queer ideas

What is wrong with trojan horse fundraising?

There's a fundraising technique that's caught on in the last few years based on offering important information as a means to obtain someone's contact details.

You probably have seen the type of thing I'm talking about on TV or train ads. Rather than directly offer advice, the ads ask you to email or text in for an information booklet instead. Then, as part of the delivery or follow-up process, you are also asked to sign up to a regular gift.

Much of the approach is built on ideas highlighted in Robert Cialdini’s book, Influence: The Science of Persuasion.

Cialdini points out that as a general rule, people want to be consistent in their words and actions. If someone takes some form of action, it makes them feel uncomfortable if they fail to support it later on. In one study featured in the book, researchers spoke to people about road safety concerns and gave them a free postcard to display in their window that promoted safe driving. A few weeks later they went back to the same neighbourhood and asked participants to put a huge billboard up in their garden that featured the same message.

Compared to a control group (who were never asked to display the postcard), the people who put up the postcard were four times more likely to agree to have a billboard erected in their garden. All because they wanted to appear consistent in their commitment to promoting safe driving.

The fact that this approach of reciprocity and consistency is sometimes known as the Foot in the Door technique, should raise a few alarm bells. But that hasn't stopped it from being used by a number of high profile charities. Not least because it can generate significant numbers of prospects that can be spoken to outside the constraints of the current or upcoming fundraising legislation.

The fact that seems to be ignored is that Cialdini also highlights the point that this style of marketing often creates ill-feeling amongst those who have been exposed to it as they can feel they have been tricked (along with high attrition rates, this technique has also generated at least one complaint that has been upheld by the FRSB). He cites the fact that Hare Krishna fundraisers (who give away free books or flowers) actually stopped wearing their religious robes as they found potential donors would change paths to avoid an encounter. As he explains...

"Although the Society has tried to counter this increased vigilance by instructing members to be dressed and groomed in modern styles to avoid immediate recognition when soliciting (some actually carry flight bags or suitcases), even disguise has not worked especially well for the Krishnas. Too many individuals now know better than to accept unrequested offerings in public places like airports...It is a testament to the societal value of reciprocation that we have chosen to fight the Krishnas mostly by seeking to avoid rather than to withstand the force of their gift giving. The reciprocity rule that empowers their tactic is too strong—and socially beneficial—for us to want to violate it.

What's particularly concerning is the long-term implications of this approach. What might happen if people take the same approach to charities as they did to the Hare Krishna movement and started avoiding us? Any street fundraiser knows that many people already change their path or bury their head in their phone in an effort to avoid being asked for a gift.

But as we have seen, people tend to draw a distinction between fundraising and the core activity of a charity. If we start muddying the water to the point that people see a request for information is going to be accompanied by a telephone call asking for a direct debit, might that cause them to stop asking for information from the very charities they need help from in the first place? 

It's a very high risk strategy that could well impact on organisations that don't use the approach along with those who do. And with the current high level of media scrutiny, the implications really worry me.

Fundraising is most effective when it is built on real connection and strong relationships. And I continue to believe that is what fundraisers should focus on building. 

Just as there are good reasons why a donor chooses to give, there are other good reasons why they say no. We should overcome those barriers not through subterfuge, but by extolling the benefits of giving. I'm not convinced that ours is a profession that really needs to employ trojan horses to get our fundraising message across. But I may well be in the minority. What do you think?

How do we change the public perception of fundraising?

With the ongoing media storm, improving the public perception of fundraising is near the top of every fundraiser's list of concerns. But luckily, not only do we have the Commission on the Donor Experience working on the problem, senior staff from the UK’s top charities recently got together to look at what they can do and, of course, there is the magnificent #DonorLove movement in Canada.

You can probably guess my opinion - more power to them.

As anyone who has seen my presentations or read my blog posts will know, I’ve become increasingly concerned that much of the sector’s work over the last twenty-five years hasn’t necessarily achieved much in terms of developing the nation’s philanthropic spirit.

To help illustrate this point, can I point you in the direction of The Logic of Charity: Great Expectations in Hard Times by Beth Breeze and John Mohan. Published last month, this excellent book takes a look at the historical impact of fundraising – principally since the early 1990s. Beth and John found the following…

• The number of people giving to charity and the amount they donate has remained stubbornly stable.
• There are regular upward swings in giving (driven by international disasters) though these increases are not maintained.
• There remains a widespread belief that ‘charity begins at home’ but no sense that charities should replace the role of government as suggested by the proponents of the “Big Society” idea.
• Less than a quarter of people think it is everyone’s responsibility to support charities.
• More than half of people think we should not rely on charities and look after ourselves instead (up from just 28% in 1991).
• Almost 40% of people think charities are wasteful and over 80% think there are too many voluntary organisations.

It’s not a great picture. So what have we done wrong? Why aren’t we seeing growth in giving and why hasn't there been a positive change in public attitudes?

The answer is perhaps summed up by an anecdote featured by Beth and John. The Labour MP, Frank Field gave a speech to the Charity Commission in 2015 where he shared a story about Margaret Thatcher. The former Prime Minister was asked what was her greatest disappointment in government. She responded by saying…

“I cut taxes because I thought we would get a giving society. And we haven’t.”

In all Bluefrog’s private and public research there is one key sentiment that comes through. People don’t give more just because they can afford it. They give more when they feel rewarded by their philanthropy. And sadly, very few people feel rewarded by being on the sharp end of some modern fundraising techniques.

We’ve seen far too many innovations that are based purely on the way we ask people to give. Whether it’s face to face, digital, mobile or even direct mail, if all we are doing is changing the way we ask for support it’s not going to make a blind bit of difference to how much we raise - nor will it increase the number of people who give to charity. All those presentations about the future of fundraising have amounted to little more than the splutterings of a faulty hair dryer.

So what can we do?

For a start, we can recognise one simple fact. The people who we have to influence are donors.

And talk of commissioning advertising campaigns to show people what their donations achieve misses the point by a mile. Donors won't judge us by what we say. They will judge us by what we do.

And what we need to do is to ensure that we recognise and respond to their needs as donors. Of course they want to solve problems. But they also need to feel part of the solution that we offer. And they must be thanked and rewarded for what they do, in a way that actually enhances their lives.

And the reality of the situation is, this needn't cost the sector anything.

In my experience, when we treat supporters in a way that provides a more enjoyable experience of being a donor, we raise more money. Attrition is also reduced, repeat giving increases and the number of legacies are boosted.

In fact, the first piece of advice I give to anyone who asks me how they can raise more money from their appeals, is to concentrate on improving how they thank and engage their donors.

But of course there is an if – and it’s a big one. It only works if those donors actually care about your work in the first place. That remains one of my concerns with industrial scale face-to-face and mobile giving programmes. They generate a great deal of chaff that hide the few grains of wheat.

In all the fundraising programmes I’ve seen that have taken a long-term approach to donor development rather than focus on cheap recruitment and quick wins, I've also seen positive growth rates that last. And at the end of the day, that’s what matters.

When you break it down, it is all achieved through the use of a hugely technical and scientific strategy that I like to call, being nice.

And that’s how we can change the public perception of fundraising. Simply by being nice to donors.

If the public start to enjoy giving, the headlines from 2015 won’t be repeated. It might take some time, but through focusing on Feel Good Fundraising, we will create a future that both the next generation of fundraisers and donors will thank us for.

So at your next fundraising brainstorm, why not make this simple suggestion….

When people have tried everything else, they might just decide to focus on what we know actually works.

Best of luck.

This is not fundraising

Over the last fifteen years or so, we've seen a fundamental change in how we raise money. For most of the twentieth century, fundraising was about engagement.

It was about recruiting new donors, nurturing them, getting a second gift, then a third and then moving them to regular giving (which we used to call committed giving). We would maintain their support with feedback that showed them the impact of their generosity until finally we received the ultimate gift – a legacy.

It was hard work. It wasn't cheap. But when done well, it produced great returns.

But in the late 1990s, things changed. We discovered face to face fundraising and the power of interruption.

Face to face fundraisers would stop people on the street and sign them up as regular givers. At a stroke, we could cut out the hard work (and expense) needed to engage people before we gained their 'commitment'.

We soon worked out that these donors were different to the traditional donor. They were younger and they didn't give to our DM appeals. But because they gave through a Direct Debit, that didn't matter. After all, these donors gave twelve times a year.

There was the growing problem of attrition, but the face to face agencies introduced guarantees and it became something we learned to live with. After all, if these new recruits weren't responding to mail packs, what could we do?

And slowly the structure of donor bases changed. Rather than recruiting older supporters with an engagement to the cause, many charities were increasingly likely to be funded by younger people who didn't seem to want much of a relationship. They were regular givers. But they couldn't necessarily be described as supporters.

And if these donors didn't want to engage, charities were a bit stuck. Crossing fingers and hoping for the best, replaced old-fashioned fundraising. Donors grew to resemble a commodity where they were bought and sold for up to £100 each. Ironically, if they were the sort of person who was too busy or too disinterested to cancel a Direct Debit, it increased their value.

This all created something of a problem.

If you look at what's happened over the last five or six years, the income from individuals for many charities has stagnated. Yes, the recession has had a great deal to do with this but so has the fact that many charities have been primarily recruiting unengaged donors for the last fifteen years.

CAF figures show that the percentage of donors who give via Direct Debit has been stuck at about 30% of people who donate to charity since 2006/07. When the PFRA reminds us that face to face recruited 2.2 million new regular givers between 2009/10 and 2011/12, it makes you think we might be simply swapping donors on some form of philanthropic merry-go-round.

And the implications appear to be worse for legacy income.

Remember a Charity reports (PDF) that the number of Wills that include a charitable gift at probate has increased by 10% in the first part of this century. But take a visit to the Charity Commission website and have a look at what's happened to the legacy income of many of the big charities over the last five or six years or so. You'll see that legacy income is, by and large, flatlining or even in decline.

The fact is that the legacy prospect pools for some of our biggest charities are rapidly shrinking.

So what should we do?

I think it's about time for a change of focus. To value instead of cost.

Cheap regular givers are usually cheap for a reason. They have low levels of engagement. Commitment doesn't happen overnight – it is the result of hard work.

This isn't a criticism of face to face. As a technique, it has recruited hundreds of thousands of new supporters. Without it, we would be poorer.

My concern is simply an over-reliance on interruption – in all its guises. And the long-term implications of the technique.

Mobile, for instance, has been presented as the future of fundraising. Like face to face, it recruits donors cheaply. But the levels of loyalty and interest demonstrated by mobile donors are also incredibly low. Click through rates are tiny. And if a donor isn't going to click through, it doesn't really matter what information we put on our mobile responsive website, it's unlikley to be read. All for an average gift of £3 a month.

So where are the most valuable donors?

They can come from any source (even your own warm file) but perhaps direct mail, press and online offer the best return, particularly at the moment. And particularly direct mail. At Bluefrog, for example, we've seen responses of up to 5% on cold mailings in 2013.

They work because engagement requires time and space.

These techniques (when done well) allow you to not only present your case, but to also show the beneficiary as a real person and to give the donor what they need  – a taste of the joy of giving (and perhaps even a chance to show off about what they have done).

These donors might not be the cheapest to recruit. They might require a great follow-up after recruitment. And they might not all become long-term supporters. But there are at least four good reasons why they are more valuable than a donor who only gave because they were interrupted.

They recognise the value of giving to you and give freely.

One of the problems with interruption techniques is that social pressure comes into play. Though this can be valuable in gaining that first gift, it can leave the donor feeling uncertain. It's one of the reasons so many face to face cancellations happen in the first few days after recruitment.

They give a sum that matters to them.

Great fundraising isn't just about asking for smaller and smaller sums until you reach a point where the gift is so small it doesn't really concern your potential donor. Consider increasing the amount you ask for, rather than reducing it.

They are happy to share their address and contact details with you.

Donors who feel bombarded by charities who send inappropriate communications are not neccesarily in the right place to embark on a new relationship, even if it is going to be one that they might enjoy.

It's one of the problems that we face with mobile giving.

Mobile donors tell us that they value the ease with which they can skip and stop. They also value the anonymity it offers them. It is ironic, but they value the fact that they can use their mobile to keep charities at arm's length.

They are responsive.

Donors who are interested in your work, are far more likely to read your communications. If they aren't interested, they won't read anything you send them. And if they don't read, they aren't going to give. 

In short, we need to make giving enjoyable for the donor again.

After all, that is our job. That is fundraising.

Mobile giving – it's easy to stand out in a crowd of one

This is a guest post from Bluefrog's new Head of Donor Engagement - James Waring.

In the first couple of weeks after you start a new job (as I have done this January) you often find yourself looking for things to do, or waiting around for meetings and inductions. During these lulls, in a bid to appear as up to the minute as possible, I’ve been reading a lot of fundraising blogs. One theme has really rung out across the sector this January – Retention (So much so that all these words link to a different article on it).

Something else that’s in everyone’s mind and has decent retention rates is regular giving via your mobile phone. So could the retention issue be solved by the convenience of a text? Has one of the holes in that leaky bucket been plugged?

Giving regularly via your phone was created because engagement through giving to charity via a direct debit was pretty poor. After all, direct debits were invented to pay bills – you aren’t meant to think about them. I (and I’m still pretty young) remember back in the heady days of 2010 talking about how giving a monthly donation through your phone could be much more engaging – interactive content with a different tangible case study every month. And everything was sent straight into your pocket!

But anyone coming from the world of telemarketing (as I do) has heard hundreds of conversations with this new breed of 'mobile donor'. The fact of the matter is simple – they sign up because it’s easy, they can 'skip' a gift whenever they want and, crucially, they don’t think they are going to be asked to do anything more.

The lower attrition rates we are seeing from people who give via their mobile phone bill aren’t because we’ve fixed any of the basic problems leading to high attrition and a lack of engagement from donors; they’re because donors and some charities seem to have confused novelty with interest and convenience with loyalty.

If a product’s strength is that it’s new and easy now, the risk is that it will soon be old and unimportant.

Donors like the fact that mobile giving isn’t a direct debit, they like the fact that they don't have to put anything in the post and they like the fact that they don’t HAVE to give – but they also like the fact that it’s new and different.

Just under a third of the total amount given to charity comes via direct debits. The people who give via their mobile are more often than not, the very same donors. Very few of them are teenagers making their first gift to charity. Most are in their thirties, forties, fifties and older. So in a year or two, when they have signed up to three or four charities on their phone – how often are they going to get four messages across a few days and think “that’s it, I’m stopping two of them”?

I’d tentatively suggest that it will probably be around 50% - 70%; the same number that cancel their gifts from face to face, or telephone recruitment. When you are giving to multiple charities through the same medium, it loses its sparkle pretty quickly.

The extra level of engagement we were excited about isn’t happening, though on the face of it for good reasons.

Donors, if you ask them (which we have done), often don’t want additional content because they are worried that charities might take 'advantage' of them. More contact so often leads to more asks and upgrade calls that they’d rather dis-engage and be left alone.

But ask people why they cancelled their direct debit and beneath the claims of financial hardship we find the truth is that they weren’t engaged by the charity in the first place.

This quote from Phil Caroe (CEO of Allia) taken from a research paper on online giving by Spring sums it up. He was approached on the street to give by text and said "no"...

“I wonder whether at times we’re in danger of trying to make giving so easy that we get a gift but not a relationship. How many people made a text donation just because it was the easiest way to end the conversation?”

Throughout this post I’ve referred to the people who give money to charity as donors and not as supporters.

I’ve done that as they aren’t really supporting a charity. If the truth was told, they probably don’t even know what the charity really does and that is the issue.

Mobile fundraising is a great opportunity to really link the action of giving to the means of communicating what that gift does. But let’s not confuse the medium of a gift (via a phone) with the aim (cultivating long term, valuable relationships with supporters).

As fundraisers, getting people to say “yes” is one of the hardest things we do, but just because we’ve found a way to get people to do that more easily, doesn’t mean we should only ask for that one basic level of engagement.

Once giving regularly through your phone becomes “normal” and donors start receiving upgrade calls and text messages from multiple charities, we won’t be able to rely on the novelty of mobile to solve the retention issue. So something needs to be done to really engage these potential new supporters – even if they don’t think they want it.

Thanks to Tom Fishburne for the cartoon.

This is a guest post by James Waring who was previously a senior planner at Listen and is now Bluefrog's new Head of Donor Engagement.

Bluefrog gets connected

An organisational case for support might help highlight some of the reasons why people give to you, but it will rarely help you identify why they don't.

The reasons are surprisingly complex, but one is quite simple - it's a hassle. It's rarely a case of simply handing over money. The industry standard that we all use requires people to fill in forms, write cheques or hand over credit card numbers.

It might not be a particularly difficult task, but it's enough of an ordeal for many people to put an appeal aside to respond to later and then forget about it. Why else are reminders so successful?

It was one of the reasons that I came up with a pack back in the mid-nineties that was designed to circumvent the barriers to giving. That meant that I needed to ensure that there were no onerous forms to fill in and no cheques to write.

The result was the pound pack (which you can read more about here) and rather than generating a response rate of one or two per cent, it recruited donors at rates in excess of 20%.

Of course, that first gift of £1 didn't mean a great deal. What was important was the subsequent donor journey and the process that led the supporter to set up a direct debit.

When managed correctly, it generated a ten year ROI that beat those achieved by face to face recruitment. It was one of the reasons why it was copied so widely.

Over the years, Bluefrog has used the same techniques developed for the pound pack in other ways - for prospecting (two-step) street recruitment and, starting back in 2002, for the mobile phone. Both techniques helped reduce the barriers to giving by making sign-up easy - no forms to complete and no searching for a means of payment.

With the growth in mobile giving, it became obvious that we needed a partner to work with in order to offer mobile one-off and regular giving services to our clients - particularly for two-step street recruitment.

As a result, I am very pleased to announce that we have agreed to work with Cymba and can now add their Connected product to the Bluefrog fundraising portfolio. Cymba have a huge amount of practical experience and there was no other player in the market with their level of understanding of the use of mobile devices for fundraising.

Steve Hanna, Cymba's director summed up why we decided to work together...

"Bluefrog had a fantastic appreciation of the donor journey. We've undertaken a great deal of testing and were very impressed with their approach. We can't wait to see it in action."

There seems to have been some confusion in the market with regard to Connected. As Cymba have pointed out, it is not tied to one particular fundraising agency and there is no patent in place.

Anyone can use Connected with any combination of creative, strategic, face to face or telephone agencies they wish. If you would like to speak to Cymba about Connected you can get in touch with them directly by clicking here.

But as mentioned, it's the donor journey what really counts and with having many years of experience with prospecting fundraising techniques, everyone at Bluefrog is very excited about really starting to push the boundaries of what can be achieved through mobile devices.

Mobile regular giving is not just another form of direct debit. With the combination of the control and great feedback it offers, it can generate attrition rates that are far lower than those achieved by many more traditional techniques.

It is also very effective at reactivating lapsed regular givers - even those who were originally recruited by face to face fundraisers.

There's an app for that.

And to provide the best feedback available to supporters, Bluefrog has created a rather exciting new app.

Built on the back of our award winning uSpace feedback engine, we have created a device that can provide your donors with direct insight into what their gifts are achieving and really connect them to your cause.

All this can be achieved both inside and outside your donors' email stream as they can be directly informed of updates via push messages to their home screen.

It's taken Bluefrog many months to build, and we are very pleased with the results. As you'll see from the images using WSPA's platform as an example, it looks rather good too.

You can be set up with your own branded app packed full of great content in a matter of weeks and you'll find the cost structure very, very affordable. If you'd like to see a demonstration version and hear more about bluefrog's 360 degree mobile offering (with or without our app) please get in touch with us by emailing me at mark@bluefroglondon.com.

And finally, if you are interested in helping us run our new mobile fundraising operation, we are looking to recruit a Head of Mobile. You can find out more by emailing me at mark@bluefroglondon.com in strictest confidence.

Using mobile to make press ads speak

Interesting use of mobile / QR codes to turn a press ad into a multi-media experience.

 The original inspiration looks like it came from this idea used to spice up a CV.

Where next for mobile giving?

Following from last week's post on mobile giving in the UK, I thought it might be useful to share this rather good presentation from US digital agency, space150 on broader trends in mobile use.

Mobile Trends - June 2011 - Trending The Future

View more presentations from space150

You'll see that they identify three behavioural trends of the mobile experience:

• Convenience
• Context
• Fun

Convenience is the obvious one for fundraisers. Providing supporters with an easy way to donate and receive updates on work they are funding seems like a sensible option.

But when you consider that mobile companies are looking at how they can replace our wallets and keys with NFC technology (Near Field Communications) you begin to appreciate that offering a mobile giving option could soon become something of a necessity.

The impact of context on mobile giving needs a little more consideration. It has more obvious use in the commercial world, where we are seeing rapid growth in the use of customised search and location services (such as foursquare).

But it's not necessarily so clear what this offers charities.

Orange has recently released their Do Some Good micro-volunteering app which provides opportunities to do nice things for charities whenever someone has five minutes spare time.

Hopefully the attraction of free concert tickets might encourage a greater level of participation than was seen with the original micro-volunteering app, The Extraordinaries. The team behind this idea soon re-focussed their efforts on the desk-top environment through Sparked, simply because it offered a more effective volunteering platform.

Or perhaps we need to look some of the award winning ideas coming out of places like Kingston University for inspiration...

Re:write – a mobile app that adds extra functionality to newspaper apps, giving people the opportunity to act on current events as they read about them.

Donate at the Gate – which offers NFC users (that's Oyster cards to you and me) the chance to donate to charity by going through a specific gate at a train station.

These concepts show that there are most certainly different and effective ways to fundraise that place context at the centre of the donor experience. We just need to come up with ideas that donors will find attractive.

I'd be particularly tempted by a special charity gate at Old Street tube when there are huge queues of people waiting to get in or out of the station.

Which leaves us with fun.

That doesn't take much explanation but when it comes to older donors, there's one piece of old-fashioned technology that can get in the way of making the mobile phone a fun way to interact with a charity. And unfortunately it's one I have to struggle with...

It's always the right time for mobile

Mobile seems to be gaining momentum as the 'next big thing' in fundraising.

It's strange, considering just how long charities have been using the medium. I'm not sure if this is the first example of text fundraising, but Bluefrog created this ad way back in 2002 for Shelter (building on the popularity surrounding Big Brother).

It worked. And we've continued to use text as a recruitment vehicle (primarily for press and TV advertsing) either for small gifts or to give people a chance to raise their hand and show interest in a cause.

It didn't take a genius to identify that it was the follow-up that was important. Because you have a telephone number, you're able to call the donor and convert a significant number of them to regular giving.

But with today's smart phones we can do a little more than that. 

This presentation from Just Giving shows a massive increase in the number of people visiting justgiving.com from mobile devices. They've seen a growth rate of nearly 82% in 2011 (and that's just up until April).

They have also identified a pattern of mobile use that we've seen on a number of Bluefrog's specialist donor engagement charity sites. They call it snacktime browsing.
 
Snacktime browsing happens whenever people have a few minutes to go online on their mobile phone. As this JustGiving chart demonstrates, visits from a mobile device are much less prone to the peaks and troughs you tend to see when people visit from a desktop machine.

This is happening at a time when we are seeing huge growth in the number of people using their mobile phone to give through traditional texting. The UK's Haiti moment occured with Comic Relief 2011, when over £15 million was raised through 4.3 million text donations.

nfpSynergy's recent report on charity use of mobiles, Sending out an SMS (PDF), shows the impact this campaign had on text based giving...

The fact is, the mobile phone allows us to get an interactive donation form in the hand of the donor within seconds of them seeing or hearing our appeal. And that's what makes it so special. We know that the desire to give to a cause can quickly fade. The mobile phone gives people the chance to give exactly when they are most emotionally engaged. And, as we know, donors tend to reward convenience.

It's still new technology, so it's not surprising that mobile giving seems to be most attractive for those aged under 35. But, this isn't a bad group from which to recruit regular givers.

But whether we are talking to younger or older donors, offering easy access isn't enough, we have to make sure donors find the use of mobiles satisfying too – otherwise we'll soon find the growth that we are currently seeing will flatline and stall.

nfpSynergy have some advice for us on that point...

"In the early days of the web, charities had a tendency not to know how to include the Internet in their paper-based campaigns. So they didn’t, or they added a web address and hoped for the best.

The new wave of mobile pioneers needs to learn from this and make sure that their campaigns integrate the mobile in as a key part of their communications portfolio.

A TV ad can encourage people to send a text which in turns sends them a web link with which they can visit a campaign microsite. Mobiles and text can act as the links between different parts of the campaign."

If you need any help on putting together a paper on why your charity might consider investing in mobile fundraising, the nfpSynergy study contains a number of case studies that you might find useful.

For a US view, take a look at Ready. Set. Go Mobile for information on mobile fundraising in America.

You'll find more case studies and information at the Association for Interactive Media and Entertainment. And even more at MobileActive (US based).

For up to date statistics on mobile use in the UK, Ofcom is not a bad place to visit.