Setting up a Facebook Fundraiser page
Simple steps for setting up a Facebook fundraiser page for your congregation (via the charity/non-profit organisation route)
Before you start
You need to be aware of the following Facebook Privacy and Data Protection issues
- When a Church of Scotland (CoS) entity (either a congregation or CSC) creates a Facebook page, they also create a "Joint Data Controller" situation between themselves and Facebook. Facebook makes this clear on their legal terms page. The use of anything from embedding Facebook Likes/comments buttons through to donations buttons creates exactly the same set of obligations.
- This means Facebook is responsible for their handling of all the personal data involved, and the CoS entity is responsible for how they process that same personal data. Facebook makes it clear - they are not responsible, the page controller IS. This refers to the transaction data each data controller will need to download from Facebook in order to comply with their obligations under the Charities Act and Gift Aid.
- IMPORTANT: The transaction reports for donations made on Facebook are only available on a 180-day window. (see this page: How do I view transaction reports and donor information for my charitable organisation?) This means the reports need to be sought frequently enough to make sure all the transactions are captured. Waiting until the end of the year will mean missing out on 6 months of transaction data.
- The transaction report data fields are specified on this page: How do I view transaction reports and donor information for my charitable organisation? There is enough in these downloaded reports to identify this personal data as "special category" personal data, which means we will need to identify two lawful reasons for processing, which we clarify below.
- The use of personal data sourced from Facebook for this processing activity needs to be recorded in the "Record of Processing"for each data controller (Congregation/department involved). A sample Record of Processing form is available.
- Even if a congregation does not regard itself as a data controller, it will automatically be defined as such by the Data Protection Act 2018 as a result of using Facebook Fundraiser or Donations buttons.
- Each data controller should make sure they have added this purpose of processing to their "Record of Processing" (an example document is available, with an example entry for "Online Donations" noted in bold text at the foot of the table). I have also included the two "lawful reasons for processing" which I think are appropriate for this case. Congregations should note, they must not use the same lawful reasons as are quoted on Facebook guidance. What works for Facebook is not adequate for our purposes.
- Note the data feed supplied by Facebook includes the donor's email address and postal address. The email address is supplied for the single purpose of issuing a receipt and should be used for NO OTHER PURPOSE without the prior consent of the data subject. We can't stress this strongly enough. Postal address is supplied where possible to support Gift Aid applications.
Facebook page security
Make sure your Church Facebook page is set up with appropriate security settings. Always make sure that more than one person has access to administer the page. This is crucial to ensure you never lose access to your page. When people move on from this role, change your security settings and passwords to reflect this and make sure only authorised church administrators have access.
Setting up a Facebook Fundraiser Page
You will need to:
- Create or update an existing Facebook page for your congregation
- From your Page's admin account, sign up for Facebook Payments
- Go to Page Settings > Donations
- Check both boxes to allow people to create fundraisers and add donate buttons to their posts
Your congregation's Facebook Page category will have to be set as a 'Nonprofit Organization' or 'Charity Organization' and its address be included in the ‘About' section of its Facebook Page. Your Page needs to be published and complete with a cover image and description.
To register, you will be required to provide the following details:
- The date of birth and address of the Session Clerk, Treasurer or another Trustee
- A charity registration number (when applicable).
- A bank account registered with a licensed financial services institution. This may include bank account details like the bank name, bank account holder's name (organisation's name), a legible and official bank letter or statement dated within the last three months and sort code.
Tell your story
Telling your story on your Facebook page is an important part of the fundraiser and should engage both church and community if possible. Tell good-news stories of how you are engaged with your community. Here is a suggested story for adapting as required:
Although we are not meeting for Sunday worship due to the COVID-19 crisis, the work of the church continues. We are aware that many of you will want to continue your regular giving, and we need to continue to provide ministry and support to those in our community who we love and serve, especially in this difficult time. If you're able to donate to the work of our church through Facebook, then this would be a great encouragement and blessing to the work of your local church. Your donation will be used to support those in need and in the community. Many thanks for your support and generosity.
Once your Fundraiser is active, please feel free to email a link to email@example.com