Response 390516237

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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?

I don't think there should be any.

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

Yes

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

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

All trustee names and contact details
Disqualified trustees' names

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

Onus should be on the charity to keep information up to date

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

Names of Trustees
One address
Disqualified trustees

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

None

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

10 years

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

Name and date of birth

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’?

Not sure what is meant here, presumably a manager reporting directly to trustees

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?

Financial management
Discrimination

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

Charity should comply for at least 5 years. Consequences of non compliance should be removal of charitable status

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?

More than two reminders

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?

Yes, two reminders should be given

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?

I think Scottish charities should carry out work in Scotland.
Any other charities should have a physical presence in Scotland

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