Response 232826281

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Proposal 1 – Publishing annual reports and accounts in full for all charities on the Scottish Charity Register

1. In what circumstances should there be a dispensation to full annual reports and accounts publication?

Not sure what you mean "in full". Is that without redaction? Redacted reports should be published.

There may be commercial reasons (e.g. competition for council/goverment contracts) and client reasons for reports to be redacted.

2. If dispensations are made, should some form of annual reports and accounts always be published, for example in a redacted or abbreviated form?

A basic set of accounts and information should be published for all charities.

Proposal 2 – An internal database and external register of charity trustees

1. What information should be included in an internal database?

Happy for the information mentioned above to be included in an internal database which is kept secure and information such as date of birth ONLY used for identification.

2. How should the internal database information be kept up to date?

1. annual check
2. by easy submission online (or by form avialable online) by each charity of updates to its trustees as and when they change.

3. What information should be included in a public list of charity trustees?

Only the information each individual trustee is willing to have published.

4. In what circumstances should there be an exception to being included in a public list?

Any reason. It would be wrong for there to be a prescribed list of reasons. There may be family connections, personal security, social networking issues for an individual to be unwilling to be named and s/he should not have to declare what reason (where would that information be kept?)

5. How long should a disqualified trustee remain on the list?

20 years similar to criminal convictions

6. What information should be available in the disqualified trustee list?

name and part of address. Enquiries should be available with cause to the charities regulator if there is doubt about identification.

Proposal 3 – Criteria for automatic disqualification of charity trustees and individuals in senior management positions in charities

1. What factors should be considered in defining a ‘senior manager’?

Cannot say - dont have managers in charities I am involved in.

Proposal 4 – A power to issue positive directions to charities

1. If a positive power of direction were to be specific, what areas should be subject to the power, or are there any areas that should not fall within the power?

no view

2. How long should a charity have to comply? What should be the consequences of non-compliance with a positive direction?

no view

Proposal 5 – Removal of Charities from the Scottish Register that are persistently failing to submit annual reports and accounts and may no longer exist

1. What factors need to be considered to define ‘persistent’ failure to submit annual reports and accounts?

maximum 2 years after failure after multiple attempts to contact.

2. What steps should the Scottish Charity Regulator (OSCR) take prior to a decision to remove? Should a positive direction to provide accounts always be required first?

dont know. - publish in local paper? No accounts may not be an issue

Proposal 6 – All charities in the Scottish Charity Register to have and retain a connection in Scotland

1. What factors should be considered when defining what ‘have and retain a connection to Scotland’ means? Does this have to require a physical presence in Scotland, such as an office address or trustee address?

Need a physical presence in Scotland as described above

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