in an open and transparent manner on a skills and experience basis.

Within the sector it is essential that there is an understanding of the importance of governance and that strong consideration is given within charities to employing a qualified governance professional or seeking external governance advice.

Trustees need to set and agree the strategy and enable the executive to deliver it in accordance with the charity’s vision, mission and values. The trustee role is strategic and there should be clear distinction between this and the operational role of the executive. Trustees need to give proper financial oversight and challenge where appropriate so that the charity is compliant with the law, and to secure the future of the charity. Trustees should select, manage and support the Chief Executive and set objectives to measure their performance and that of the charity.

The board is legally responsible for everything that happens within the charity so the relationship and trust between the CEO and Board is important. Trustees are responsible for ensuring that the composition of the Board is appropriate to enable them to function effectively and regular appraisals should be undertaken.

As with leadership, the charity should carry out a skills gap analysis for trustees and recruit openly and transparently to attract skilled and experienced candidates.  Newly appointed trustees should undergo induction and ongoing training to ensure they understand the work and purpose of the charity; meeting service users and volunteers will give them invaluable insight. Regular Board meetings must be held and sufficient and appropriate information should be presented to help them make decisions in the best interest of the charity. If meetings are held on a quarterly basis, trustees should be updated on the charity’s activities and performance regularly in the intervening period.

Accountability

Accountability is achieved by ensuring that a charity’s aims and activities are within the objects set out in its governing document. A charity can be accountable by demonstrating through its activities and work methods its commitment to the published vision, mission, and values as this will enable stakeholders to assess and define the charity’s efficacy.

The charity should set targets and indicators to measure success based on the charity’s aims, beneficiaries’ needs, the quality of services and available resources. It should regularly review the objectives in its governing document.

The role of the Government

Whilst the Government and the charity sector have a positive and mutually beneficial relationship, there is a perception that the Government does not fully support charities’ campaigning work. According to the Charity Commission, political campaigning is “legitimate and valuable” for charities to undertake.[11] However, there is concern within the sector that charities’ important civic role in campaigning could be at risk following comments and initiatives from Government such as the former Charities Minister Brooks Newmark comments in 2014 that charities should “stick to their knitting” and should not stray into the “realm of politics”,[12] restrictions on charity campaigning through the Lobbying Act, and new grant rules which prohibit charities from using grants for "activity intended to influence - or attempt to influence - Parliament, government or political parties".[13]

Guide Dogs undertakes political campaigning where necessary to our beneficiaries. For example, we campaigned on the issue of dogs attacking assistance dogs.

Between 2011 – 2013, 10 attacks on guide dogs were reported per month. Attacks have serious implications: in some cases they leave a guide dog owner alone with an injured animal, in others, dogs are withdrawn from service leaving the owner without their mobility aid and possibly unable to leave home. Even if a dog continues working, the psychological trauma of the attack on the owner and the dog can affect their ability to go out. In addition to the emotional impact of assistance dog attacks, the cost to the charity between was £170,000 between 2011-2013, money given to us by donors which would otherwise be spent on supporting people with sight loss.

As a result of our work, the Government made it an offence for a dog to attack an assistance dog, helping to address the issue. This illustrates how campaigning is a legitimate activity for a charity and an efficient use of charity resources. We would therefore welcome reassurances from the Government that it recognises the necessity of charities’ ability to campaign.

5 September 2016