Reporting

Reporting Serious Incidents

The Charity Commission requires charities to report serious incidents. If a serious incident takes place within your church, it is important that there is prompt, full and frank disclosure to the Commission.

You need to report what happened and, importantly, let the Commission know how you are dealing with it, even if you have also reported it to the police, a Solicitor or this Association.  You need to do this as soon as possible.

The Charity Commission guidance on this is available here. Quotes in this document are taken from that guidance, which we recommend that all church leaders read in full and adhere to [bold text is ours].

 

What is a serious incident in this context?

“A serious incident is an adverse event, whether actual or alleged, which results in or risks significant:

  • harm to your charity’s beneficiaries, staff, volunteers or others who come into contact with your charity through its work (who are collectively referred to throughout this guidance as people who come into contact with your charity through its work)
  • loss of your charity’s money or assets
  • damage to your charity’s property
  • harm to your charity’s work or reputation

For the purposes of this guidance, “significant” means significant in the context of your charity, taking account of its staff, operations, finances and/or reputation.”

 

What to report?  For illustration only

A list of examples of what to report and what not to report is available on the Charity Commission website.

In a Baptist Church context this could include:

Cyber fraud – church email account hacked and bank account raided

Attempted fraudulent misuse of a church cheque that you intercepted

A Data Protection Breach which you reported to the ICO

A spate of thefts of money or property from the church.

A member of the fellowship reports having been harmed by another member or church worker

 

Action to take

“If something does go wrong, you should take immediate action to:

  • prevent or minimise any further harm, loss or damage
  • report it to the Commission as a serious incident
  • report it to the police (and/or other relevant agencies) if you suspect a crime has been committed, and to any other regulators the charity is accountable to
  • plan what to say to your staff, volunteers, members, the public, the media and other stakeholders, such as funders
  • review what happened and prevent it from happening again – this may include reviewing internal controls and procedures, internal or external investigation and/or seeking appropriate help from professional advisers”

The Charity Commission expect you to make a report as soon as you are clear that the event should be reported.  You should not wait for the outcome of an investigation, whether internal or by an external agency.  You can report serious incidents by email to: RSI@charitycommission.gov.uk

Remember: You should report what happened and explain how you’re dealing with it, even if you have already reported it to the police or another regulator and even if it’s still under investigation.

If you’re reporting the incident as a charity trustee, you need to confirm that you have authority to report on behalf of the trustee body.

 

Considerations

Who should you inform internally? Don’t keep it to yourself, certainly share it with the trustees/church leadership as they are ultimately responsible to the Charity Commission.

Which of the church’s policies and procedures need to be followed?

Can you deal with the situation immediately? If not, how can you minimise the impact?

Consider taking advice, e.g. legal or accounting advice.

Consider whether you need to file a Serious Incident Report with the Charity Commission

Look to the future: do you need to improve policies and procedures?

 

WEBA’s role

Whilst they can help churches draft a Serious Incident Report WEBA staff cannot:

  1. tell your church’s deacons/charity trustees whether or not to report a particular incident; you must decide this yourselves, being sure to record your reasoning if you decide not to make an SIR.
  2. make the SIR on behalf of the church