JustGiving and Streeva (which operates the SwiftAid solution) have joined together to integrate their systems to help maximise Gift Aid claims. Oliver Shaw Latimer, Director of Global Fintech at Blackbaud and David Michael, CEO and founder of Streeva provide an update on their progress at a CTG Expert Insight Session on 14 July 2022.

• Presentation slides
• Meeting recording

The presentation also provided a fascinating insight into the extensive data cleansing systems JustGiving now has in place to ensure data is valid and the donation is eligible for Gift Aid – refer to slides 8-10 of the presentation for further details.

Written responses to questions tabled at the meeting can be found below.

How do you ensure direct giving to charities is not from a pool of funds (i.e. a raffle)?

[OSL] on JG we don’t include explicit opt-in statements for direct giving so we rely on donors reading/understanding this eligibility criteria. On direct donations we took a view – with HMRC – that these occurrences were marginal enough that they weren’t worth disrupting the Gift Aid flow for every donor. On Fundraising page scenarios on the contrary, we went down the route of displaying the eligibility statements.

If JG removes gift aid is the donor informed?  The donor needs to know as they may be claiming higher rate relief.

[OSL] yes, the donor is usually informed via email. Furthermore, the donation published on the fundraising page is specified as not having Gift Aid included.

Do you use the standard HMRC year end Gift Aid statement or do you have an easier to read but still compliant version?

[DM] We have our own statement design that meets the requirements. In addition to the requirements, we also include detail of all donations including the charity, amount, date and donation method (e.g. JustGiving).

As a donor, I am very concerned about JG automatically registering me with SwiftAid when I make a donation to one charity and select gift aid – surely this needs to be optional.? It seems the only way out is then to cancel the SwiftAid account after every donation, which is quite a messy process as you first have to ask SwiftAid to send you a code.  I have two concerns: (a) For donors who pay a bit of tax but not that much, they may well only be able to gift aid SOME of their donations and need to retain the right to select gift aid separately for some charities but not others: that’s fundamental to the gift aid consent process. (b) Any kind of “automatic” transfer of data to a third party – which authorises SwithAid to match donations form other charities surely requires an opt-out under GDPR.

[OSL] We considered offering an option to add Gift Aid without including Swiftaid but have opted not to at this stage as it’s detrimental to clarity, overall user flow on our Gift Aid declaration and reduces the overall ‘scale data’ value of the Swiftaid network. It’s key to underline here that where Gift Aid is included ‘automatically’ (without an explicit declaration) donors always have the option of removing it on a per donation basis before they complete the transaction. We understand that some donors will opt to forgo Gift Aid altogether vs registering/deregistering from Swiftaid as part of the process but consider this is outweighed by the upside in Gift Aid this approach generates as a whole.

How do you manage people who wish to claim Gift Aid retrospectively?

[OSL] on JG, we perform an automatic retrospective claim spanning the previous tax year. (DM) May wish to reword this to where Swiftaid is authorised to provide a Gift Aid declaration

[DM]  At Swiftaid we are facilitating a retrospective on donations where we hold a donor intermediary authorisation. We have looked at 4 years of retrospective, but any solution would require the donor to provide the declaration on donations before the current tax year. (Swiftaid as a donor intermediary is limited to donations within the current authorised tax year).

If donors have signed a declaration with Swiftaid and then we have an audit with HMRC, what evidence of a declaration would we have?

[OSL] it’s no different to JG holding the Gift Aid declaration. In the case of a direct integration to Swiftaid, I defer to David

[DM] Swiftaid would support any audit by providing the records required by HMRC.

How does someone ‘opt out’ of Gift Aid if the SwiftAid system recognises them?

[OSL] by removing it from their donation in the checkout. They can edit the GA selection, which will remove the donation from our submission to HMRC.

What is the normal practice for renewing donors gift aid declaration?

[OSL] in the JG use case, a new Gift Aid declaration is presented on the first donation made in the tax year. Opting in renews the Gift Aid declaration for the tax year in flight. It stays active until the end of the tax year (when it automatically resets) or until the donor informs JG/Swiftaid they want it turned off.

What are the main principle criteria for allowable Gift Aid claim on major gift donors?

[OSL] If they have opted into a Gift Aid declaration, we will submit their claim to HMRC. For any donations exceeding £5,000 we will send them a notification email prior.