All connections & interactions are of value to us, as the WCB starts to become more well known. Even getting emails on why a Rescue doesn't want to be a WCB Holder (as long it's polite, obviously) is appreciated, as at least we are all getting to have a conversation around the subject of wildlife care...
I thought that I would share 3 points that were sent to me recently, in a very nice email, about why the sender wasn't going to sign up for the WCB. I am sharing my answers too. (If I am incorrect in any of my answers, or perhaps you might think that I have misunderstood the point that was being raised, I am happy to be corrected: we can only ever do the best with what we know, in each moment.) ...
First point... "Release policies. We have strict guidelines for releasing animals held at the hospital for more than a few days. E.g. birds who have been unable to fly for two weeks must be rehabilitated in an aviary that is at least 7 times longer than the length of their wingspan. Unless the bird is fit for release it is unlikely to survive either being preyed upon or failing to catch prey."
MY REPLY... "Our WCB Holders are expected to have suitable release premises for all of their animals too and their full facilities are included in the Vet Visit. Unless you have experienced a lack of suitable premises with any of our Badge Holders please, that I should be aware of?
As per the RR&T Policy that I sent you this week, page 34 references the pre-release and release policies that we expect WCB Holders to follow, as laid out by Liz Mullineaux, consultant Wildlife Vet with Secret World."
Second point... "Inability to monitor adherence to standards. This is a tough one, particularly when people work alone, how can anyone know what they are really doing? I say this from experience of working with one WCB holder but it’s most certainly not exclusively a WCB issue and I have no ready answer."
MY REPLY... "This was a big concern for us too, when the RR&T Policy was in development. How could we confirm ongoing welfare whilst in between Vet Visits? After a huge amount of discussion between Wildlife Rescues big and small and with Wildlife Vets too, it was decided that ‘accountability’ was required to be proven throughout the year. You can see that laid out in the RR&T Policy and on our website. Remember too that the willingness to be transparent is key to the WCB succeeding or failing: that is one common trait amongst WCB Holders - they are holding themselves up to scrutiny voluntarily and then that can be built on.
The truth is, no Wildlife Rescue is fully accountable, to anyone except themselves, especially where there is no government licensing in place and no compulsory training to ensure standards before even starting. The very worst - by far - case of serious mis-assessment and misdiagnosis of injuries in a wildlife casualty that I have ever encountered was by a large centre, with staff/volunteers who were perhaps too inexperienced in their roles at that moment and so missed what an animal was suffering. The injuries were then picked up on by the centre that the animal had been sent to for release.
This example is not uncommon: it is not only home based Rehabbers who operate without full veterinary onsite supervision at all times (as an example) or who struggle to keep up with on the spot training. I think the key here is to create a base level of proven standards - as the WCB does - to start to enable Rescues to trust one another to be open and transparent, to share experiences and ask for advice and for everyone to support and help one another."
Third point... "Governance – no requirement for a written constitution or a bank account in the name of the organisation, no requirement for auditing of accounts. This means donations are paid into the personal account of the rescue organiser and this is open to fraud (and just as importantly false accusations of fraud) which would reflect badly on the WCB and its members."
MY REPLY... "The WCB operates within the law (which is why we don’t state that captive unreleasable wildlife are ‘good/bad’ and why we focus so much on welfare standards within what is currently legal).
It is my understanding, that I confirmed again today, that it is actually perfectly legal to be a sole trader and run a Wildlife Rescue. It is legal to take donations in your name (as long as tax laws are adhered to). It might not be preferable - I myself have always run my organisations as registered companies in favour of being a sole trader - but it is 100% legal.
The WCB has no right to dictate the form of organisational structure that a Wildlife Rescue legally takes. There is however a legal (under the Animal Welfare Act and the Wildlife & Countryside Act & Veterinary Surgeons Act, for example) framework that holds a structure for if/how/when an animal should be treated if they are taken in by a human and are under their control, as well as legal use of medications etc. It is within this awareness of legislation that the WCB operates and so we set the standards for wildlife rehabilitation that are advised by experts in the field: what are the minimum levels of treatment that would justify keeping an animal and not passing them to be rehabbed by someone with more experience (?) etc, for example.
RE having a written constitution: whilst I have one for each of my different organisations, it is not a legal requirement, as a sole trader or a registered company. [I myself have remained a company and not a CIC or charity, for example, after extensive consultations with charity solicitors and consultants, because being a simple registered company actually suits the WCB and UKWT more and helps us to achieve our goals more efficiently. I have constitutions because I find them helpful and I like to operate that way but they are not a legal requirement.] Nor does having a written constitution prove that it is more than an ideal for a Rescue to say that they operate around. In most cases, they're words, not proven fact. The WCB asks for proof of knowledge (with Knowledge Assessments created by a Wildlife Vet and Rehabbers working together). We need proof of premises, re-proven every year, and ongoing proof of a vet relationship, legal medications being used and high welfare records being kept.
RE the auditing of accounts: even the charity commission doesn’t do this on a regular basis. There was a Rescue charity reported to them for submitting exactly the same accounts, down to the last penny, 2 years in a row - the report was made to them this year - and they weren’t interested in investigating the issue, for whatever reason. [I submit my company tax accounts every year to Companies House and they trust me that they’re real - obviously with the penalties I would suffer if they were found to be false - and the charity commission appears to operate similarly (?)]
I do 100% understand what you mean by not wanting WCB Holders to be open to allegations of fraud and not wanting to risk being a WCB Holder, to be potentially tarnished by association. Being a charity however, for example (a recognised top organisational standard) doesn’t actually prevent fraud any more than being a sole trader does. If a sole trader takes money on false pretences (exactly as though a Rescue took donations to fund rescue work and then went on holiday) it would be a case of fraud, that could also be investigated, as far as I am aware. I know of 2 Wildlife Rescues who have been prosecuted for misappropriation of donations but that doesn’t mean that other charities are tarnished by comparison. What are your thoughts on this please?
I am not stating that the WCB is a ‘fix all’ solution to every challenge that human nature can raise, when running a wildlife rescue: lack of honesty, lack of professionalism, neglect of duty and other human character flaws or errors can appear within any structural form (charity or WCB Holder) and without a hugely controlling influence - an enormous and frighteningly controlling bureaucratic effort, of every structure and action - they are hard to prevent, in any measure.
What the WCB does do is invite voluntary proof of standards: the willingness of Rescues & Rehabbers to stand up as an example of being open to scrutiny. It’s a very important start, I think."
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I ENDED WITH... "Thank you so much for your honesty and your email. It means a great deal that you went to the effort to be part of this important conversation. I would love to see you at the next open zoom WCB Meeting - I am setting it for later this year - inviting discussion around these topics and others - to see how Wildlife Rescue standards can best be established, for the sake of everyone (wildlife especially).
Alana x"
The response that I received to my email/answers was as follows... "Thank you for your thorough response. Perhaps we will get to meet on line, or even in person, to discuss these issues. Typing them out is time-consuming and always lacks the nuances of a conversation.
Until then stay safe and keep up your great work."
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