5.3 Communication methods

Advance publicity

Any form of publicity that refers to a society’s intention to sell community shares forms part of the contract with the purchaser of those shares. All public communications, at all stages of a promotional campaign, should be consistent with the contents of the share offer document. These communications should not provide supplementary or additional information that changes the material nature of the offer, or implies different terms and conditions.

At the early stages of planning a community share offer, a society should restrict its public communications to more general matters, and avoid giving details that it might later want to alter when it is ready to launch the offer. As plans develop, care needs to be taken to ensure the consistency of communications across all the forms of media used to promote the share offer, including websites, social media, and public meetings, as well as the published share offer documents.

News coverage

It is beyond the scope of this handbook to provide detailed guidance on how to manage media campaigns. From a community shares perspective, accurate factual reporting of the details of any community share offer is vital. Advance publicity should focus on the purpose of the offer, rather than on the offer itself. So, for instance, if the purpose of the offer is to save the last retail outlet in the community, then this should be the news story. Details of the community share offer should only be released when the share offer document is ready for distribution.

Local, regional, and national news coverage is welcome and achievable. Community ownership, community investment and community shares are novel concepts and may attract media interest. Several community share offers have attracted national news coverage, but this did not appear to significantly alter the geographic distribution of investors. Instead, national coverage tends to bolsters local support, perhaps by reinforcing the sense of pride and identity within the target community. 

Websites

All but the smallest of societies need to have their own websites in order to communicate with members and prospective members. Electronic communications are far cheaper and easier to administer than paper-based communications, and a website forms the hub of an electronic communication system. A website enables a society to provide members and prospective members with full information about the society at low cost. It also provides a vehicle for people to express an interest in the society and to consent to future communications, enabling the society to build a contact list of supporters. To do this, the website needs to elicit contact.

Invitations to receive newsletters, email bulletins, or make pledges should comply with the requirements of the Privacy and Electronic Communications Regulations, and as a matter of good practice should require people to opt-in to communications for each of the formats the society intends to use in its direct marketing efforts. If the website uses cookies, it should also be compliant with the General Data Protection Regulation on this matter.

Email and text communications

Email and text communications count as electronic communications for the purposes of the Privacy and Electronic Communications Regulations, and the electronic storage of this personal data is also covered by the General Data Protection Regulation. A society should only email or text people who have consented to receive direct marketing materials from the society on the specific matters being addressed via the particular medium concerned. This applies to existing members, prospective members and supporters who have expressed an interest in a community share offer. 

Phone calls

If a society plans to communicate with members, prospective members and supporters via phone calls it should first obtain their consent. But it can make unsolicited calls, as long as any phone lists it uses have been screened for people registered with the Telephone Preference Service (TPS). A society can only call someone registered with TPS if the person has consented to such communications. When making calls a society must always say who is calling, and provide a contact address or Freephone number if asked.

Doorstep materials

Unsolicited mail and hand-delivered promotional materials are allowable, although if these deliveries are being made using an electronic database, then the General Data Protection Regulation still applies. Door-to-door leafleting, used by many community share offers targeting small target communities, is fully allowable under almost all circumstances, especially when it does not involve the electronic storage of personal data.

Social media

Social media campaigns to draw attention to community share offers are a well established practice. It is beyond the scope of this handbook to state how the Privacy and Electronic Communications Regulations applies to all the various forms of social media. The main issue here is whether the electronic message is directed at and can be stored by an individual, in which case prior consent may be required. Where the communications are not directed at or designed to be stored by individuals then the Privacy and Electronic Communications Regulations may not apply. 

Published documents

Published share offer documents, including printed media and electronic documents, form part of the contract between the society and its potential and existing members. As soon as such documents are distributed, or placed in the public domain, they should not be altered or changed without communicating these changes to all existing members and applicants.

This means that care should be taken to ensure that all the details of the offer document are correct before publication. If any substantive changes are made to an offer document after it has been published, and before the offer is closed, then all applicants and existing members should be contacted to inform them of the changes and to allow applicants the option of cancelling their application. 

Public meetings

Public meetings are an excellent campaign tool for societies seeking to engage communities in their objects, purpose and projects. Care has to be taken at such meetings to ensure that anything that is said about an impending or live community share offer is consistent with the share offer document, the society’s rules and its business plan. If these meetings are used to collect personal data from supporters, the guidance in this Section relating to the General Data Protection Regulation and the Privacy and Electronic Communications Regulations must be followed.