Why has it taken 2 years to reply ?

First sent April 2008.. From the Executive Director of Charity Services.

Re: The Royal National Institute for Deaf People — Registered Charity 20772

Thank you for your letter and enclosing an email from your constituent MM, I am sorry that MM was dissatisfied with the Commission's response.

I understand from his latest email that MMs concerns are that:

• there is a lack of stakeholder involvement in decision making at RNID, with the exception of paid up members MM needs to understand that this is allowed by the Charity Commission's guidelines, but he believes that the Commission should help to give the 9 million people with a hearing loss a voice with charities;

• RNID has offered work to ex-government officials, and that this may create a conflict of interest;
• charities take government contracts; and
• the information provided to him by the Charity Commission did not address the needs of someone who uses sign language.

I will consider these points in turn.

Lack of stakeholder involvement at RNID

The Charity Commission welcomes user involvement in charities as a way of helping a charity to achieve its aims more effectively. Such involvement might include consulting users about the charity's services or having a trustee body that includes users. However, the extent to which a charity engages in such user involvement and how it does so is a matter for the trustees. Anw: www.charitycommission.gov.uk e: enquiries(@.charitycomm issioncisimov.uk General Enquiries: 0845 300 0218 (Voice) 0845 300 0219 (Minicom) effective trustee body will include a variety of people with a range of skills, interests, views and perspectives.

This suggests that users of RNID services can be ignored because they don't pay the RNID as members. I insisted a right was there via the DDA and Human rights, and using our voices as end users was an inalienable right, not determined by a fee. Consultation is not a right to vote on services given. Consultations never took actual place.


According to its last published annual report and financial statements, the RNID has over 38,000 members. Membership is open to anyone who wishes to support the charity and they can play an active part in its administration. Members are invited to attend the charity's Annual General Meeting where they can vote on any proposed changes to its governing document and the members also elect 8 of the charity's 12 trustees.


Fact: AGM's were only held in London this prevented near all members outside London with no means to attend. Suggestions they held AGM's regionally to give RNID paying members access was refused, and again non-paying members but active users of services denied that access. Trustees can ONLY be approved by the current RNID executive regardless what members vote for.


Members who are resident in Wales, Scotland and Northern Ireland elect representatives to sit on advisory groups which advise the trustees on local priorities and issues. The intention is that at least half of the representatives will be deaf or hard of hearing.

The flaw here is members can only advize and still not be able to change the charities approaches. This disabled membership from participation and influence, and reduced them to mere magazine subscribers. It is a deliberate image of active participation that doesn't take place.

Membership of the charity also gives access to a magazine and a website forum where they are encouraged to share tips, advice and problems. Members also have the opportunity to become involved in the charity's campaigns and wider work. I understand that MM is concerned about the cost of membership but it is open to charities to charge for membership in order to meet the costs of, for example, sending out the regular magazine. According to RNID's website, there is a range of membership fees according to individual circumstances, starting at £12.50 per year.

My objection was the cost didn't entitle you to a real vote. It just gave you a magazine, and the RNID an address to target for funds..

The charity should be able to advise MM whether there are any other opportunities for him to participate in any informal discussions, consultation groups or service surveys. The charity's accounts also state that RNID seeks to encourage deaf and hard of hearing employees to play an active role in developing both the charity and themselves and arranges training courses to meet this need. At the end of the financial year 18% of the charity's staff had a disability or a hearing loss.

This is non-proven, they used the Data protection Act to prevent me knowing the details. I maintain less than 8% are really deaf staff at all.

RNID also has a process for dealing with complaints for service users. This is accessible from the charity's website using the following link:
http://www.rnid.org.uk/Content.aspx?id=84929&clid=300375

False, it is NOT accessible to anyone that signs, and they removed the feedback forum.


MM suggests that the Charity Commission might make representations on behalf of deaf and hard of hearing people. The Commission is the regulator and registrar of charities in England and Wales, and our aim is to provide the best possible regulation of these charities in order to increase charities' efficiency and effectiveness and public confidence and trust in them. However, it is not our role, as an independent regulator, to lobby on behalf of any particular charity or its beneficiaries.

This is complete rubbish by the Charity Commission, on one hand it 'supports' inclusion of the deaf, on the other accepted the RNID has a right to ignore them. I asked the Charity Commission to make their muscle felt in insisting the RNID honours deaf inclusion, because I felt the RNID was blocking representation by deaf and actively preventing feedback, and manipulating comment going on.


RNID offering work to ex government officials. If MM has any evidence that any staff at RNID were recruited by anything other than a fair and open recruitment process and that there are conflicts of interest within the charity then we would consider this.

Staff are hired from discreet corporate agencies, agencies not readily accessible to deaf people and have lists of ex-government staff on them..

Charities and government contracts

There is no general or legal prohibition on charities delivering public services under a funding agreement with a public authority. If the trustees of a charity are satisfied that the right way to carry out its purposes is by entering into a contract with the government or a local authority then it is open to them to do so. Public service delivery presents both opportunities and risks for charities, including financial risks and the risk of compromising the charity's independence. Any charity considering entering into a public service delivery contract needs to weigh up the risks and benefits and ensure that the risks are appropriately shared between the charity and the public authority.

Again the CC in complete ignorance of the RNID. They just declared they are not in the business of public service delivery, then put in tenders. The charity is there to provide services NOT usually provided by public service bodies, not to take them over, I accused the CC of acting in collusion with the state in off-loading deaf services to cheap charity provision, which offers deaf reduced service provision by amateurs, and leaves deaf at the mercy of tin-rattling charities....
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Unsuitable information sent by the Charity Commission

The Commission actively promotes diversity issues wherever possible and is aware of the need to make reasonable adjustments for a customer with a disability. I agree that we should have considered whether someone asking about the beneficiaries of RNID was a sign language user, and provided him with a clearer and more tailored reply to his queries rather than simply referring him to our published guidance. We are sorry for this oversight and hope that this letter is more helpful to MM.

They couldn't provide proper access to the deaf., and were sending out responses deaf couldn't follow, bloody pages and pages of crap bumpf..


We have not contacted RNID before preparing this reply and I assume that the charity will reply to you separately. We would usually contact a charity only where a complainant has raised concerns that are of regulatory interest to the Commission and, on the basis on the information provided to date, this is not the case in this instance.

I hope that RNID is able to provide a satisfactory response to MM's concerns but if he remains dissatisfied then I would suggest that he follows the charity's complaints procedure which I mentioned on the previous page. I hope this information is useful.

2 years on, the RNID still has failed to respond CC, who gives a shit what deaf think ? and when are you going to get off your backside and sort the RNID out ? You didn't even forward the complaint or response TO the RNID which I asked for as they wouldn't reply to me...

Sincerely
Executive Director of Charity Services
David.locke(@charitvcommission.qsi.qov.,uk