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PR for membership organisations · crisis communications

Crisis communications for membership organisations, members first

Crisis communications for membership organisations is the plan for what you say, to whom and in what order when something goes wrong: a data breach, a safeguarding allegation, a governance row or a hostile story.

It differs from company crisis PR in one way. Your members own the organisation, so they hear it from you before they read it anywhere else, and some incidents carry legal reporting clocks that start before any statement does.

Crisis communications

01/ Crisis communications plan for associations

Decide the roles before the phone rings.

A crisis plan is mostly a list of names and decisions made in calm conditions.

Four roles matter: a lead who decides, a spokesperson who speaks, a writer who drafts, and a gatekeeper who logs every inbound call, email and post.

In a membership body add a fifth: whoever can speak for the board or council, because members will ask whether their elected leaders know.

Keep the plan short enough to read on a phone, and test it once a year with a scenario.

Crisis plan: what it must contain · 0/10 in place

Still to write

02/ Which crisis is it?

Size the incident before you speak.

Our triage questions. Each “yes” moves the incident up a level and adds a duty or an audience.

Crisis triage · 0/5 answered

  1. 01Is personal data involved?

  2. 02Could anyone be harmed, or have they been?

  3. 03Is the media already asking?

  4. 04Are members talking about it publicly?

  5. 05Does it involve a named officer or member?

Answer all 5 to see your result.

Our template, not a regulatory test. Reporting duties are set by the ICO and the Charity Commission, linked below.

03/ The members-first order

Tell the people who own you first.

The order matters as much as the words.

Staff and the board come first, because they will be asked and must not learn it from the news.

Members come next, ideally minutes before any public statement, in a plain email from the chief executive or president.

Then regulators where a duty applies, partners and sponsors, and finally the media and your public channels.

A regulatory deadline can override the order: an ICO report or a Charity Commission report does not wait for the member email.

01

Crisis team and chair

Facts so far, the log opened, roles confirmed.

04/ Holding statements

Say what you know, and when you will say more.

A holding statement buys time without looking evasive.

It confirms what happened in one sentence, says what you are doing, names who is affected if you know, and gives a time for the next update.

It never speculates on cause or blame, and never names an individual who is the subject of an allegation.

Accuracy is the one thing journalists are held to as well: IPSO's Editors' Code requires the press to correct significant inaccuracies promptly and to distinguish comment from fact (IPSO Editors' Code, clause 1). Keep your own statement to facts, so a correction is easy to request.

  1. What happened, in one sentence
  2. What data, as far as known
  3. What members should do now
  4. That the ICO has been or is being informed
  5. When the next update will come

05/ Data breach communications

Seventy-two hours runs from when you knew.

A notifiable personal data breach must be reported to the ICO “without undue delay, but not later than 72 hours after becoming aware of it” (ICO, personal data breaches: a guide).

Not every breach is notifiable: the test is whether it is likely to result in a risk to people’s rights and freedoms. The ICO publishes a self-assessment to help decide (ICO self-assessment).

If the breach is likely to result in a high risk, the affected members must also be told without undue delay, and you must keep a record of every breach, notifiable or not (ICO guide).

Information can be given to the ICO in phases, so a partial report on time beats a complete one late.

Your member message and your ICO report must say the same thing. Draft them side by side.

Is this a reportable breach?

  1. 01Was personal data lost, accessed, altered or disclosed without authorisation?

  2. 02Is there likely to be a risk to the people affected?

Answer the 2 questions to see where you stand.

Our summary of the ICO guide; use the ICO's own self-assessment for the decision.

06/ Charity crisis communications

Charities report serious incidents to the Commission.

The Charity Commission requires charities to report serious incidents: an actual or alleged adverse event that results in or risks significant harm to people, loss of money or assets, damage to property, or harm to the charity's work or reputation (Charity Commission, serious incidents).

Reputation is on that list, so a press crisis can itself be reportable. Responsibility rests with the trustees, though they can delegate the reporting; if you decide not to report, you must be able to explain why later (Charity Commission).

The Commission wants to know what happened and how you are handling it, even when you have also told the police or another regulator.

That guidance applies to charities in England and Wales. Membership bodies that are not charities have no equivalent duty to the Commission, though their own regulators may impose one.

07/ Defamation basics

Serious harm is the threshold.

In England and Wales a statement is not defamatory unless its publication has caused, or is likely to cause, serious harm to the claimant's reputation; for a body that trades for profit, that means serious financial loss (Defamation Act 2013, s.1).

The Act's main defences are truth, honest opinion and publication on a matter of public interest (Defamation Act 2013, sections 2 to 4).

Two risks are particular to associations: a statement about a member being disciplined, and a member forum where others post about named people.

Statements about named individuals go to a lawyer before release. This is general information, not legal advice.

Facts about your own actions

What you have done and will do next.

08/ The post-crisis review

Within a month, write down what changed.

The review is where a crisis becomes a better plan.

Hold it once the incident is closed, with everyone who had a role, and keep it blame-free so people say what actually happened.

For a charity, the Commission looks for steps taken to limit the impact and, where possible, to prevent a recurrence (Charity Commission). The review is the evidence of those steps.

Report back to members in proportion to how much they were told at the time.

Post-crisis review · 0/8 in place

To do

09/ Crisis support

Plan, drafting and on-call support.

We run communications and PR for membership organisations with our specialist PR partner: crisis plans, holding statements, scenario tests and support when an incident happens.

See PR for membership organisations for the full service, and media training for membership organisations for spokesperson preparation.

Routine member messaging stays with member communications; charity PR more broadly is covered by charity PR, and the release itself by our press release template for associations.

Dan Keegan, Founder, Membership Quest and GTM Quest

Written by Dan KeeganFounder, Membership Quest and GTM Quest · GTM Quest ↗

10/ questions

Crisis communications FAQs.

What is crisis communications for a membership organisation?

The plan for what you say, to whom and in what order when something goes wrong. Because members own the organisation, they should hear from you before they read it elsewhere.

What should a crisis communications plan for an association include?

Named roles, sign-off rules, a board contact route, regulatory reporting routes, holding statements for your likeliest scenarios, contact lists and a single incident log.

How long do we have to report a data breach?

A notifiable breach must be reported to the ICO without undue delay and not later than 72 hours after becoming aware of it. Not every breach is notifiable; the ICO publishes a self-assessment.

Do we have to tell members about a data breach?

If the breach is likely to result in a high risk to their rights and freedoms, yes, without undue delay. Many organisations tell members in lower-risk cases too, to keep trust.

Does a charity have to report a crisis to the Charity Commission?

Charities must report serious incidents, which include actual or alleged events that risk significant harm to people, money, property, or the charity’s work or reputation. The duty rests with the trustees.

What is a holding statement?

A short statement confirming what has happened, what you are doing and when you will next update. It avoids speculation about cause or blame and names no individual subject to an allegation.

Can we be sued for a crisis statement?

A statement about a named person can be defamatory if it causes or is likely to cause serious harm to their reputation (Defamation Act 2013, s.1). Have statements about individuals reviewed by a lawyer.

Who should speak for the organisation in a crisis?

One named spokesperson, usually the chief executive, with a trained back-up. In a membership body the president or chair often speaks to members while the chief executive speaks to the media.

Ready before it happens

Write the plan while it is quiet.

We run communications and PR for membership organisations with our specialist PR partner, from the crisis plan to the review.