Serious Incident Reporting Policy
1. Introduction
The Charity Commission requires all charities to formally report serious incidents, and that a full and frank disclosure of any serious incident is made promptly. When something serious happens, the Charity Commission seeks assurance that the charity has taken steps to limit the immediate impact of the incident and, where possible, prevent it from happening again. Where a charity decides not to make a report about something serious that has happened and the Charity Commission later becomes involved, the charity must explain why it decided not to report at the time.
This policy sets out the Houghton Trust’s approach to serious incident reporting. It should be read in conjunction with the Houghton Trust’s other relevant policies and governing documents (see section 7).
2. Serious Incident definition
The Charity Commission defines a serious incident as: an adverse event, whether actual or alleged, which results in or risks significant:
- Harm to the charity’s beneficiaries, staff, volunteers or others who come into contact with the charity through its work.
- Loss of the charity’s money or assets.
- Damage to the charity’s property.
- Harm to the charity’s work or reputation.
The Charity Commission guidance states that “significant” means significant in the context of the charity, taking account of its staff, operations, finances and/or reputation.
3. Responsibility
The responsibility for reporting serious incidents rests with the Houghton Trust’s Trustee Directors. While this may be delegated, all Trustee Directors bear ultimate responsibility for ensuring the Houghton Trust makes a report and does so in a timely manner. The Trustee Directors have ultimate responsibility for deciding whether an incident is significant and whether it should be reported.
Reporting serious incidents and managing them responsibly reflects the legal duties of Trustee Directors.
4. Policy
- All serious incidents will be reported to the Charity Commission within 72 hours of a decision by the Trustee Directors to report a serious incident.
- The Houghton Trust will provide the Charity Commission with an appropriate level of information in any report and will respond to resulting requests for information within a reasonable timeframe.
- The Trustee Directors collectively are responsible for deciding whether to make serious incident reports and to do so in a timely manner. Decisions to make a Serious Incident Report will ordinarily be discussed and minuted at a full meeting of the Trustee Directors.
- Where it is not possible to convene the Trustee Directors to discuss the charity’s approach to a serious incident, the Trustee Directors will delegate the decision to make a serious incident report to the Chair and one other nominated Trustee Director. In such circumstances, the Chair and nominated Trustee Director must provide the other Trustee Directors with a written explanation of the decision and the reasons for the decision once a decision has been made.
- Any such decision will be reported and minuted at the next full meeting of the Trustee Directors.
- The Trustee Directors will ensure it documents decisions relating to ‘borderline’ cases - i.e. those where a serious incident report was considered, but it was decided not to make one.
- Where a reportable incident involves actual or alleged criminal activity, it will also be reported to other relevant agencies.
5. Incidents that should be reported
The Houghton Trust acknowledges the Charity Commission guidance that it should report an incident if it results in, or risks, significant:
- Harm to people who come into contact with the Houghton Trust through its work.
- Loss of the Houghton Trust’s money or assets.
- Harm to the Houghton Trust’s work or reputation.
The main categories of reportable incident are:
- Protecting people and safeguarding incidents – incidents that have resulted in or risk significant harm to beneficiaries and other people who come into contact with the Houghton Trust through its work.
- Financial crimes such as fraud, theft, cyber-crime and money laundering.
- Large donations from an unknown or unverifiable source, or suspicious financial activity using the Houghton Trust’s funds.
- Other significant financial loss.
- Links to terrorism or extremism, including ‘proscribed’ (or banned) organisations, individuals subject to an asset freeze, or kidnapping of staff.
- Other significant incidents, such as insolvency, forced withdrawal of banking services without an alternative, significant data breaches/losses or incidents involving partners that materially affect the Houghton Trust.
- Activities funded by the Trust that bring Trustee Directors, Members or the Trust into disrepute.
The Houghton Trust will also follow UK government advice on trusted research (which protects UK researchers and infrastructure from theft, manipulation and exploitation) trusted research and innovation and securing the integrity of international research collaboration
The nature of the Houghton Trust’s assets and activities means that it is very unlikely that reportable events will occur. Robust procedures are in place for the review of proposals for research or travel, with responsibilities to comply with relevant legislation transferred to the hosting organisation(s).
How the Houghton Trust will report serious incidents
- Where the Trustee Directors agree to make a serious incident report, they will delegate responsibility so that the report comes from a named individual. The Chair and/or another nominated Trustee Director can make serious incident reports under the delegated authority in this policy.
- Serious incident reports will be made to the Charity Commission using its online reporting form.
- To ensure the relevant and appropriate information is captured at the time, is reported consistently, and is consistent with Charity Commission guidance, we will use the Serious Incident Reporting Form (See Appendix A).
- The Houghton Trust is required, as part of its annual return, to sign a declaration confirming that there were no serious incidents during the financial year that should have been reported to the Charity Commission.
- If incidents did occur, but weren’t reported at the time, we will submit these before we file our Charity Commission Annual Return so we can make the declaration and meet our legal reporting requirements.
7. References
Houghton Trust documents
- Articles of Association
- Byelaws
- Payment Policy
- Grants & Publications Policy
- GDPR Policy
- EDI and Equal Opportunities Policy
- Complaints Policy
- Anti-bribery & Corruption Policy
- Reserves Policy
- Safeguarding Policy
8. Review of Serious Incident Reporting Policy
- This policy will be reviewed annually at the annual meeting of the Committee.
- Any questions about this policy may be addressed to the Secretary sue.baigent@outlook.com
- This Policy was prepared in December 2025.