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1701

Risk of privacy screens around gaming machines

https://www.gamblingcommission.gov.uk/licensees-and-businesses/page/privacy-booths

A screen or pod around a gaming machine, designed to increase the privacy of the player, could be stopping your staff from effectively monitoring gaming machine play. > It is your responsibility to ensure your staff are able to effectively monitor gaming machine play for a number of reasons that are part of your licence conditions. > > The [Licence conditions and code of practice (LCCP)](/licensees-and-businesses/lccp/online) state: ‘Facilities for gambling must only be offered in a manner which provides for appropriate supervision of those facilities by staff at all times-. Age verification, customer interaction and self-exclusion policies all require you to take into account the structure and layout of your gambling premises. You must be able to evidence to us and your local licensing authority how you have considered the risk to the licensing objectives and implemented effective controls, prior to the introduction of any new machine arrangements. Where you are unable to demonstrate effective controls we, or the LA, can use regulatory powers to instruct the removal of any impediments to staff carrying out their responsibilities and investigate any regulatory breaches. Commercial motivations should never take precedence over the requirement to provide gaming machines in a safe and responsible manner.

1702

Risk of privacy screens around gaming machines

For licensing authorities

https://www.gamblingcommission.gov.uk/licensees-and-businesses/page/privacy-booths

Where you encounter atypical gaming machine arrangements, you should consider the means by which gaming machines are supervised (eg line of sight to counter, effective CCTV, mirrors or floor staff) and consider whether that is appropriate for that premises. Whether amendments to a premises amount to a ‘material change- warranting an application to vary the premises licence under [section 187 of the Gambling Act (opens in a new tab)](https://www.legislation.gov.uk/ukpga/2005/19/section/187 ) is a matter for local determination and it is expected a common sense approach should be adopted. There is more information in [section 7.51 of the Guidance to licensing authorities](/guidance/guidance-to-licensing-authorities/part-7-application-for-premises-variation-s-187-material-change) . --- Last updated: 14 June 2021 Show updates to this content No changes to show.

1703

5.1.1 - Cash and cash equivalents

https://www.gamblingcommission.gov.uk/licensees-and-businesses/lccp/condition/5-1-1-cash-and-cash-equivalents

Applies to: All operating licences except gaming machine technical, gambling software and host licences 1. Licensees, as part of their internal controls and financial accounting systems, must implement appropriate policies and procedures concerning the usage of cash and cash equivalents (eg bankers drafts, cheques and debit cards and digital currencies) by customers, designed to minimise the risk of crimes such as money laundering, to avoid the giving of illicit credit to customers and to provide assurance that gambling activities are being conducted in a manner which promotes the licensing objectives. 2. Licensees must ensure that such policies and procedures are implemented effectively, kept under review, and revised appropriately to ensure that they remain effective, and take into account any applicable learning or guidelines published by the Gambling Commission from time to time.

1704

6.1.1 - Provision of credit

https://www.gamblingcommission.gov.uk/licensees-and-businesses/lccp/condition/6-1-1-provision-of-credit

Applies to: All gaming machine general operating licences for adult gaming centres and family entertainment centres 1. Licensees must neither: 1. provide credit themselves in connection with gambling; nor 2. participate in, arrange, permit or knowingly facilitate the giving of credit in connection with gambling.

1705

3.7.1 - Provision of credit

https://www.gamblingcommission.gov.uk/licensees-and-businesses/lccp/condition/3-7-1-provision-of-credit

Applies to: All non-remote general betting licences (except where betting is offered under a 2005 Act casino premises licence), pool betting licences and all remote licences (including ancillary remote betting licences), except gaming machine technical, gambling software, host, ancillary remote casino, ancillary remote bingo and remote betting intermediary (trading rooms only) licences **Social responsibility code** Compliance with these is a condition of licences; therefore any breach of them by an operator may lead the Commission to review the operator-s licence with a view to suspension, revocation or the imposition of a financial penalty and would also expose the operator to the risk of prosecution. 1. Licensees who choose to offer credit to members of the public who are not themselves gambling operators must also: 1. have procedures for checking and scoring applications for credit from such customers, for setting, and for the increase of, credit limits 2. explain these procedures to customers 3. set a maximum credit limit for each customer and not permit customers to exceed that limit without further application 4. apply a 24-hour delay between receiving a request for an increase in a credit limit and granting it in those cases where the limit exceeds that which the operator previously set 5. not require a minimum spend within a set time period 6. take all reasonable steps to ensure that offers of credit are not sent to vulnerable persons, including those who have self-excluded from gambling 7. ensure that information about an offer of credit includes a risk warning of what may happen in the event of default.

1706

Social responsibility

https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/page/social-responsibility

Lotteries are a form of gambling and as such societies and local authorities are required to ensure that children and other vulnerable people are not exploited by their lottery. The minimum age for participation in a society or local authority lottery is 16 years of age. A person commits an offence if they invite or allow a child to enter such a lottery. Licensed societies and local authorities running lotteries must have written policies and procedures in place to help prevent and deal with cases of under-age play. Licence holders must take all reasonable steps to ensure that information about how to gamble responsibly and how to access information and help in respect of problem gambling is readily available. Further information about social responsibility requirements is contained in the Commission-s [Licence Conditions and Codes of Practice](/licensees-and-businesses/lccp/online) . [Previous page Lottery submissions](/licensees-and-businesses/guide/page/lottery-submissions) [Next page B3A lottery machines](/licensees-and-businesses/guide/page/b38-lottery-machines) --- Last updated: 23 February 2021 Show updates to this content No changes to show.

1707

3.1.1 - Combating problem gambling

https://www.gamblingcommission.gov.uk/licensees-and-businesses/lccp/condition/3-1-1-combating-problem-gambling

Applies to: All licences **Social responsibility code** Compliance with these is a condition of licences; therefore any breach of them by an operator may lead the Commission to review the operator-s licence with a view to suspension, revocation or the imposition of a financial penalty and would also expose the operator to the risk of prosecution. 1. Licensees must have and put into effect policies and procedures intended to promote socially responsible gambling including the specific policies and procedures required by the provisions of section 3 of this code. 2. Licensees must make an annual financial contribution to one or more organisation(s) which are approved by the Gambling Commission, and which between them deliver or support research into the prevention and treatment of gambling-related harms, harm prevention approaches and treatment for those harmed by gambling.

1708

LCCP RET list: Procedure and guidance for removal of organisations

Introduction

https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/lccp-ret-list-procedure-and-guidance-for-removal-of-organisations

The purpose of this guidance note is to reiterate the requirements and expectations for organisations on the LCCP RET list for research, prevention and treatment, and clarify the circumstances, criteria and process for removing organisations from the list. ## Background - LCCP RET list procedure and guidance for the removal of organisations ## Requirements for operators ## Requirements for organisations on the LCCP RET list ## By accepting RET contributions from licensed operators, organisations on the LCCP RET list commit to: ## Approach - LCCP RET list procedure and guidance for the removal of organisations ## Removal from the LCCP RET list ## Process ## Appeals --- Last updated: 30 July 2021 Show updates to this content No changes to show.

1709

LCCP RET list: Procedure and guidance for removal of organisations

Background - LCCP RET list procedure and guidance for the removal of organisations

https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/lccp-ret-list-procedure-and-guidance-for-removal-of-organisations

On 1 January 2020 a new LCCP requirement came into force requiring operators to direct their annual financial contribution for gambling research, prevention and treatment (referred to as RET for shorthand) as required by [LCCP SR code 3.1.1](/licensees-and-businesses/lccp/condition/3-1-1-combating-problem-gambling) to one or more organisations on a [list maintained by the Commission](/licensees-and-businesses/guide/list-of-organisations-for-operator-contributions) . This change was a result of the Commission-s review of the RET arrangements in February 2018 which concluded that the current voluntary system was falling short of its objectives. The Commission was concerned that RET contributions were disparate and uncoordinated and that some recipients of RET contributions had no clear link to the research, prevention or treatment of gambling harms. To address this the Commission committed to improving the transparency of the amounts and destinations of RET funding, with a specific commitment in relation to LCCP and following a public consultation the amended SR code came into force.

1710

LCCP RET list: Procedure and guidance for removal of organisations

Requirements for operators

https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/lccp-ret-list-procedure-and-guidance-for-removal-of-organisations

The purpose of the LCCP RET list is to demonstrate to operators how to be compliant with the LCCP requirement to make annual financial contributions to research, prevention and treatment. Operators must: * make an annual financial contribution to each of research, prevention and treatment * ensure that these donations go to one or more organisation on the LCCP RET list * ensure that they have no connection to the recipient organisation * report information accurately in their annual or quarterly regulatory return to the Commission about the destination(s) of their payment and the amounts that have been contributed. This includes ensuring that there is no duplication of data across multiple licences.

1711

LCCP RET list: Procedure and guidance for removal of organisations

By accepting RET contributions from licensed operators, organisations on the LCCP RET list commit to:

https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/lccp-ret-list-procedure-and-guidance-for-removal-of-organisations

* using contributions solely for the purpose of reducing gambling harms * working within the structures of the Strategy to engage with people with lived experience * providing information as requested to support the coordination and delivery of actions under the Strategy. Collaborating under the National Strategy to Reduce Gambling Harms to: * prioritise actions * coordinate activity * minimise duplication or conflict of activity. Upholding the principles of the Strategy by taking: * an evidence-based approach * evaluating impact * supporting transparency. ### Organisations on the LCCP RET list are also expected to: * work with the Gambling Commission in an open and cooperative way and inform the Commission of anything that could have a significant impact on the nature or structure of their organisation * not interpret being on the LCCP RET list as approval or endorsement by the Gambling Commission nor refer to the Commission approving or endorsing their organisation in any promotional or publicity materials * not have industry representatives on their boards or in other roles that have decision-making powers * provide data on the amount of LCCP RET contributions received, which operator(s) they relate to, and when the contribution(s) were made * provide information about changes to the information outlined above to the Gambling Commission as soon as reasonably possible.

1712

LCCP RET list: Procedure and guidance for removal of organisations

Approach - LCCP RET list procedure and guidance for the removal of organisations

https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/lccp-ret-list-procedure-and-guidance-for-removal-of-organisations

The Gambling Commission commits to working with organisations on the LCCP RET list in an open, supportive and transparent manner. Any investigations into possible removal from the LCCP RET list will be conducted fairly and openly and organisations whose status on the LCCP RET list is under consideration will be given the opportunity to review and comment on their potential removal before a final decision is made. We expect organisations on the LCCP RET list to also be open and transparent with the Commission and to alert us as soon as possible to any potential issues which may affect their status on the LCCP RET list, including any formal investigations.

1713

LCCP RET list: Procedure and guidance for removal of organisations

Removal from the LCCP RET list

https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/lccp-ret-list-procedure-and-guidance-for-removal-of-organisations

Organisations on the LCCP RET list must inform the Commission of anything that could have a significant impact on the nature or structure of their organisation. Any misrepresentation or failure to reveal information may be deemed sufficient cause for the organisation to be refused or removed from the list of organisations to which gambling businesses may make financial contributions in order to meet the LCCP RET requirement. Examples of criteria which would undermine the aims and objectives of the LCCP RET list and would result in review and likely removal from the list include (but are not limited) to the following: * going into administration or equivalent, or criminal charges being laid, the nature or circumstances of which give the Commission cause for concern (such as theft or fraud) * an investigation by a professional, statutory, regulatory or government body into their activities and/or removal of their independent oversight (e.g. Charity Commission or CIC status) * changes in key personnel or circumstances which means the organisation is no longer commissioning or delivering research, prevention or treatment to reduce gambling harms * failure to provide information when requested (e.g. data on RET contributions) * evidence of a persistent refusal to engage collaboratively with other stakeholders and partners * complaints by other organisations, service users or others where there is evidence to suggest serious concerns * mergers or takeovers, LCCP RET list status cannot be transferred to another organisation and a new request must be submitted.

1714

LCCP RET list: Procedure and guidance for removal of organisations

Process

https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/lccp-ret-list-procedure-and-guidance-for-removal-of-organisations

Where there is evidence of a serious concern which may compromise the aim of the LCCP RET list, call into question an organisation-s suitability to be on the RET list, or an issue that could have a significant impact on the nature or structure of an organisation on the list, the Gambling Commission will undertake an internal review as follows: * the Gambling Commission will convene a review panel comprising members of the Social Responsibility Funds Group * Gambling Commission officials will compile a summary of the issue(s) identified, along with any relevant documents, setting out the evidence and concerns * the organisation under review will be given sight of these papers and will be given the opportunity to provide any written representations and any relevant supporting information that they would like the panel to consider * the review panel will consider the papers and any representations or additional documents provided by the organisation and reach a decision accordingly. A decision letter will be sent to the applicant as soon as practicable after the decision has been made. > An organisation that is removed from the LCCP RET list will not to be prevented from applying to rejoin the RET list again, but the Commission may take account of any previous decision that has been made when assessing the application. > >

1715

LCCP RET list: Procedure and guidance for removal of organisations

Appeals

https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/lccp-ret-list-procedure-and-guidance-for-removal-of-organisations

If an organisation wishes to appeal a decision made by the review panel for removal from the list, the following appeals process will apply: * notification of the wish to appeal must be sent to [SRFunds@gamblingcommission.gov.uk](mailto:SRFunds@gamblingcommission.gov.uk) within 28 days of the date the decision letter was issued * the Gambling Commission will convene an appeal panel comprising at least one Executive Director (or higher) who will have had no involvement with the decision under appeal * Gambling Commission officials will compile a pack of papers, comprising the original papers that were considered by the review panel, any representations and additional documents that were submitted by the organisation, and the decision under appeal, as well as any further documents that may be relevant to the case * the organisation making the appeal will be given sight of these papers and will be given the opportunity to provide any further representations or additional documents they would like the appeal panel to consider as to why the original decision was wrong * the Appeal panel will consider the papers and any representations or additional documents provide by the organisation and reach a decision accordingly. A decision letter will be sent to the organisation as soon as practicable after the decision has been made.

1716

Contents

https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/lccp-ret-list-procedure-and-guidance-for-removal-of-organisations

* [LCCP RET list: Procedure and guidance for removal of organisations](#) * [Background - LCCP RET list procedure and guidance for the removal of organisations](#background-lccp-ret-list-procedure-and-guidance-for-the-removal-of) * [Requirements for operators](#requirements-for-operators) * [Requirements for organisations on the LCCP RET list](#requirements-for-organisations-on-the-lccp-ret-list) * [Approach - LCCP RET list procedure and guidance for the removal of organisations](#approach-lccp-ret-list-procedure-and-guidance-for-the-removal-of) * [Removal from the LCCP RET list](#removal-from-the-lccp-ret-list) * [Process](#process) * [Appeals](#appeals) [Print this guide](#)

1717

3.5.2 - Self-exclusion – non-remote ordinary code

https://www.gamblingcommission.gov.uk/licensees-and-businesses/lccp/condition/3-5-2-non-remote-ordinary-code

Applies to: All non-remote licences and remote betting intermediary (trading rooms only) licences, but not gaming machine technical and gambling software licences **Ordinary code** These do not have the status of operator licence conditions but set out good practice. Operators may adopt alternative approaches to those set out in ordinary code provisions if they have actively taken account of the ordinary code provision and can demonstrate that an alternative approach is reasonable in the operator's particular circumstances; or that to take an alternative approach would be acting in a similarly effective manner. Ordinary codes of practice are admissible in evidence in criminal or civil proceedings and must be taken into account in any case in which the court or tribunal think them relevant, and by the Commission in the exercise of its functions; any departure from ordinary code provisions by an operator may be taken into account by the Commission on a licence review, but cannot lead to imposition of a financial penalty. 1. Self-exclusion procedures should require individuals to take positive action in order to self- exclude. This can be a signature on a self-exclusion form. 2. Individuals should be able to self-exclude without having to enter gambling premises. 3. Before an individual self-excludes, licensees should provide or make available sufficient information about what the consequences of self-exclusion are. 4. Licensees should take all reasonable steps to extend the self-exclusion to premises of the same type owned by the operator in the customer-s local area. In setting the bounds of that area licensees may take into account the customer-s address (if known to them), anything else known to them about the distance the customer ordinarily travels to gamble and any specific request the customer may make. 5. Licensees should encourage the customer to consider extending their self-exclusion to other licensees- gambling premises in the customer-s local area. 6. Customers should be given the opportunity to discuss self-exclusion in private, where possible. 7. Licensees should take steps to ensure that: - the minimum self-exclusion period offered is of a duration of not less than 6 nor more than 12 months - any self-exclusion may, on request, be extended for one or more further periods of at least 6 months each - a customer who has decided to enter a self-exclusion agreement is given the opportunity to do so immediately without any cooling-off period. However, if the customer wishes to consider the self-exclusion further (for example to discuss with problem gambling groups), the customer may return at a later date to enter into self- exclusion - at the end of the period chosen by the customer, the self-exclusion remains in place for a further 6 months, unless the customer takes positive action in order to gamble again - where a customer chooses not to renew the self-exclusion, and makes a positive request to begin gambling again during the 6 month period following the end of their initial self-exclusion, the customer is given one day to cool off before being allowed access to gambling facilities. The contact must be made via telephone or in person - notwithstanding the expiry of the period of self-exclusion chosen by a customer, no marketing material should be sent to them unless and until they have asked for or agreed to accept such material. - The licensee should retain the records relating to a self-exclusion agreement at least for the length of the self-exclusion agreement plus a further 6 months. - Please note that the Commission does not require the licensee to carry out any particular assessment or make any judgement as to whether the previously self-excluded individual should again be permitted access to gambling. The requirement to take positive action in person or over the phone is purely to a) check that the customer has considered the decision to access gambling again and allow them to consider the implications; and b) implement the one day cooling-off period and explain why this has been put in place. - Licensees should have, and put into effect, policies and procedures which recognise, seek to guard against and otherwise address, the fact that some individuals who have self-excluded might attempt to breach their exclusion without entering a gambling premises, for example, by getting another to gamble on their behalf. - Licensees should have effective systems in place to inform all venue staff of self-excluded individuals who have recently attempted to breach a self-exclusion in that venue, and the licensees neighbouring venues. - In providing training to staff on their responsibilities for self-exclusion, licensees should have, as a minimum, policies for induction training and refresher training.

1718

Destinations of regulatory settlements to be applied for socially responsible purposes

https://www.gamblingcommission.gov.uk/licensees-and-businesses/page/destinations-of-regulatory-settlements-to-be-applied-for-socially

The Commission reviews proposals for destinations of regulatory settlements. The following projects have been approved as destinations of regulatory settlements since March 2019. Some of these projects have been approved as destinations but have not yet received funds. This information will be updated at least on an annual basis.

1719

Destinations of regulatory settlements to be applied for socially responsible purposes

Information about destinations of regulatory settlements to be applied for socially responsible purposes

https://www.gamblingcommission.gov.uk/licensees-and-businesses/page/destinations-of-regulatory-settlements-to-be-applied-for-socially

Information about destinations of regulatory settlements to be applied for socially responsible purposes. | Date | Organisation | Amount | Project | | --- | --- | --- | --- | | November 2022 | Anonymind and Leon House | £992,298.94 | A 24-month study to better understand gambling in the veterans community including the pathways to problem gambling and access to interventions to develop policy and practice solutions. || November 2022 | Addiction Recovery Agency (Ara) | £115,000 | A 18-month project to understand the developmental precursors to disordered gambling, with a focus on the relationship between disordered gambling and trauma. This will assist in the development of more effective early intervention and treatment initiatives. || November 2022 | Glasgow University | £402,184 | A 18-month project that will conduct new empirical research on gamblers patterns of expenditure across a range of areas, through secondary analysis of existing data, design and implementation of a bespoke random probability survey of gamblers and a Discrete Choice Experiment. To understand the preferences and choices of gamblers to generate robust new insights into likely consumer behaviour changes in response to a range of potential new protections from gambling harm. || November 2022 | GamCare | £236,086 | A 12-month pilot to explore the feasibility of enabling organisations to 'warm transfer' their customers who are harmed by gambling directly into the National Gambling Helpline-s live-chat and instant messenger services (for example WhatsApp and Facebook Messenger). || November 2022 | Red Card Gambling Support | £130,000 | A 2-year pilot to provide gambling awareness and education for semi-professional (non-league) football clubs, targeting 1,500 young players aged 16 to 25 years old and club staff in up to 30 clubs across London, southeast, and the Midlands. || November 2022 | JC Foundation Trust | £24,560 | A 18-month project to support the Jewish community in Salford and ensure that more individuals and families in this community receive the help and support they need to reduce their gambling habits and therefore improve their financial situation, personal relationships, and mental health. || November 2022 | The Association of Directors of Public Health (ADPH) North East | £750,000 | A 3-year pilot to address gambling harms in a region which has high rates of deprivation and high rates of harmful gambling compared to other areas in England. Working with key target groups including those already living in poor health, low life-satisfaction, pre-existing mental health conditions and history of substance misuse and implementing and evaluating co-produced interventions with practice partners and experts by experience, across primary, secondary, and tertiary prevention. || August 2022 | GREO | £1,612,300 | The goal of the Gambling-Related Suicide Research Programme is to fund research in the United Kingdom (UK) that will improve understanding of the links between gambling and suicide to increase the effectiveness of regulatory measures, harm reduction, prevention, postvention, and ultimately reduce the number of gambling-related suicides in the UK. Among the £1,612,300 available, GREO Evidence Insights will disburse more than 80 percent as research grants and supports for knowledge mobilisation via a transparent, peer review adjudicated competition. Two grant opportunities were launched in March 2023. || August 2022 | Behavioural Insights Team (BIT) | £4,320,000 | An extension of the BIT Gambling Policy & Research Unit to develop and test approaches to reducing gambling harms. The Unit will work with stakeholders and policymakers to discover, test and scale ways to reduce gambling harm. || August 2021 | University of Edinburgh and Evidence to Impact | £35,598.92 | The project is a pilot study to test delivery of Preventing Gambling Related Harm in Adolescents (PRoGRAM-A), a school-based, peer-led gambling prevention intervention which trains secondary school students to become peer supporters to diffuse gambling prevention messages to their peers and social networks. The intervention is adapted from an existing and effective smoking prevention programme called A Stop Smoking in Schools Trial (ASSIST). || December 2021 | TalkBanStop Campaign in partnership with Gamcare, Gamban and GAMSTOP | £1,379,451 | A one-year extension to the TalkBanStop partnership pilot to further promote, offer and evaluate the use of blocking software free of charge, alongside other tools for consumers which are already free of charge. This one-year extension is with a particular focus on evaluation to inform decisions around long-term sustainability. The three organisations coming together to promote and evaluate the role of blocking software are: * GamCare-s National Gambling Helpline * GAMSTOP self-exclusion * Gamban blocking software, (which will be provided free of charge as part of the pilot). | | November 2021 | GamCare | £1,107,082 | A three-year project to develop a new money and debt service within GamCare which will complement existing services and provide simultaneous gambling, money and debt advice support to gamblers and affected others via telephone or online, and foster partnerships with money and debt organisations to increase cross-signposting and referrals. | | November 2021 | Sheffield Mind Ltd | £148,202.27 | A two-year pilot to develop new ways of working with young people at risk of gambling-related harm in Sheffield with an emphasis on resilience and prevention to empower young people to act as peer educators. | | August 2021 | GREO | £226,064 | The overarching goal of this 18-month project is to support specific communities who are at greater risk for gambling harms by extending understanding of effective information pathways. | | August 2021 | National Institute of Economic and Social Research (NIESR) | £140,050 | This short six-month pilot aims to provide a new way of measuring the socio-economic effects of gambling through an evaluation of existing evidence on benefits and costs of gambling, a specialised survey and NIESR-specific modelling to measure the behavioural dimension of gambling and its socio-economic effects, and ongoing engagement with key stakeholders. | | August 2021 | Gambling with Lives | £498,000 | This one-year project will create, test and embed a range of information, resources and training tools, and undertake professional engagement, with partners across Greater Manchester. This will facilitate identification of people experiencing gambling harms, help to ensure that essential information is provided and support people to identify support that is needed. | | August 2021 | Behavioural Insights Team (BIT) | £1,680,000 | Funding for one-year to support the creation of a Gambling Policy & Research Unit that will: * work with key stakeholders to design and scale successful interventions across the gambling market such as with banks and the financial services sector to help them understand, identify and support their most at-risk customers * build evidence for policy and regulatory advice and changes through a database of ‘what works- that can be replicated and iterated globally * explore instances where gambling is influenced and intersects with other sectors, to inform cutting-edge solutions. | | August 2021 | City, University of London in partnership with LAB Group Services | £209,601 | University of London, and LAB Group Services have collaborated on a one-year project to research methods for reducing gambling related harms in digital spaces. To understand the impact of COVID this project has been extended to include the full integration of mobile kinetics and interventions through a supplementary project of research to dovetail with its original laptop/desktop focused research. | | August 2021 | Local authorities represented by the Association of Directors of Public Health, Yorkshire & Humber | £800,000 | This three-year project is to implement and embed a sustainable, multi-component and collaborative programme across Yorkshire and the Humber to tackle gambling related harms, including gambling related debt, with a focus on education and prevention and access to support and treatment. The aim of the project is to understand what works in preventative education through insights provided by research and evaluation and to increase referrals to treatment and support. | | August 2021 | Ara-Addiction Recovery Agency in partnership with: * Beacon Counselling Trust * DrugFam * GREO | £994,540 | This project is a collaboration between a number of organisations working to support affected others in a two-year project to expand the knowledge and evidence of any links between gambling and substance misuse in those affected by another-s gambling. The pilot also aims to develop support via hubs which will offer structured support plan to affected family members. | | July 2021 | GamCare | £344,440 | A 2-year project to accelerate GamCare-s work in improving signposting for gambling customers, specifically through developing industry codes for the display of safer gambling information and evaluating the impact of these codes on customer behaviour. | | July 2021 | Epic Restart Foundation | £500,000 | The EPIC Restart Foundation pilot project will aim to help those recovering from the effects of gambling addiction to build resilience, find new and meaningful opportunities, and positively restart their lives after gambling by giving ongoing help after treatment to help prevent any relapse via a three-stage education programme. | | March 2021 | Deal Me Out CIC | £161,103 | This project aims to deliver a safer gambling awareness and education programme in Wales which will specifically target Welsh language users. | | March 2021 | Scottish Public Health Network (ScotPHN) | £394,000 | Building on the work of ScotPHN to develop a whole systems approach to reducing gambling harms, this programme of activity supports development of public health surveillance approaches, evaluation of programme activity, local community capacity building and a summit on gambling harms to be held in Glasgow. | | March 2021 | StepChange Debt Charity in partnership with Personal Finance Research Centre (PFRC), University of Bristol and Northern Gambling Clinic | £63,604 | This project aims to explore how to reduce the harm caused by gambling related over indebtedness among those who gamble and those with problem debts. | | March 2021 | Beacon Counselling Trust Criminal Justice Police Custody Suites Screening, Horizon Scanning and Capacity Building Project | £984,000 | This projects aims to use the findings from an initial pilot to develop a sustainable implementation model embedded within NHS commissioning. Beacon intend to work with the following Police forces over approximately three years to develop a model that will be suitable for roll out nationally: * Lancashire * Merseyside * West Midlands * Cumbria * Manchester * Cheshire | | February 2021 | GamCare – Criminal Justice Project | £850,851 | This project aims to deliver a bespoke two-year Gambling Harms and Criminal Justice (CJ) Development Project. The nature of the work will include: * CJ-focused training and awareness raising to staff/people in the CJ system (CJS) * exploration of the needs and issues facing gamblers in the CJS - facilitating ‘thought leadership- to discuss potential solutions and responses * raising the profile of the gambling/crime issue, including targeted campaigns. | | February 2021 | Academic Forum for Gambling Research, facilitated by GREO | £574,600 | This project will support the development of the Academic Forum for the Study of Gambling which is a coordinated body to support rigorous, independent research to prevent, reduce, and address gambling harms in the UK, facilitated by GREO. | | December 2020 | GREO-Global Research Exchange | £2,088,370 | The project aims to develop a knowledge translation platform to facilitate evidence-based action in support of the National Strategy to Reduce Gambling Harm in Great Britain. The next phase of the project builds upon the ‘research to inform action- enabler of the National Strategy for the purpose of widening the research base and improving links between research and policy. | | November 2020 | YGAM in partnership with Redcard, TalkGen and Clear View Research | £627,391 | The project-s aim is to create a purposeful and tailored approach for gambling-harm prevention, with and for BAME communities. The project centres on understanding socio-cultural and religious contexts on shame and stigma. | | November 2020 | Beacon Counselling Trust in partnership with ARA - Recovery 4 All and GREO | £560,653 | To meet the needs of an underserved ethnocultural population with unique cultural considerations, this two-year project will build capacity in the South Asian community to reduce gambling harms by: * implementing a culturally appropriate train-the-trainer model to deliver gambling harm reduction education * increasing knowledge of gambling harm and treatment options among the South Asian population * improving referral pathways to treatment for those experiencing harms. | | November 2020 | Birmingham City Council in partnership with University of Birmingham | £393,800 | Project aims to pilot the ability to detect and prevent gambling related harm as a cause of tenancy loss by establishing and putting in support mechanisms to those at risk or already engaged in harmful gambling. | | November 2020 | GamFam | £276,348 | A pilot project which provides a support programme to families impacted by gambling related harms. | | November 2020 | Gamcare – Woman-s Programme | £1,669,000 | The programme comprises primarily of training and prevention activities, outreach and strategic stakeholder engagement for women who are experiencing gambling related harm. | | October 2020 | TalkBanStop Campaign in partnership withGamcare, Gamban and GAMSTOP | £2,633,379 | TalkBanStop partnership campaign. A 12-month pilot to promote, offer and evaluate the use of blocking software free of charge, alongside other tools for consumers which are already free of charge. The three organisations coming together to promote blocking software are: * GamCare-s National Gambling Helpline * GAMSTOP self-exclusion * Gamban blocking software, (which will be provided free of charge as part of the pilot). | | September 2020 | Gambling with Lives | £102,600 | Scoping of a Treatment Pathway project to be delivered in collaboration with Leeds and York NHS Partnership Trust, NHS England, City Council public health team, primary care team the project aims to develop clear care pathways for those experiencing gambling related harm. The pathway will be designed with stakeholders including people with lived experience, specialist treatment providers, public health and the third sector. The pathway will be designed with stakeholders including people with lived experience, specialist treatment providers, public health and the third sector. | | July 2020 | City University of London in partnership with LAB Group | £366,893 | Project seeks to spot potential problem gambling earlier in the lifecycle, by mapping kinetic, typing, scrolling and other 'implicit' digital behavioural interactions via gambling and apps. It also aims to provide comparative linguistic analysis and nudge theory to facilitate safer gambling messaging and take-up tools and support. | | July 2020 | YGAM | £90,000 | Stand-alone to respond to Covid-19. Development of Digital Learning (digital assets for flipped or fully online content solution, learning platform and of microsite). Development of current face-to-face learning resources. Development of Evaluation Framework. | | February – July 2020 | GamCare | £500,000 (part funded) | A project to enhance the delivery of youth education and age-appropriate treatment options. Design and delivery of both guided self-help and session plans for both young people and professionals. These will be available in both analogue and digital formats and supported by the existing evidence base around what works with young people. | | June 2020 | PG Solutions (part of ARA Group) | £311,000 | Project to test and evaluate safer gambling messaging and embed a safer gambling toolkit to support the messaging. The project aims to reduce the numbers of people harmed by problem gambling and improve the access to safer gambling information, advice, and help. | | June 2020 | Forward Trust | £30,900 | Supporting offenders serving prison sentences across 19 sites, conducting a survey exercise to assess if issues with gambling have worsened during the coronavirus prison lockdown, and developing tailored self-help material and resources for prisoners coming up to release. | | June 2020 | GamCare | £195,672 | Ensuring GamCare maintains appropriate IT infrastructure to remain resilient during Covid-19 period. | | June 2020 | GamCare | £36,000 | Project to enable gambling blocking software to be provided to individuals accessing the National Gambling helpline or GamCare treatment network, on a temporary basis. This project was originally in receipt of £21,000 although it was noted that an extension to the project may be possible. In December 2021, this project was extended to provide deeper longitudinal evaluation and research about those who access self-exclusion, barriers to treatment, and use of other tools such as gambling blocking and financial blocking. The extension was for a further £15,000. | | May 2020 | Gambling Research Exchange (GREO) | £1,100,000 (part funded) | Evaluation based project which aims to accelerate the implementation and spread of effective, evidence-based initiatives for safer gambling. | | April 2020 | Beacon Counselling Trust | £30,000 | Scoping project working with five police forces in the North West of England to support co-ordination of police forces- problem gambling screening activity within custody suites, working alongside other criminal justice projects. | | April 2020 | Beacon Counselling Trust | £517,228 | Project in collaboration with the Unite trade union, the Union Learning fund, and Addiction Recovery Agency (ARA), alongside employers, to roll out a Workplace Charter, to reduce harms in the workplace from gambling through education, support and referral to treatment. | | April 2020 | Birmingham and Solihull Mental Health Trust | £67,500 | Introducing and evaluating a co-designed and co-produced pilot public health Recovery College course on gambling and addiction. The course is targeted at mental health service users, carers and families and mental health professionals. | | April 2020 | GambleAware | £8,800,000 | Funds to help ensure treatment and support services can continue to operate effectively and withstand additional pressures on their services caused by the Covid-19 outbreak. | | March 2020 | Charities Aid Foundation | £40,000 | Supporting effective coordination of the National Strategy to Reduce Gambling Harms – focus on funding, flows and partnerships for the third sector. | | January 2020 | Greater Manchester Combined Authority | £750,000 | Pathfinder project for local authority public health approaches. | | December 2019 | Health and Social Care Alliance | £496,647 | Operation of a forum for participants with lived experience of gambling harm to steer the implementation of the National Strategy within Scotland. | | December 2019 | Scottish Public Health Network | £142,483 | Embedding a whole population approach to gambling in Scotland. | | November 2019 | Centre for Public Scrutiny | £103,200 | Using local authority scrutiny processes to understand and tackle gambling related harms. | | November 2019 | The Samaritans | £523,998 | Training and resources for gambling businesses to identify and support customers experiencing risks of suicide. | | October 2019 | Money and Mental Health Policy Institute | £228,500 | A two-year programme of work to engage the financial services sector in efforts to reduce gambling harms. | | September 2019 | Healthy Stadia | £37,500 | An effective model to be rolled out to reduce the incidence of unhealthy gambling behaviour in the football stadium environment. | | September 2019 | Hurley Group | £1,562,184 | A pilot project to explore the design and delivery of an NHS based integrated community-based service for people experiencing harm from gambling. | | September 2019 | Gordon Moody | £220,000 | Capital funds to increase treatment capacity. | | August 2019 | Gordon Moody | £200,000 | To enable the effective analysis of the data that is captured by Gordon Moody treatment provision. | | July 2019 | Howard League for Penal Reform | £1,838,000 | Large scale problem gambling and crime commission. | | June 2019 | Gambling Research Exchange | £1,900,000 | Creating a programme of work including a new research, dissemination evidence hub committed to preventing and reducing gambling harms in Great Britain in support of the National Strategy. | | May 2019 | GamCare | £3,223 | Provide and distribute stock of printed self-help workbooks. | | | | £298,590 | Design and deliver a website to support the administration of the GamCare Safer Gambling Standard, and ensuring the ‘scores- for accredited operators are clearly visible to consumers. | | | | £250,000 | To build capacity for the effective analysis of the data that is captured by GamCare treatment provision and from the National Gambling helpline. | | March 2019 | GambleAware | £30,000 | To accelerate progress to deliver GambleAware-s activity to support the [National Strategy to Reduce Gambling Harms.](/about-us/reducing-gambling-harms) | --- Last updated: 30 March 2023 Show updates to this content Added the latest 10 projects approved for funding via regulatory settlements.

1720

Social Responsibility Funds Group - Terms of Reference

Introduction

https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/social-responsibility-funds-group-terms-of-reference

The Social Responsibility Funds Group has been established to ensure robust and transparent decision-making in relation to the allocation of Regulatory Settlement funds and applications to join the approved Licence Conditions and Codes of Practice (LCCP) Research, Education and Treatment (RET) list. [Next page Scope](/licensees-and-businesses/guide/page/social-responsibility-funds-group-terms-of-reference-scope) --- Last updated: 4 May 2022 Show updates to this content No changes to show.

1721

Identifying the right customers

https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/page/identifying-the-right-customers

> This formal guidance for remote gambling operators is not current and from 12 September 2022 operators are no longer required to take it into account. It was published in July 2019 and remained in effect from 31 October 2019 to 11 September 2022. > Following our consultation on customer interaction, Social Responsibility Code Provision 3.4.3 for remote gambling operators has been introduced and the majority of requirements are in effect from 12 September 2022. We issued this [update on the regulatory requirements and status of formal guidance regarding customer interaction for remote gambling operators](/news/article/new-remote-customer-interaction-requirements-and-guidance-update) . The [guidance issued in June 2022 under Social Responsibility Code Provision 3.4.3](/guidance/customer-interaction-guidance-for-remote-gambling-licensees-formal-guidance) is not in effect and is subject to further consultation. Operators are not required to take it into account. > > You need to know: * the types of markers and behaviours that could indicate harm relevant to online gambling, and * how to spot when those indicators should trigger an interaction. You need to put together what you know about the customer, with the relevant indicators of harm, to decide whether you need to interact. More knowledge about what to look for, with effective processes for monitoring customer behaviour, can mean quicker and better-informed decisions. Some indicators of harm, such as high staking behaviour, can look similar to VIP and high-value customer activity. Even if you think the customer can afford it, they may still be experiencing gambling harms. Your enhanced contact with your VIPs means you have many opportunities to get to know them well and make better informed decisions. ### Identify We expect you to: * use a range of indicators relevant to your business. Do not rely on financial indicators alone. You should use realistic thresholds and trigger points, and remember that not every customer who is experiencing or at risk of harm will trigger every indicator * monitor customer activity so that you are able to interact early and quickly. Invest in systems and staff to manage your customer interaction process effectively * monitor customer accounts from the time that they are opened * make sure your process keeps pace with any increase in demand – through growth, mergers or other internal changes. * train your staff to know their roles and responsibilities, and ensure they are supported and able to act promptly when they spot or are alerted to indicators of harm. This includes your VIP teams. * aim to minimise the risk of harm for customers, whatever time of day they play, as well as for new customers * take safer gambling seriously for all customers, including VIPs, and not let commercial considerations override customer protection. This means your VIP customers get the same level of protection as your other customers * make meaningful records of all interactions with customers. Make these records available to staff and use them to aid decision-making. This should also take place in circumstances where an interaction has been ruled out e.g. because the customer is displaying signs of agitation * even if you think your sector is “lower risk”, all forms of gambling present risks and you should understand the prevalence of gambling harms for the type of gambling products you offer and implement appropriate processes. * actively promote and encourage the use of gambling management tools to all customers, and in particular where you have carried out a customer interaction. Research (Behavioural Insights Team, 2018) has shown that reducing friction in applying a gambling management tool leads to increased numbers taking it up. [Previous page Customer interaction: formal guidance for remote gambling operators](/licensees-and-businesses/guide/customer-interaction-formal-guidance-for-remote-gambling-operators) [Next page Understanding the impact of gambling harm](/licensees-and-businesses/guide/page/understanding-the-impact-of-gambling-harm) --- Last updated: 15 September 2022 Show updates to this content * Information in the callout at the beginning of the guidance page has been updated.

1722

Understanding the impact of gambling harm

https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/page/understanding-the-impact-of-gambling-harm

> This formal guidance for remote gambling operators is not current and from 12 September 2022 operators are no longer required to take it into account. It was published in July 2019 and remained in effect from 31 October 2019 to 11 September 2022. > Following our consultation on customer interaction, Social Responsibility Code Provision 3.4.3 for remote gambling operators has been introduced and the majority of requirements are in effect from 12 September 2022. We issued this [update on the regulatory requirements and status of formal guidance regarding customer interaction for remote gambling operators](/news/article/new-remote-customer-interaction-requirements-and-guidance-update) . The [guidance issued in June 2022 under Social Responsibility Code Provision 3.4.3](/guidance/customer-interaction-guidance-for-remote-gambling-licensees-formal-guidance) is not in effect and is subject to further consultation. Operators are not required to take it into account. > > In 2018, the Gambling Commission [published research (Wardle et al 2018)](/news/article/new-report-takes-significant-step-forward-in-measuring-the-impact-of) on understanding the full range of gambling harms and the impact this can have on society. This research defined gambling harms as ‘the adverse impacts from gambling on the health and wellbeing of individuals, families, communities and society-. This can include loss of employment, debt and crime – gambling harms can also have detrimental impacts on physical and mental health and relationships, and at its worst, gambling can contribute to loss of life through suicide. Gambling harms cannot be solely measured in terms of finance and resources. This is why we expect you to use a range of indicators in order to identify customers who may be experiencing harms. [Previous page Identifying the right customers](/licensees-and-businesses/guide/page/identifying-the-right-customers) [Next page Using the right indicators for your business](/licensees-and-businesses/guide/page/using-the-right-indicators-for-your-business) --- Last updated: 15 September 2022 Show updates to this content * Information in the callout at the beginning of the guidance page has been updated.

1723

Using the right indicators for your business

https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/page/using-the-right-indicators-for-your-business

> This formal guidance for remote gambling operators is not current and from 12 September 2022 operators are no longer required to take it into account. It was published in July 2019 and remained in effect from 31 October 2019 to 11 September 2022. > Following our consultation on customer interaction, Social Responsibility Code Provision 3.4.3 for remote gambling operators has been introduced and the majority of requirements are in effect from 12 September 2022. We issued this [update on the regulatory requirements and status of formal guidance regarding customer interaction for remote gambling operators](/news/article/new-remote-customer-interaction-requirements-and-guidance-update) . The [guidance issued in June 2022 under Social Responsibility Code Provision 3.4.3](/guidance/customer-interaction-guidance-for-remote-gambling-licensees-formal-guidance) is not in effect and is subject to further consultation. Operators are not required to take it into account. > > Change compared with previous gambling activity is a general trigger for customer interaction. Building up your knowledge of your customers is key to helping you spot changes in their behaviour. You should use a range of indicators based on research, experience and shared practice. The PWC remote gambling research (2017) identified some account and play indicators, but they are not a definitive list. Your list should include the following. ### Time and spend indicators Amount and frequency of time and deposits, time of day (according to research (PWC 2017), a higher percentage of overnight gamblers were found to be problem gamblers, than during other times of day), increasing length of sessions or escalation in deposit levels, large losses. ### Account indicators Cancelled withdrawals, failed deposits, multiple or more expensive payment methods, pre-loaded cards and e-wallets which could indicate gambling with money the customer does not have. ### Use of gambling management tools Changing deposit limits, trying to ‘switch off- the reverse withdrawal option to prevent re-staking prior to withdrawal, previous self-exclusions, frequent or repeated use of the time out facility or previous customer interactions. ### Customer-led contact Information or hints from customers, frequent complaints about not winning, requests for bonuses following losses, or talking about the negative impacts of their gambling. ### Play indicators chasing losses, erratic betting patterns, gambling on higher risk products or unusual markets or outcomes on which the customer is unlikely to have been able to make an informed choice. People who bet in-play may place a higher number of bets in a shorter time period than people who bet in other ways, as [in-play betting](/licensees-and-businesses/guide/in-play-or-in-running-betting) offers more opportunities to bet. Some studies have shown that placing a high number of in-play bets can be an indication that a customer is at an increased risk of harm from gambling. ### A ‘big win- or a windfall Research (Parke and Parke 2017) shows high staking following a win could hide or even lead to harmful behaviour. Suddenly having more money than usual can lead to increasing staking, which can lead to harms not associated with wealth or resources. [Previous page Understanding the impact of gambling harm](/licensees-and-businesses/guide/page/understanding-the-impact-of-gambling-harm) [Next page Affordability and customer-s personal circumstances](/licensees-and-businesses/guide/page/affordability-and-customers-personal-circumstances) --- Last updated: 15 September 2022 Show updates to this content * Information in the callout at the beginning of the guidance page has been updated.

1724

Affordability and customer-s personal circumstances

https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/page/affordability-and-customers-personal-circumstances

> This formal guidance for remote gambling operators is not current and from 12 September 2022 operators are no longer required to take it into account. It was published in July 2019 and remained in effect from 31 October 2019 to 11 September 2022. > Following our consultation on customer interaction, Social Responsibility Code Provision 3.4.3 for remote gambling operators has been introduced and the majority of requirements are in effect from 12 September 2022. We issued this [update on the regulatory requirements and status of formal guidance regarding customer interaction for remote gambling operators](/news/article/new-remote-customer-interaction-requirements-and-guidance-update) . The [guidance issued in June 2022 under Social Responsibility Code Provision 3.4.3](/guidance/customer-interaction-guidance-for-remote-gambling-licensees-formal-guidance) is not in effect and is subject to further consultation. Operators are not required to take it into account. > > Historically, gambling operators have not systematically considered customer affordability when developing their customer interaction policies. Many have used deposit or loss thresholds as a main or sole prompt for a customer interaction, but these have often been set at levels that were inappropriately high, in comparison to the average amount of money that the majority of people have available to spend on leisure activities. This has led to a number of examples of customers spending more than they could afford, and this not being identified sufficiently early, as seen in much of the Commission-s compliance and enforcement casework since 2017. Operators should aim to identify those experiencing or at risk of harm and intervene to try to reduce harm at the earliest opportunity. Reliance on deposit or loss thresholds that are set too high will result in failing to detect some customers who may be experiencing significant harms associated with their gambling. It is therefore imperative that threshold levels are set appropriately. Open source data exists which can help operators assess affordability for their GB customer base and improve their risk assessment for customer interactions. Thresholds should be realistic, based on average available income for your customers. This should include the [Office of National Statistics publications (opens in a new tab)](https://www.ons.gov.uk/peoplepopulationandcommunity/personalandhouseholdfinances) on levels of household income. In considering these thresholds, you should be aware of the difference between ‘disposable income- and ‘discretionary income- which refers to the amount left after living costs are taken into account, but it does still include many other unavoidable costs. Most people would consider it harmful if they were spending a significant amount of their discretionary income on gambling. [Previous page Using the right indicators for your business](/licensees-and-businesses/guide/page/using-the-right-indicators-for-your-business) [Next page Vulnerability](/licensees-and-businesses/guide/page/vulnerability) --- Last updated: 15 September 2022 Show updates to this content * Information in the callout at the beginning of the guidance page has been updated.

1725

Vulnerability

https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/page/vulnerability

> This formal guidance for remote gambling operators is not current and from 12 September 2022 operators are no longer required to take it into account. It was published in July 2019 and remained in effect from 31 October 2019 to 11 September 2022. > Following our consultation on customer interaction, Social Responsibility Code Provision 3.4.3 for remote gambling operators has been introduced and the majority of requirements are in effect from 12 September 2022. We issued this [update on the regulatory requirements and status of formal guidance regarding customer interaction for remote gambling operators](/news/article/new-remote-customer-interaction-requirements-and-guidance-update) . The [guidance issued in June 2022 under Social Responsibility Code Provision 3.4.3](/guidance/customer-interaction-guidance-for-remote-gambling-licensees-formal-guidance) is not in effect and is subject to further consultation. Operators are not required to take it into account. > > Life events or changes to an individual customer-s circumstances may mean that a person becomes more or less vulnerable to experiencing gambling harms. Those circumstances could include bereavement, loss of income or other factors, as follows. It will not always be obvious or clear to an operator when such events have occurred, but knowing your customers, and ensuring staff ask questions when there are potential signs of vulnerability, will help to determine whether those individual circumstances present an increased risk. As part of ‘know your customer- and developing customer interaction policies and procedures, operators should consider the factors that might make an individual more vulnerable to experiencing gambling related harm. Factors include: * **personal and demographic** - if the individual is experiencing poor physical or mental health, physical or cognitive impairment, suffering side effects from a brain injury or medication or has an addiction * **situational** - if the individual is experiencing financial difficulties, is homeless, is suffering from domestic or financial abuse, has caring responsibilities, experiences a life change or sudden change in circumstances * **behavioural** - if an individual has a higher than standard level of trust or high appetite for risk * **market-related** - if an individual is engaged in an activity which is highly complex; that they have a lack of knowledge and/or experience of the market * **access** - if an individual has difficulty accessing information because of poor literacy or numeracy skills, knowledge, dyslexia. We have seen examples through our casework of customers who should have received some interaction but did not, including customers who were particularly vulnerable, and more susceptible to experiencing gambling harms. [Previous page Affordability and customer-s personal circumstances](/licensees-and-businesses/guide/page/affordability-and-customers-personal-circumstances) [Next page Spotting harmful gambling](/licensees-and-businesses/guide/page/spotting-harmful-gambling) --- Last updated: 15 September 2022 Show updates to this content * Information in the callout at the beginning of the guidance page has been updated.

1726

Spotting harmful gambling

https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/page/spotting-harmful-gambling

> This formal guidance for remote gambling operators is not current and from 12 September 2022 operators are no longer required to take it into account. It was published in July 2019 and remained in effect from 31 October 2019 to 11 September 2022. > Following our consultation on customer interaction, Social Responsibility Code Provision 3.4.3 for remote gambling operators has been introduced and the majority of requirements are in effect from 12 September 2022. We issued this [update on the regulatory requirements and status of formal guidance regarding customer interaction for remote gambling operators](/news/article/new-remote-customer-interaction-requirements-and-guidance-update) . The [guidance issued in June 2022 under Social Responsibility Code Provision 3.4.3](/guidance/customer-interaction-guidance-for-remote-gambling-licensees-formal-guidance) is not in effect and is subject to further consultation. Operators are not required to take it into account. > > How you monitor activity depends on your business. Larger operators with more active customers will need comprehensive systems, which could include a mix of automated and manual processes, and should draw on all available sources of data to give a comprehensive picture of the customer-s gambling. Options for spotting harmful gambling include: * in-play real time monitoring to identify harmful behaviour as it occurs. * daily reports on activity. * chatroom monitoring and moderation. The right information can mean better and quicker decisions. You should aim to integrate your systems so that staff have a more complete picture of the customer-s activity, and this includes records of previous customer interactions. Unmonitored overnight gambling carries an increased risk. Remote gambling research (PWC 2017) found that the highest risk customers were much more likely to gamble overnight than non-problem gamblers. Some operators have full 24-hour dedicated safer gambling monitoring and support, so that customers have the same level of protection overnight as during the day. Another option could be more training and extra responsibilities for customer service staff or chat hosts to provide that support. Because VIP customers can also experience gambling harms, it is good practice to carry out a safer gambling check when upgrading a customer to VIP status, and to keep this under review. You should also use these opportunities to carry out checks for Anti-Money Laundering (AML). This could also help you to support customers who have had major wins.

1727

Spotting harmful gambling

The role of staff

https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/page/spotting-harmful-gambling

It is important that all staff receive training so that they are aware of the signs that could indicate that a customer may be experiencing harms associated with gambling. This is not an exhaustive list, but you should ensure that: * staff are trained to identify the signs of harm and are able to refer back to documents that include the types of behaviour that may trigger customer interaction at an appropriate moment. Staff should know how to escalate a situation if they are unsure or require support. * staff understand how indicators of harm could be displayed differently in VIP or ‘high value- customers, and know how to spot the signs. * as a minimum, staff receive training at induction as well as refresher training.

1728

Spotting harmful gambling

Identify: questions to consider

https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/page/spotting-harmful-gambling

These include: * Are you curious about your customers? * Are your indicators relevant to your products and customers? * Do you rely too much on financial indicators like deposit levels or losses? * Do you consider all types of vulnerability? * How do you decide the right level of your thresholds? Do you set your thresholds based on the staff you have to manage the workload, or do you think about what is right for your customers? * Do you take into account all relevant information, and act quickly? * Do all appropriate staff have access to customer interaction records? * How could you assess the risks around new customers? What can you find out about your customers? What protections could you put in place until you know enough about your customers? * Can your monitoring process keep up with demand? * Do you offer the same level of protection for all your customers, no matter how long they have been a customer, what time of day they play, or whether they are VIPs? * Do you track customers across your different platforms and do enough to spot multiple customer accounts? * Is staff training on customer interaction meaningful and engaging? [Previous page Vulnerability](/licensees-and-businesses/guide/page/vulnerability) [Next page Interacting with the customer](/licensees-and-businesses/guide/page/interacting-with-the-customer) --- Last updated: 15 September 2022 Show updates to this content * Information in the callout at the beginning of the guidance page has been updated.

1729

Interacting with the customer

https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/page/interacting-with-the-customer

> This formal guidance for remote gambling operators is not current and from 12 September 2022 operators are no longer required to take it into account. It was published in July 2019 and remained in effect from 31 October 2019 to 11 September 2022. > Following our consultation on customer interaction, Social Responsibility Code Provision 3.4.3 for remote gambling operators has been introduced and the majority of requirements are in effect from 12 September 2022. We issued this [update on the regulatory requirements and status of formal guidance regarding customer interaction for remote gambling operators](/news/article/new-remote-customer-interaction-requirements-and-guidance-update) . The [guidance issued in June 2022 under Social Responsibility Code Provision 3.4.3](/guidance/customer-interaction-guidance-for-remote-gambling-licensees-formal-guidance) is not in effect and is subject to further consultation. Operators are not required to take it into account. > > When you are concerned that a customer may be experiencing harm, acting early and quickly could help stop or prevent the harm worsening. For some customers, making them aware of why you are concerned may be enough to prompt them to think and make a change. Some customers will need more support or advice. Your interactions should have an outcome. Knowing what impact your interaction has had will help you support the customer and help to keep improving your approach. To achieve this, it is vital to keep good records and make them available to staff to inform decisions. ### Interact We expect you to: * be curious, and if you spot behaviour or vulnerabilities that could indicate harm, to act on it. * make all reasonable efforts to make contact and interact with a customer, and find out what impact your interaction had. * you should choose the type of interaction based on the extent of the potential harm – from automated responses to human contact – and adapt your messaging to try to get the best outcome. You should trial and evaluate different approaches to achieve this. **Importantly, this may include refusing service or ending the business relationship.** * think about what information you should give the customer, such as describing the type of behaviour they display or practical help or support where appropriate. There are a number of ways for you to interact with your customers, including email, telephone calls, live chat or pop-up messages. The best way may depend on the circumstances: * what you need to know from the customer, and what you already know about them. * what information you want to give to the customer. * how urgent it is to make contact. * how many times you have already interacted with the customer. * the outcome you want to achieve. ### A customer interaction has three parts These are: 1. Observation – behaviour or activity you have spotted or something the customer tells you. 2. Action – contact to prompt the customer to think about their gambling, for you to find out more, and an opportunity for you to offer information or support. 3. Outcome – what you or the customer did next. In some cases, you may need to monitor the customer-s gambling to spot any change which may prompt further action. [Previous page Spotting harmful gambling](/licensees-and-businesses/guide/page/spotting-harmful-gambling) [Next page Tailoring messages for your customers](/licensees-and-businesses/guide/page/tailoring-messages-for-your-customers) --- Last updated: 15 September 2022 Show updates to this content * Information in the callout at the beginning of the guidance page has been updated.

1730

Tailoring messages for your customers

https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/page/tailoring-messages-for-your-customers

> This formal guidance for remote gambling operators is not current and from 12 September 2022 operators are no longer required to take it into account. It was published in July 2019 and remained in effect from 31 October 2019 to 11 September 2022. > Following our consultation on customer interaction, Social Responsibility Code Provision 3.4.3 for remote gambling operators has been introduced and the majority of requirements are in effect from 12 September 2022. We issued this [update on the regulatory requirements and status of formal guidance regarding customer interaction for remote gambling operators](/news/article/new-remote-customer-interaction-requirements-and-guidance-update) . The [guidance issued in June 2022 under Social Responsibility Code Provision 3.4.3](/guidance/customer-interaction-guidance-for-remote-gambling-licensees-formal-guidance) is not in effect and is subject to further consultation. Operators are not required to take it into account. > > You may already target your marketing messages to different customers. You could also use insight about your customers, such as how the customer prefers to contact you, to decide the best way to interact with them about their gambling. Industry-led research [(Revealing Reality 2017)(PDF opens in new tab)](https://about.gambleaware.org/media/1581/revealing-reality-igrg-report-for-gambleaware.pdf) shows that messages that get customers to think and make their own decisions based on the information they are given can be more effective than messages that seem to be ‘nagging-. Research by [Auer and Griffiths 2015 (opens in new tab)](https://www.frontiersin.org/articles/10.3389/fpsyg.2015.00339/full) also shows that personalising feedback can also improve the impact it has on customers. You should test different types of messaging to see what works best. [Previous page Interacting with the customer](/licensees-and-businesses/guide/page/interacting-with-the-customer) [Next page Offering help and support](/licensees-and-businesses/guide/page/offering-help-and-support) --- Last updated: 15 September 2022 Show updates to this content * Information in the callout at the beginning of the guidance page has been updated.

1731

Offering help and support

https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/page/offering-help-and-support

> This formal guidance for remote gambling operators is not current and from 12 September 2022 operators are no longer required to take it into account. It was published in July 2019 and remained in effect from 31 October 2019 to 11 September 2022. > Following our consultation on customer interaction, Social Responsibility Code Provision 3.4.3 for remote gambling operators has been introduced and the majority of requirements are in effect from 12 September 2022. We issued this [update on the regulatory requirements and status of formal guidance regarding customer interaction for remote gambling operators](/news/article/new-remote-customer-interaction-requirements-and-guidance-update) . The [guidance issued in June 2022 under Social Responsibility Code Provision 3.4.3](/guidance/customer-interaction-guidance-for-remote-gambling-licensees-formal-guidance) is not in effect and is subject to further consultation. Operators are not required to take it into account. > > Encourage customers to think about their gambling. Their responses will help you work out the right kind of help and support to offer. It is good practice to suspend direct marketing to customers who show signs of harm so that you do not actively encourage them to keep gambling while you consider them to be experiencing or at risk of harm. If you have difficulty making contact with a customer, you could suspend account access until you are able to interact with them. A self-assessment questionnaire can help customers think about their own gambling. Their shared responses, alongside their gambling behaviour, can help both you and the customer work out the right kind of help and support they may need. You will need to direct some customers to information about safer gambling, and/or suggest suitable gambling management tools. You might need to signpost them to sources of help and specialist support from organisations who deal with advice and treatment for problem gambling. You will need to interact with some customers a number of times. Your records of previous interactions with customers will help you decide how to provide the right help and support. Feedback from consumers shows that they often respond better to being informed about their behaviour and why, rather than being “told” what to do. But for some customers, and particularly if the behaviour continues to cause concern, you may need to take a more proactive approach. In some cases, you may need to take action for the customer, such as setting limits or refusing service by closing their account.

1732

Offering help and support

The role of staff

https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/page/offering-help-and-support

You should ensure that your staff: * understand the types of interaction that could take place and how to interact appropriately e.g. only need a brief intervention may be needed. * know the type of help or support to offer, such as information, signposting customers to specialist support or the gambling management tools which are available. These may be the minimum required under the LCCP or the Remote Technical Standards, or tools you offer which go beyond minimum requirements. * know the circumstances and process for refusing service to customers, such as by applying limits or closing an account. * understand their respective responsibilities and who is designated to carry out customer interactions, if only certain staff members are authorised to interact. Whilst training on the legislative framework is important, staff also need to be trained on the skills and techniques they need to help them carry out customer interactions, including what to do if a customer becomes distressed. [Previous page Tailoring messages for your customers](/licensees-and-businesses/guide/page/tailoring-messages-for-your-customers) [Next page Keeping records](/licensees-and-businesses/guide/page/keeping-records) --- Last updated: 15 September 2022 Show updates to this content * Information in the callout at the beginning of the guidance page has been updated.

1733

Keeping records

https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/page/keeping-records

> This formal guidance for remote gambling operators is not current and from 12 September 2022 operators are no longer required to take it into account. It was published in July 2019 and remained in effect from 31 October 2019 to 11 September 2022. > Following our consultation on customer interaction, Social Responsibility Code Provision 3.4.3 for remote gambling operators has been introduced and the majority of requirements are in effect from 12 September 2022. We issued this [update on the regulatory requirements and status of formal guidance regarding customer interaction for remote gambling operators](/news/article/new-remote-customer-interaction-requirements-and-guidance-update) . The [guidance issued in June 2022 under Social Responsibility Code Provision 3.4.3](/guidance/customer-interaction-guidance-for-remote-gambling-licensees-formal-guidance) is not in effect and is subject to further consultation. Operators are not required to take it into account. > > Good record keeping allows you to demonstrate when and why you have interacted with customers, and helps with ongoing monitoring of customers. You should: * keep records of all customer interactions, including where an interaction didn-t take place, the reasons for this, and how it was followed up * make use of and record all relevant sources of information to guide and deliver effective customer interactions, including your records of previous interactions. Good records should include: * the behaviour or activity before the interaction. * the change in behaviour or prompt for the interaction. * how you interacted and what was said or done, for example advice or suggestions to help the customer manage their gambling, or to take a break from their gambling, and * what happened next. You should also record situations where an interaction was prompted but did not take place, and how you followed that up. In some cases, you will need to monitor the customer-s gambling to spot behaviours which could indicate further harm.

1734

Keeping records

Interact: questions to consider

https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/page/keeping-records

* Where concerns arise, are you able to intervene early and engage with a customer? * How do you decide the best way of interacting with a customer? Do you use different methods for different groups of customers? * Do you tailor your method and message depending on the extent of the harm? * Do you know if the customer received and acted on the information you gave? * Have you allocated sufficient resources to be able to interact with customers early and effectively when you have concerns? [Previous page Offering help and support](/licensees-and-businesses/guide/page/offering-help-and-support) [Next page Evaluate](/licensees-and-businesses/guide/page/evaluate) --- Last updated: 15 September 2022 Show updates to this content * Information in the callout at the beginning of the guidance page has been updated.

1735

Evaluate

https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/page/evaluate

> This formal guidance for remote gambling operators is not current and from 12 September 2022 operators are no longer required to take it into account. It was published in July 2019 and remained in effect from 31 October 2019 to 11 September 2022. > Following our consultation on customer interaction, Social Responsibility Code Provision 3.4.3 for remote gambling operators has been introduced and the majority of requirements are in effect from 12 September 2022. We issued this [update on the regulatory requirements and status of formal guidance regarding customer interaction for remote gambling operators](/news/article/new-remote-customer-interaction-requirements-and-guidance-update) . The [guidance issued in June 2022 under Social Responsibility Code Provision 3.4.3](/guidance/customer-interaction-guidance-for-remote-gambling-licensees-formal-guidance) is not in effect and is subject to further consultation. Operators are not required to take it into account. > > By evaluate, we mean to understand impact and effectiveness in two ways: * did an individual customer interaction have a positive outcome for the customer, and * does your overall approach to customer interaction work? To help with the latter, the Advisory Board for Safer Gambling published an evaluation protocol in 2016 for the industry to use when designing evaluations. > Find out more about the [National Strategy to Reduce Gambling Harms](/about-us/reducing-gambling-harms) , including the [evaluation protocol](/manual/national-strategy-to-reduce-gambling-harms/evaluation-gambling-commission-actions) and further research on gambling-related harms. > > ### Evaluate We expect you to: * Understand the impact of individual interactions on a consumer-s behaviour and whether, or what, further action is needed. * Evaluate the effectiveness of your approach by trialling and measuring impact. * Embed lessons learned and best practice across the business and collaborate to share across the industry. [Previous page Keeping records](/licensees-and-businesses/guide/page/keeping-records) [Next page Understanding the impact of individual interactions](/licensees-and-businesses/guide/page/understanding-the-impact-of-individual-interactions) --- Last updated: 15 September 2022 Show updates to this content * Information in the callout at the beginning of the guidance page has been updated.

1736

Understanding the impact of individual interactions

https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/page/understanding-the-impact-of-individual-interactions

> This formal guidance for remote gambling operators is not current and from 12 September 2022 operators are no longer required to take it into account. It was published in July 2019 and remained in effect from 31 October 2019 to 11 September 2022. > Following our consultation on customer interaction, Social Responsibility Code Provision 3.4.3 for remote gambling operators has been introduced and the majority of requirements are in effect from 12 September 2022. We issued this [update on the regulatory requirements and status of formal guidance regarding customer interaction for remote gambling operators](/news/article/new-remote-customer-interaction-requirements-and-guidance-update) . The [guidance issued in June 2022 under Social Responsibility Code Provision 3.4.3](/guidance/customer-interaction-guidance-for-remote-gambling-licensees-formal-guidance) is not in effect and is subject to further consultation. Operators are not required to take it into account. > > In this context, by impact we mean a change in the customer-s **gambling activity** which could be attributed to the interaction. An important part of this is whether the customer has understood the information or advice you gave. Not every customer who receives an interaction will require active follow up, but many will. In these cases, follow up activity should be proportionate to the severity or extent of the harm being displayed. This approach will help you target your resources where they are most needed. Understanding the impact of the interaction on the customer includes being able to look at and compare: * the behaviour before the interaction. * the change in behaviour or prompt for the interaction * how you interacted and what was said or done, and * what happened next. Some ways to work out that impact include: * Did the customer start using gambling management tools; independently or following your advice? * If you are tracking links from emails, did the customer click through to safer gambling information? * Was there a positive change in behaviour? Did the customer-s gambling seem to change after the interaction? * You could also follow up and ask the customer whether they found the interaction helpful or not. * Is there a need for further or follow up action? You may already quality assure individual customer interactions by spot- checking chat records and emails. As well as checking that customers are getting the right support, this can also identify staff development needs and highlight good practice that you can share across your business and across the industry. [Previous page Evaluate](/licensees-and-businesses/guide/page/evaluate) [Next page Evaluating the effectiveness of the approach](/licensees-and-businesses/guide/page/evaluating-the-effectiveness-of-the-approach) --- Last updated: 15 September 2022 Show updates to this content * Information in the callout at the beginning of the guidance page has been updated.

1737

Evaluating the effectiveness of the approach

https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/page/evaluating-the-effectiveness-of-the-approach

> This formal guidance for remote gambling operators is not current and from 12 September 2022 operators are no longer required to take it into account. It was published in July 2019 and remained in effect from 31 October 2019 to 11 September 2022. > Following our consultation on customer interaction, Social Responsibility Code Provision 3.4.3 for remote gambling operators has been introduced and the majority of requirements are in effect from 12 September 2022. We issued this [update on the regulatory requirements and status of formal guidance regarding customer interaction for remote gambling operators](/news/article/new-remote-customer-interaction-requirements-and-guidance-update) . The [guidance issued in June 2022 under Social Responsibility Code Provision 3.4.3](/guidance/customer-interaction-guidance-for-remote-gambling-licensees-formal-guidance) is not in effect and is subject to further consultation. Operators are not required to take it into account. > > Records of interactions provide useful evidence of what types of indicators, methods of interacting and options for support work well for customers. They will help to inform an evaluation of the effectiveness of your overall approach to customer interaction. Good evaluation helps you to understand which aspects of your approach are the most effective at identifying the right customers, and the types of tools or support that work well to help customers manage their gambling in a way that works for them. The following measures could help to work out whether your approach is working well: * gambling management tools – increased take up and more customers sticking within their limits. * customer retention. * reduction in complaints. * numbers of customer interactions appear to be in line with the prevalence of gambling harm for the product, as follows. Statistics which estimate the numbers of problem and ‘moderate risk- gamblers are published regularly, based on the combined health surveys in England, Scotland and Wales (NatCen 2018). This data is broken down to gambling activity type, and by region, and can help you to work out the percentage of your customers you should be interacting with. When looking at the potential percentage of your customers who may be experiencing harm, remember to consider the percentage of gamblers participating in that activity and not the percentage of the adult population. Currently the only industry-wide quantitative measure of identifying and interacting with customers who may be experiencing harms associated with gambling is data on the numbers of customers who received an interaction, submitted to the Commission as part of [regulatory returns](/guidance/regulatory-returns-guidance) . We have clarified the definitions in regulatory returns to offer guidance on what should be included in a customer interaction (incident) log and make clearer what should be recorded. Your log should include as a minimum: * the identity or other identifier of the customer involved * the behaviour or activity that prompted the interaction * the advice or support given, and * the outcome of the interaction. Keeping your policies and procedures under review and up to date by taking into account research and industry best practice will help you to identify customers you should be interacting with, which will help you target your resources where they are most needed, in ways which may lead to better outcomes. You should also review your internal controls following the publication of a regulatory settlement, to address any similar weaknesses which could exist in your own processes.

1738

Evaluating the effectiveness of the approach

The role of staff

https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/page/evaluating-the-effectiveness-of-the-approach

Your staff have an important role to play to understand whether your approach works. As a minimum, you should: * ensure that staff make records of all customer interactions and use them to aid decision making. Such records should be used for evaluation purposes, for example dip sampling for quality assurance purposes or to assess whether a customer changed their behaviour as the result of an interaction * train staff to recognise when follow-up activity to an interaction is required * ensure that staff use customer interaction records as a decision- making tool * ensure that staff are properly supported in carrying out effective interventions.

1739

Evaluating the effectiveness of the approach

Evaluate: questions to consider

https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/page/evaluating-the-effectiveness-of-the-approach

* Do you know how many of your customers may be experiencing some level of harm associated with gambling? * How do you know you are delivering positive outcomes for your customers? * How could you improve on your policy and procedures? How do you plan to make improvements over time? * How could you share your good practice with the industry? [Previous page Understanding the impact of individual interactions](/licensees-and-businesses/guide/page/understanding-the-impact-of-individual-interactions) --- Last updated: 15 September 2022 Show updates to this content * Information in the callout at the beginning of the guidance page has been updated.

1740

Minimising gambling-related harm

https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/page/minimising-gambling-related-harm

We encourage operators to consider how they can gather data both before and after the implementation of any measure so that they can demonstrate the impact of control measures.

1741

Minimising gambling-related harm

Considerations for operators

https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/page/minimising-gambling-related-harm

Research has shown that individuals can frequently gamble more money than they intended during gambling sessions. This leads to them making impulsive decisions that override their initial intentions to allocate a set amount of money to gamble with. Easy access to additional funds in gambling premises can therefore be a risk factor for problem gambling. [Key issues in product-based harm minimisation (opens in a new tab)](https://www.greo.ca/Modules/EvidenceCentre/Details/key-issues-in-product-based-harm-minimisation-examining-theory-evidence-and-pol) by Parke A, Parke J and Blaszczynski, A, was published in December 2016, and is a summary of research evidence. Research also shows that non-cash payment methods in gambling can lead to consumers over-spending, as such methods require less thinking about the actual cost and affordability implications of a transaction compared to cash payments. It is for operators to consider how player protection and empowerment can be most effectively delivered in practice. They are best placed to assess which measures are: * most effective in mitigating the risk of customers spending more on gambling than they might be able to afford * which are most effective in enabling customers to retain control over their own gambling spend. Operators may need to take account of specific risks such as the layout of their premises or vulnerabilities for particular customers. As part of their assessments on how they can best mitigate harm, operators must consider how they can facilitate the following. While there is no evidence to suggest what the ideal duration of a break should be, wherever possible the customer should at least be required to cease gambling at, and physically leave, the machine, terminal or table at which they are situated. This provides some time away from the gambling facilities before they are able to access and use new funds. This is consistent with the mandatory conditions attached to all premises licences that any ATM is located in a place that requires customers to cease gambling and leave the gambling product in order to use it. In any circumstance where customers might be able to access new gambling funds with only a limited or no physical break from the gambling product (for example, where customers might be able to use a debit card to replenish an app-based digital gambling ‘wallet-), the operator must ensure that customers are otherwise provided a break from or an interruption in gambling before those funds can be used. ### Customers should be required to take a break from gambling before they access and use new funds to continue gambling The purpose of the break or interruption in play is to reduce the risk of harm to players that could arise from them losing track of the time and money they have spent gambling. By interrupting their state of dissociation, a break in play can give customers an opportunity to evaluate their own gambling behaviours, and could therefore facilitate better control (see [Operator-based approaches to harm minimisation in gambling (opens in a new tab)](https://www.begambleaware.org/media/1177/obhm-report-final-version.pdf ) , by Parke A, Parke J, Blaszczynski, A and Rigbye J, published by Gamble Aware in 2014). A break or interruption in play could therefore involve, for example, slowing the transactional process and providing delays before new funds are made available to the player for use; perhaps combined with informative messaging, so as to support the player-s control and awareness of their gambling spend. Operators should use these new opportunities to support innovation in the protection and empowerment of consumers. For example, cashless payment technology may assist operators in tracking their customers- play, allowing them to collect better data on their customers- gambling behaviour and therefore helping to inform an assessment of those who may be at risk of gambling-related harm. The new technologies may also assist in the provision of tailored responsible gambling information to customers, including transactional information on the sums of money they have spent or withdrawn; or the development of player-led controls to enable better self-management of the customer-s gambling (eg allowing customers to set their own spend or withdrawal limits). [Previous page Cashless payment technologies in gambling premises](/licensees-and-businesses/guide/cashless-payment-technologies-in-gambling-premises) [Next page Licence Conditions and Codes of Practice: cashless payment](/licensees-and-businesses/guide/page/licence-conditions-and-codes-of-practice-in-cashless-payment-technologies) --- Last updated: 28 November 2022 Show updates to this content Following an audit the link to 'Key issues in product-based harm minimisation' has been updated.

1742

Licence Conditions and Codes of Practice: cashless payment

https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/page/licence-conditions-and-codes-of-practice-in-cashless-payment-technologies

There are certain conditions and codes of practice that must be adhered to when providing cashless payment facilities. These include, for example, the need to implement effective policies and procedures for minimising certain risks to the licensing objectives; and provisions that limit the circumstances in which credit can be provided, or prevent credit cards being accepted (and where the Gambling Act does not otherwise prohibit or restrict any such facility). ## Operators should refer to the LCCP for full details of the following relevant requirements: [The Gaming Machines (Circumstances of Use) Regulations 2007 (opens in a new tab)](https://www.legislation.gov.uk/uksi/2007/2319/contents/made) provide prohibitions and restrictions on the use of debit and credit cards for payments to play machines, which are straightforward safeguards intended to prevent consumers from gambling more than they can afford via a card. ## Specific matters in relation to gaming machine payments

1743

Licence Conditions and Codes of Practice: cashless payment

Operators should refer to the LCCP for full details of the following relevant requirements:

https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/page/licence-conditions-and-codes-of-practice-in-cashless-payment-technologies

* [Licence condition 5.1 – cash and cash equivalents, payment methods and services](/licensees-and-businesses/lccp/condition/5-1-1-cash-and-cash-equivalents) * [Licence condition 6.1 – provision of credit by licensees and the use of credit cards](/licensees-and-businesses/lccp/condition/6-1-1-provision-of-credit) * [Social responsibility code provision 3.7 – provision of credit](/licensees-and-businesses/lccp/condition/3-7-1-provision-of-credit)

1744

Licence Conditions and Codes of Practice: cashless payment

Specific matters in relation to gaming machine payments

https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/page/licence-conditions-and-codes-of-practice-in-cashless-payment-technologies

Our view is that card payments that originate from contactless mobile payment systems such as Apple Pay, Android Pay or Samsung Pay should be regarded as the same as payments to use a gaming machine by means of a card itself. This is because the device used for such types of payment (eg a smartphone or watch) is essentially just a medium by which a contactless card payment is made (ie the debit card sat behind the payment system is charged directly and the customer-s bank account is debited; the same as for any payment where the debit card itself is used). Both contactless card and mobile payment system transactions can be completed quickly, and so the risks to the consumer are largely identical. The regulations also prescribe limits as to the amounts an individual can deposit onto a gaming machine in any single action, and separately the (non-refundable) amount a player can commit to play the machine. These measures were designed to ensure consumers make regular decisions as to how much money they wish to commit to play a machine, and they must be observed regardless of the means of payment. That is, whether the customer has inserted cash into the machine, or whether they have transferred funds from a debit card via indirect means, a TITO (ticket-in, ticket-out) method or an operator-provided app-based digital wallet, a customer must only be able to deposit and commit funds to the gaming machine-s meters in accordance with these limits. [Previous page Minimising gambling-related harm](/licensees-and-businesses/guide/page/minimising-gambling-related-harm) [Next page Checklist of considerations](/licensees-and-businesses/guide/page/checklist-of-considerations) --- Last updated: 7 June 2021 Show updates to this content No changes to show.

1745

Licence conditions and codes of practice (LCCP)

https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/page/licence-conditions-and-codes-of-practice-lccp

Our [LCCP](/licensees-and-businesses/lccp/online) is the rulebook that sets out the measures that you must take and other aspects that we think are good practice. Use the LCCP as a starting point in order to run your business and build on these provisions, to ensure that you put your customers at the heart of your business. [Previous page Compliance with safer gambling requirements](/licensees-and-businesses/guide/page/compliance-with-safer-gambling-requirements) [Next page Working together to improve standards of safer gambling](/licensees-and-businesses/guide/page/working-together-to-improve-standards-of-safer-gambling) --- Last updated: 9 June 2021 Show updates to this content No changes to show.

1746

Working together to improve standards of safer gambling

https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/page/working-together-to-improve-standards-of-safer-gambling

We work with a number of partner organisations in the area of safer gambling. [GambleAware's (opens in a new tab)](https://www.begambleaware.org/) programme of treatment, education, harm prevention and research is guided by the [National Strategy to Reduce Gambling Harms](/about-us/reducing-gambling-harms) , which is defined by the independent [Advisory Board for Safer Gambling (ABSG)](/about-us/governanceCommitteesAndBoards/advisory-board-for-safer-gambling) , and endorsed by us. We also work with industry groups responsible for raising standards in safer gambling, such as [Industry Group for Responsible Gambling (opens in a new tab)](https://bettingandgamingcouncil.com/members/igrg) . ## Our expectations [Previous page Licence conditions and codes of practice (LCCP)](/licensees-and-businesses/guide/page/licence-conditions-and-codes-of-practice-lccp) --- Last updated: 13 October 2021 Show updates to this content Reference to Senet group removed and link for Industry Group for Responsible Gambling updated.

1747

Working together to improve standards of safer gambling

Our expectations

https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/page/working-together-to-improve-standards-of-safer-gambling

“We want to see you harnessing the same innovation and tools that are used to determine customer profitability, to drive customer protection. There is perhaps no better way to demonstrate a drive to raising standards than through a genuine and public commitment to meeting your social responsibilities.” - former CEO, Sarah Harrison.

1748

5.1.11 - Direct electronic marketing consent

https://www.gamblingcommission.gov.uk/licensees-and-businesses/lccp/condition/5-1-11-direct-electronic-marketing-consent

Applies to: All licences **Social responsibility code** Compliance with these is a condition of licences; therefore any breach of them by an operator may lead the Commission to review the operator-s licence with a view to suspension, revocation or the imposition of a financial penalty and would also expose the operator to the risk of prosecution. 1. Unless expressly permitted by law consumers must not be contacted with direct electronic marketing without their informed and specific consent. Whenever a consumer is contacted the consumer must be provided with an opportunity to withdraw consent. If consent is withdrawn the licensee must, as soon as practicable, ensure the consumer is not contacted with electronic marketing thereafter unless the consumer consents again. Licensees must be able to provide evidence which establishes that consent.

1749

16.1.1 - Responsible placement of digital adverts

https://www.gamblingcommission.gov.uk/licensees-and-businesses/lccp/condition/16-1-1-responsible-placement-of-digital-adverts

Applies to: All licences 1 Licences must: - Ensure that they do not place digital advertisements on websites providing unauthorised access to copyrighted content; - take all reasonable steps to ensure that third parties with whom they contract for the provision of any aspect of their business related to the licensed activities do not place digital advertisements on websites providing unauthorised access to copyrighted content; and - ensure that the terms upon which they contract with such third parties enable them, subject to compliance with any dispute resolution provisions, to terminate the third party-s contract promptly if, in the Licensee-s reasonable opinion, the third party has been responsible for placing digital advertisements for the licensed activities on such websites.

1750

Gambling regulation and the General Data Protection Regulation (GDPR)

Introduction

https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/gambling-regulation-and-the-general-data-protection-regulation-gdpr

On 25 May 2018, there will be new data protection legislation in force, both in the UK and across the EU - the General Data Protection Regulation (GDPR). GDPR is an evolution in data protection. It demands more of organisations in terms of accountability for their use of personal data, and adds to the existing rights of individuals. It creates an onus on companies to understand the risks that they create for others, and to ensure they are mitigating those risks. But it is not a total revolution - GDPR is building on foundations which have already been in place for the last 20 years. Many of the fundamentals remain the same. Fairness, transparency, accuracy, security, data minimisation and respect for the rights of the individual whose data a business wants to process – these are all things that businesses should already be doing with data. GDPR seeks to build on those principles. The Information Commissioner-s Office (ICO) is responsible for the regulation of the legislation, and issuing guidance on it. More information on GDPR and its regulation in the UK is available on the [ICO's website (opens in a new tab)](https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/) . Some have expressed concerns to the Gambling Commission that GDPR will affect what actions they can take to tackle issues such as problem gambling, and gambling-associated crime. We take the view that GDPR is not intended to prevent operators from taking steps which are necessary in the public interest, or are necessary to comply with regulatory requirements under a gambling licence. GDPR should not be improperly used as an excuse to avoid taking steps which enable compliance with licence conditions, promote socially responsible gambling, and promote the licensing objectives. Where licensees have genuine well-founded concerns about GDPR, we are committed to working with industry to get the right outcome - one that safeguards personal data whilst also promoting the licensing objectives. Whilst this document does not constitute legal advice, it will assist gambling businesses by setting out some factors they should consider when assessing their processing of personal data. It also sets out our expectations on retention of information obtained for the purposes of fulfilling those obligations. It will remain licensees- responsibility to ensure they are legally compliant with GDPR and with our regulatory framework, and we recommend that operators obtain their own legal advice on compliance. This document may be updated from time to time in accordance with legal developments, including the finalisation of the Data Protection Bill. ## General approach of the Commission to compliance ## Personal data processing ## Data subject rights ## Other obligations ## Next steps ## Retention of data ## Specific scenarios considered ## Scenarios ## Marketing to consumers ## Footnotes ## Annex A ## Social responsibility code 3.1.1 – Socially Responsible Gambling ## Social responsibility codes 3.5.1 and 3.5.3 – Self-Exclusion ## Licence Condition 12.1.1 – Anti-Money Laundering ## Social responsibility code 3.4.1 - Problem gambling ## Licence Condition 15.1.1. – Reporting suspicion of offences etc – non-betting licences ## Licence Conditions 15.1.2 - Reporting suspicion of offences etc – betting licences ## Licence Condition 15.3.1 – Information provision ## Licence Condition 2.3.1 – Technical standards --- Last updated: 29 April 2021 Show updates to this content No changes to show.

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Gambling regulation and the General Data Protection Regulation (GDPR)

Personal data processing

https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/gambling-regulation-and-the-general-data-protection-regulation-gdpr

Processing of personal data will continue to be required in order to achieve compliance with a gambling licence. Providing facilities for gambling otherwise than in accordance with the terms and conditions of a licence is a criminal offence. It would also mean that operators- may be fined, and their licence could be revoked. We expect licensees to continue to be able to evidence that they have complied fully with their licence conditions. We have been working closely with the ICO to ensure that the way in which licensees are interpreting and implementing GDPR does not conflict with the requirements of gambling regulation [1](#1) . The ICO produced a series of blogs to bust myths about GDPR. One example of this is the myth that “data can only be processed if an organisation has explicit consent to do so”. The rules around consent only apply if a business is relying on consent as its basis to process personal data. Consent is one way to comply with GDPR, but the new law provides five other ways of processing data that may be more appropriate than consent. For processing to be lawful under GDPR, you simply need to identify at least one lawful basis before you start (though more than one basis may potentially apply). So in common with the previous legislation, there has been a recognition that consent will not always be the appropriate basis for data processing. For example, it is likely to be acceptable for personal data to be processed where a licence obligation requires it. This may be the case even where the need to process data in this way is not specifically set out by a licence condition, if the processing is realistically necessary in order to achieve the aim of the condition [2](#2) . GDPR provides for a number of lawful circumstances which are designed to allow legitimate processing in circumstances where it may be not practical to acquire consent, and to ensure that public policy objectives (such as the reduction of problem gambling) are met. As well as consent, these include: **i.** the processing is necessary [3](#3) for compliance with a legal obligation to which the controller is subject **ii.** processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract **iii.** the processing is necessary for the performance of a task carried out in the public interest [4](#4) **iv.** the processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party (except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data) [5](#5) . Licensees should note that more than one of the above bases may apply to some of the personal data they obtain (for instance, data obtained to ensure operators know their customers). There are additional requirements where the personal data which is to be processed constitutes “special category” data, or data relating to criminal convictions and offences. We anticipate that the majority of data which licensees process for regulatory purposes (such as data on customer transactions) will not be special category data. Where processing of special category data or criminal offence data is required for the purposes of compliance with their licence obligations, licensees will wish to identify a legal basis which allows such processing. In addition to the permissible legal bases set out in GDPR, further permissible legal bases for processing are included in Schedule 1 of the implementing UK legislation (the Data Protection Bill) currently going through Parliament. For example, these include conditions which permit processing by non-government bodies of data about criminal activity where the processing must necessarily be carried out without the data subject-s consent, is necessary for reasons of substantial public interest, and either: **i.** is necessary for the purposes of the prevention or detection of an unlawful act **ii.** is necessary for the exercise of a protective function (such as protecting members of the public against dishonesty, malpractice or other seriously improper conduct). The Bill also includes a condition which allows processing of special category data where an individual is at risk and the processing is necessary for the purposes of protecting the mental or emotional well-being of an individual. Licensees will wish to take steps to ensure they can demonstrate that, for each type of processing, they meet the relevant tests of the identified basis.

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Gambling regulation and the General Data Protection Regulation (GDPR)

Data subject rights

https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/gambling-regulation-and-the-general-data-protection-regulation-gdpr

GDPR gives data subjects certain qualified rights in relation to their data, such as the “right to erasure” and “the right to prevent decisions being made solely based on the automated processing of data”. Data controllers should be aware of these rights, and make an assessment of the circumstances in which they do and do not apply. For example, such rights may not apply where their exercise conflicts with important regulatory objectives (such as the refusal of service to underage gamblers). Relevant considerations here may include: **i.** The right to erasure is restricted where processing is still necessary in relation to one of the permitted purposes - for instance, compliance with a legal obligation, performance of a contract, or for the performance of a task carried out in the public interest. **ii.** The right to prevent decisions being made solely based on the automated processing of data will not apply: **1.** Where decisions are not made solely on this basis i.e. there is some human intervention **2.** If the decision making is based on the data subject-s explicit consent **3.** If the decision is one which is authorised by law to which the controller is subject. Licensees should also consider whether any other exemptions to data subject rights (such as those set out in Schedule 2 of the draft Bill) may apply. In particular, licensees should have regard to their role in preventing crime (including money laundering offences and cheating at gambling) and consider to what extent this objective would be likely to be prejudiced by a request to erase data or restrict processing of personal data, for example.

1753

Gambling regulation and the General Data Protection Regulation (GDPR)

Other obligations

https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/gambling-regulation-and-the-general-data-protection-regulation-gdpr

In addition to identifying a lawful basis for processing, operators will need to comply with other aspects of GDPR, such as any applicable requirements for transparency with data subjects, and safeguarding of personal data. We do not anticipate that the need for such measures will cause a significant barrier to complying with gambling regulation. Indeed, being transparent with consumers at the outset (including informing them that their data may be passed to regulators when requested) may assist businesses to answer subsequent queries about the retention and use of their personal data for regulatory and public interest purposes. Thorough consideration of transparency requirements will also assist data subjects, and assist data controllers to demonstrate compliance with obligations relating to accountability.

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Gambling regulation and the General Data Protection Regulation (GDPR)

Next steps

https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/gambling-regulation-and-the-general-data-protection-regulation-gdpr

The ICO is continuing to produce guidance to assist businesses in complying with their GDPR obligations. This includes guidance on the available lawful bases. We recommend that licensees have regard to that guidance, as it will assist them to assess the best way of achieving their regulatory requirements under their licence and also meet obligations under data protection law. We will not accept licensees simply stating that GDPR means that they are unable to comply with an aspect of gambling regulation, or otherwise take certain steps to protect the public interest. Where genuine concerns, based on a careful and thorough analysis of GDPR and Commission regulation, are raised with us we will work with industry and the ICO to resolve them. However, if an operator thinks that this might be the case, we would expect them first to have carefully considered all available legal bases and exemptions which may allow the specific activity. Documenting the consideration of the processing will assist in meeting requirements regarding accountability and documentation. Whilst it will remain the responsibility of licensees to ensure they are legally compliant with GDPR, we are committed to offering assistance and support to help ensure that the licensing objectives and regulatory framework are upheld, and not prejudiced by the way operators interpret and implement compliance with their data protection obligations.

1755

Gambling regulation and the General Data Protection Regulation (GDPR)

Retention of data

https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/gambling-regulation-and-the-general-data-protection-regulation-gdpr

GDPR does not substantially alter the principles behind the development of policies for data retention. Licensees should already have assessed how long to retain data for, bearing in mind the legitimate purposes for which it was gathered and has been retained. Under GDPR, data subjects may request that their personal data (including data which may be relevant to regulatory compliance) is erased. However, this right is not unrestricted. In particular, such requests are unlikely to be valid if retention of the data is still necessary in relation to a lawful purpose. Where data which is relevant to a licensee-s compliance with the regulatory regime has been obtained, licensees should have regard to the fact that we may wish to investigate whether a licensee has complied with their obligations. In some cases (for instance, where we are investigating a licensee-s compliance with its social responsibility and anti-money laundering requirements as a result of a gambler stealing funds for gambling over a prolonged period of time), this may involve requesting account data which goes back a substantial period. Licensees should ensure that their retention policies ensure that such data will be available to the Commission if requested [6](#6) . Based on our experience of investigations to date, licensees should ensure that data which relates in any way to regulatory compliance should be available for a minimum period of five years after the end of a relationship with a customer.

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Gambling regulation and the General Data Protection Regulation (GDPR)

Specific scenarios considered

https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/gambling-regulation-and-the-general-data-protection-regulation-gdpr

We have been provided with a number of scenarios in respect of which industry has expressed concern that GDPR will prevent them from processing personal data needed to comply with licence conditions and further the licensing objectives. We comment on a few of the following areas, in order to illustrate the approach licensees should take when considering such issues.

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Gambling regulation and the General Data Protection Regulation (GDPR)

Scenarios

https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/gambling-regulation-and-the-general-data-protection-regulation-gdpr

### Self-exclusion and anti-money laundering **i.** Licensees should consider the requirements of their licence (for example, those requirements included at [Annex A](/licensees-and-businesses/guide/gambling-regulation-and-the-general-data-protection-regulation-gdpr#annex-a) ). As licensees must achieve these outcomes, licensees should: **1.** consider what personal data should be processed to achieve these outcomes **2.** consider which of the permitted lawful bases for processing may apply to such processing **ii.** As well as for compliance in relation to specific accounts, licensees may need to collate other personal data (such as data on changing customer demographics) in order to formulate effective policies, procedures and controls in these areas (and other areas) - see for example [Licence condition 12.1.1](/licensees-and-businesses/lccp/condition/12-1-1-anti-money-laundering-prevention-of-money-laundering-and-terrorist) . **iii.** Licensees should also consider to what extent data subject rights, such as the right to erasure and right not to be subject to automated decision-making, may not apply given the relevant lawful basis **iv.** Licensees should consider what retention period is necessary for any data obtained and processed for self-exclusion or anti-money laundering purposes (whether also obtained for other purposes). Operators should take into account that we may need to obtain such data even after an account has closed in order to establish whether or not a licensee has complied with its regulatory obligations. ### Obtaining, retaining and using data for other social responsibility purposes **i.** Licensees gather and retain personal information on customers in order to enable them to enter into and perform contracts, whilst taking into account their regulatory obligations. In common with other sectors we anticipate that licensees will continue to do so. **ii.** Our licence conditions and codes of practice require operators, at the account opening stage and thereafter, to: **1.** continue to obtain and retain information which is sufficient to satisfy them that underage gambling is not taking place **2.** continue to obtain and retain information to enable them to comply with SR 3.4.1 in relation to identification of problem gambling, which requires operators to 'use… all relevant sources of information to ensure effective decision making' Licensees are expected to continue to obtain and analyse continue to obtain and analyse data for the purposes of ensuring that their social responsibility policies and procedures are fit for purpose, taking into account the state of the art and currently available techniques for identifying and minimising problem gambling. **iii.** Licensees should also consider to what extent data subject rights, such as the right to erasure and right not to be subject to automated decision-making, may not apply given the relevant lawful basis. **iv.** Licensees should consider what retention period is necessary for any data which is obtained and processed for these purposes (whether also obtained for other purposes), noting that we may need to obtain such data even after an account has closed in order to establish whether or not a licensee has complied with its regulatory obligations. ### Sharing of data on suspected illegality (such as match-fixing, doping or fraud) **i.** Licensees should consider whether processing of such data is for a permissible purpose, such as it being necessary in the public interest and/or a regulatory requirement. See [Annex A](/licensees-and-businesses/guide/gambling-regulation-and-the-general-data-protection-regulation-gdpr#annex-a) for more information. **ii.** Although Article 10 of GDPR provides that, usually, processing of personal data relating to criminal convictions and offences shall only be carried out under the control of official authority, there are exceptions to this. The Bill includes conditions that allow processing to be carried out without the data subject-s consent, if necessary for reasons of substantial public interest, and either: **1.** necessary for the purposes of the prevention or detection of an unlawful act **2.** necessary for the exercise of a protective function (such as protecting members of the public against dishonesty, malpractice or other seriously improper conduct). **iii.** Licensees should also note that there is a specific condition (at Schedule 1 para. 23) of the Bill to allow processing for the purposes of eliminating doping in sport, and a specific condition (at Schedule 1 para. 24) to allow processing designed to protect the integrity of a sport or sporting event.

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Gambling regulation and the General Data Protection Regulation (GDPR)

Marketing to consumers

https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/gambling-regulation-and-the-general-data-protection-regulation-gdpr

Separately, concerns have been raised about the volume of unsolicited direct e-marketing (predominantly via email and SMS) for gambling products which consumers receive. Such marketing is not undertaken in the public interest or to comply with regulation, but is done in order to sell a product. The ICO report that the gambling sector is one of the most complained about sectors in this respect. We, along with the ICO, are concerned about consumers receiving such direct marketing without their genuine consent. Licensees should ensure they are compliant with the law in relation to direct marketing, in particular the Privacy and Electronic Communications Regulations (and the ePrivacy Regulation which is due to be implemented shortly). Licensees should satisfy themselves that anyone they contract with in relation to direct marketing hold the appropriate consents from consumers for marketing of the licensees- products. Ongoing failure to ensure compliance may result in regulatory action.

1759

Gambling regulation and the General Data Protection Regulation (GDPR)

Footnotes

https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/gambling-regulation-and-the-general-data-protection-regulation-gdpr

1 We expect operators to take into consideration the Gambling Commission-s views expressed in this document. However operators should be aware that the Gambling Commission cannot provide any definitive ruling on the interpretation of the GDPR, and the ICO will address any issues on a case by case basis. 2 Note that in respect of special category personal data, a further specific basis for processing would also be required. 3 ‘Necessary- in the context of such exemptions typically means “more than desirable but less than indispensable or absolute necessity.” This test may involve the consideration of alternative measures which would also sufficiently achieve the legitimate aim in question. 4 Use of this basis is not limited to public bodies. 5 We recommend that licensees refer to the guidance published by the ICO on use of this basis. 6 Additionally, some licensees will be subject to specific statutory requirements to retain relevant data, under the Money Laundering Regulations 2017 for example.

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Gambling regulation and the General Data Protection Regulation (GDPR)

Social responsibility code 3.1.1 – Socially Responsible Gambling

https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/gambling-regulation-and-the-general-data-protection-regulation-gdpr

Licensees must have and put into effect policies and procedures intended to promote socially responsible gambling, including the specific policies and procedures required by the provisions of section 3 of this code.

1761

Gambling regulation and the General Data Protection Regulation (GDPR)

Social responsibility codes 3.5.1 and 3.5.3 – Self-Exclusion

https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/gambling-regulation-and-the-general-data-protection-regulation-gdpr

**1** Licensees must have and put into effect procedures for self-exclusion and take all reasonable steps to refuse service or to otherwise prevent an individual who has entered a self-exclusion agreement from participating in gambling. **2** Licensees must, as soon as practicable, take all reasonable steps to prevent any marketing material being sent to a self-excluded customer. **6** Licensees must put into effect procedures designed to ensure that an individual who has self-excluded cannot gain access to gambling. These procedures must include … a register of those excluded with appropriate records …

1762

Gambling regulation and the General Data Protection Regulation (GDPR)

Licence Condition 12.1.1 – Anti-Money Laundering

https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/gambling-regulation-and-the-general-data-protection-regulation-gdpr

**1** Licensees must conduct an assessment of the risks of their business being used for money laundering and terrorist financing. Such risk assessment must be appropriate and must be reviewed as necessary in the light of any changes of circumstances, including the introduction of new products or technology, new methods of payment by customers, changes in the customer demographic, or any other material changes, and in any event reviewed at least annually. **2** Licensees must ensure they have appropriate policies, procedures and controls to prevent money laundering and terrorist financing. **3** Licensees must ensure that such policies, procedures and controls are implemented effectively, kept under review, revised appropriately to ensure that they remain effective, and take into account any applicable learning or guidelines published by the Gambling Commission from time to time.

1763

Gambling regulation and the General Data Protection Regulation (GDPR)

Social responsibility code 3.4.1 - Problem gambling

https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/gambling-regulation-and-the-general-data-protection-regulation-gdpr

Licensees must put into effect policies and procedures for customer interaction where they have concerns that a customer-s behaviour may indicate problem gambling, including: **e.** Specific provision for making use of all relevant sources of information to ensure effective decision making, and to guide and deliver effective customer interactions, including in particular: **i** provision to identify at risk customers who may not be displaying obvious signs of, or overt behaviour associated with, problem gambling: this should be by reference to indicators such as time or money spent. **ii** specific provision in relation to customers designated by the licensee as ‘high value-, ‘VIP- or equivalent.

1764

Gambling regulation and the General Data Protection Regulation (GDPR)

Licence Condition 15.1.1. – Reporting suspicion of offences etc – non-betting licences

https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/gambling-regulation-and-the-general-data-protection-regulation-gdpr

**1** Licensees must as soon as reasonably practicable provide the Commission or ensure that the Commission is provided with any information that they know relates to or suspect may relate to the commission of an offence under the Act, including an offence resulting from a breach of a licence condition or a code provision having the effect of a licence condition.

1765

Gambling regulation and the General Data Protection Regulation (GDPR)

Licence Conditions 15.1.2 - Reporting suspicion of offences etc – betting licences

https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/gambling-regulation-and-the-general-data-protection-regulation-gdpr

**1** Licensees must as soon as reasonably practicable provide the Commission or ensure the Commission is provided with any information from whatever source that they: **a** know relates to or suspect may relate to the commission of an offence under the Act, including an offence resulting from a breach of a licence condition or a code provision having the effect of a licence condition **b** suspect may lead the Commission to consider making an order to void a bet. **2** Licensees who accept bets, or facilitate the making or acceptance of bets between others, on the outcome of horse races or other sporting events governed by one of the sport governing bodies for the time being included in Part 3 of Schedule 6 to the Act must also provide the relevant sport governing body with sufficient information to conduct an effective investigation if the licensee suspects that they have any information from whatever source that may: **a** lead the Commission to consider making an order to void a bet **b** relate to a breach of a rule on betting applied by that sport governing body.

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Gambling regulation and the General Data Protection Regulation (GDPR)

Licence Condition 15.3.1 – Information provision

https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/gambling-regulation-and-the-general-data-protection-regulation-gdpr

Licensees are required to provide the Commission on request with such information as the Commission may require about the use made of facilities provided in accordance with the licence, including … the licensee-s policies in relation to, and experiences of, problem gambling.

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Gambling regulation and the General Data Protection Regulation (GDPR)

Licence Condition 2.3.1 – Technical standards

https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/gambling-regulation-and-the-general-data-protection-regulation-gdpr

Licensees must comply with the Commission-s technical standards and with requirements set by the Commission relating to the timing and procedures for testing. For example, remote gambling and software technical standard 11 requires licensees to implement measures intended to deter, prevent, and detect collusion and cheating. Gambling systems must retain a record of relevant activities to facilitate investigation and be capable of suspending or disabling player accounts or player sessions. Operators must monitor the effectiveness of their policies and procedures.

1768

Contents

https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/gambling-regulation-and-the-general-data-protection-regulation-gdpr

* [Gambling regulation and the General Data Protection Regulation (GDPR)](#) * [General approach of the Commission to compliance](#general-approach-of-the-commission-to-compliance) * [Retention of data](#retention-of-data) * [Specific scenarios considered](#specific-scenarios-considered) * [Marketing to consumers](#marketing-to-consumers) * [Annex A](#annex-a) [Print this guide](#)

1769

Gaming machine payouts: return-to-player

https://www.gamblingcommission.gov.uk/licensees-and-businesses/page/gaming-machine-payouts-return-to-player

## This refers to Key event 17 Your gaming machines must clearly display the percentage return-to-player figure (% RTP). You must ensure that all the machines you make available display the correct percentage return to player figure (%RTP), this is required by the Circumstances of Use Regulations. > [Gaming machine (Circumstances of Use) Regulations 2007 (opens in a new tab)](https://www.legislation.gov.uk/uksi/2007/2319/contents/made) > > If the label on the machine is in a position where it may be possible to be removed or covered up make sure you regularly check the required information is still displayed correctly and clearly for the benefit of players. ## Considerations regarding how to remedy a fault

1770

Gaming machine payouts: return-to-player

This refers to Key event 17

https://www.gamblingcommission.gov.uk/licensees-and-businesses/page/gaming-machine-payouts-return-to-player

Any gaming system fault which has resulted in under or overpayments to a player.

1771

Gaming machine payouts: return-to-player

Considerations regarding how to remedy a fault

https://www.gamblingcommission.gov.uk/licensees-and-businesses/page/gaming-machine-payouts-return-to-player

You should not benefit from a fault. You should endeavour to return the money to customers in a timely manner. If the individuals affected cannot be identified, you are encouraged to make efforts to repay the money to the group of consumers most likely to contain those affected. The money should be repaid in a way that would not incentivise additional gambling and is not based on a minimum-spend requirement or threshold. We expect consumers to be informed of steps taken and the reason for this only after all the money has been returned, and not during this period. This will avoid operators being able to benefit through promotion or advertising, which is unacceptable. If you cannot return the money to consumers in line with these aims, you should divest yourselves of the profits and this should be paid to a responsible gambling charity. --- Last updated: 5 May 2021 Show updates to this content No changes to show.

1772

Classification of crane machines

https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/page/classification-of-crane-machines

As these are gaming machines, a premises licence or permit from the local authority is needed to site them. Depending on the type of premises, some unlicensed operators will also need to apply for an operating licence. Although the majority of this type of machine are operated as cranes within adult gaming and family entertainment centres under the category D stake and prize limits, there has been a trend where they are being offered to the public. When offered to the public, they are presented as a skill machine as opposed to a gaming machine, without the necessary permissions to do so. This occurs in pubs, shopping centres, motorway service areas and other similar venues. Machines which are capable of being used as a gaming machine, whether or not they are currently operating as a gaming machine, are classified as a gaming machine. For example, a machine fitted with a compensator, which allows it to be converted from a skill machine to a gaming machine, is classified as a gaming machine. You can see a more detailed definition of gaming machines in [section 235 of the Gambling Act (opens in a new tab)](https://www.legislation.gov.uk/ukpga/2005/19/section/235) Machines using a mechanical arm or similar device to select a prize and which employ a compensator unit to determine the percentage pay-out of the machine, need to be clearly marked as a gaming machine (skill and chance combined). They also may only be operated in premises where the necessary permissions are in place. Operators supplying or maintaining these types of machine must have an operator-s licence. Check the [public register](/public-register) for those who hold or have applied for an operators- licence. ! **Warning Where the relevant permission has not been granted the machine should be removed from the site immediately.** [Previous page Non-complex cat D gaming machines (crane grabs)](/licensees-and-businesses/guide/non-complex-cat-d-gaming-machines-crane-grabs) [Next page Machine technical standards](/licensees-and-businesses/guide/page/machine-technical-standards) --- Last updated: 21 May 2021 Show updates to this content No changes to show.

1773

Machine technical standards

https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/page/machine-technical-standards

Where a machine determines whether a player has an opportunity to win a prize partly by chance (using a compensator or control system to control the payout) but also by a player using a degree of skill to ultimately win the prize, the machine would be considered a game of chance and skill combined. This is defined by [section 6(2)(a) of the Gambling Act 2005 (opens in a new tab)](https://www.legislation.gov.uk/ukpga/2005/19/section/6) as a game of chance and will therefore be defined as a gaming machine. We will consider amending the definition of category D non-complex crane machines in our Technical Standards to replicate the definition of crane in [The Categories of Gaming Machine (Amendment) Regulations 2009 (No 1502) (opens in a new tab)]( https://www.legislation.gov.uk/uksi/2009/1502/contents/made) . A crane grab machine is a reference to a non-money prize machine in respect of which: * every prize which can be won as a result of using the machine consists of an individual physical object (such as a stuffed toy) * whether or not a person using the machine wins a prize is determined by the person-s success or failure in manipulating a device forming part of the machine so as to separate, and keep separate, one or more physical objects from a group of such objects. In general, the only requirement needed to make existing crane grab machines compliant with this regulation and our technical standards would be to include a display notice on the machine stating that it is a category D gaming machine with the proviso that the stake or prize does not exceed the statutory limits of £1-£50 respectively and that prizes are totally non-monetary. Suppliers/operators will be aware that other requirements such as Gamcare information (or equivalent) must also be met. > Should the industry attempt to exploit the situation in a manner deemed undesirable or outside the spirit of that intended then we may review our position in this matter. > > [Previous page Classification of crane machines](/licensees-and-businesses/guide/page/classification-of-crane-machines) [Next page Limited prize machines](/licensees-and-businesses/guide/page/limited-prize-machines) --- Last updated: 18 May 2021 Show updates to this content No changes to show.

1774

Limited prize machines

https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/page/limited-prize-machines

Limited prize machines have been around for many years and the most recent type seems to be the ‘play until you win- or ‘prize every time- crane machine, although there may be other types. [Section 249 of the Gambling Act 2005 (opens in a new tab)](https://www.legislation.gov.uk/ukpga/2005/19/section/249) states that a person does not commit an offence under section 37 or 242 (of the Gambling Act 2005) if they make a gaming machine available for use by an individual; and the individual does not, by using the machine, acquire an opportunity to win a prize of a value in excess of the amount paid for or in connection with use of the machine. The explanatory notes to the Gambling Act elaborate on this a little and say a ‘limited prize- is “a prize whose value does not exceed any payment made for use of the machine”. That is, the prize value does not exceed the cost to play. This exemption means that a licence or permit is not required to cover the siting of a limited prize machine. [Previous page Machine technical standards](/licensees-and-businesses/guide/page/machine-technical-standards) [Next page Skill with prize machines (SWPs)](/licensees-and-businesses/guide/page/skill-with-prize-machines) --- Last updated: 18 May 2021 Show updates to this content No changes to show.

1775

15.2.1 - Reporting key events

https://www.gamblingcommission.gov.uk/licensees-and-businesses/lccp/condition/15-2-1-reporting-key-events

Applies to: All operating licences A key event is an event that could have a significant impact on the nature or structure of a licensee-s business. Licensees must notify the Commission, in such form or manner as the Commission may from time to time specify, of the occurrence of any of the following key events as soon as reasonably practicable and in any event within five working days of the licensee becoming aware of the event-s occurrence [1](#1521-1) . Operator status 1. Any of the following applying to a licensee, any person holding a key position for a licensee, a group company or a shareholder or member (holding 3% or more of the issued share capital of the licensee or its holding company): • presenting of a petition for winding up • making of a winding up order • entering into administration or receivership • bankruptcy (applying to individuals only) • sequestration (applicable in Scotland), or • an individual voluntary arrangement. Relevant persons and positions 2. In the case of licensees who are companies or other bodies corporate having a share capital, the name and address of any person who (whether or not already a shareholder or member) becomes a shareholder or member holding 3% or more of the issued share capital of the licensee or its holding company. 3. The taking of any loan by the licensee, or by a group company who then makes an equivalent loan to the licensee, from any person not authorised by the Financial Conduct Authority: a copy of the loan agreement must be supplied. 4. The appointment of a person to, or a person ceasing to occupy, a ‘key position- (including leaving one position to take up another). A ‘key position- in relation to a licensee is: - in the case of a small-scale operator, a ‘qualifying position- as defined in the Gambling Act 2005 (Definition of Small-scale Operator) Regulations 2006 - in the case of an operator which is not a small-scale operator, a ‘specified management office- as set out in (current) LCCP licence condition 1.2 - a position where the holder of which has overall responsibility for the licensee-s anti-money laundering and/or terrorist financing compliance, and/or for the reporting of known or suspected money laundering or terrorist financing activity. - any other position for the time being designated by the Commission as a ‘key position-. (Notification is required whether or not the person concerned is required to hold a personal management licence and whether or not the event notified requires the licensee to apply for a variation to amend a detail of their licence.) Financial events 5. Any material change in the licensee-s banking arrangements, in particular the termination of such arrangements or a particular facility and whether by the licensee or the provider of the arrangements. 6. Any breach of a covenant given to a bank or other lender. 7. Any default by the licensee or, where the licensee is a body corporate, by a group company in making repayment of the whole or any part of a loan on its due date. 8. Any change in the licensee-s arrangements as to the methods by which, and/or the payment processors through which, the licensee accepts payment from customers using their gambling facilities (this key event applies to remote casino, bingo and betting operating licences, except ancillary and remote betting intermediary (trading room only) licences). Legal or regulatory proceedings or reports 9. The grant, withdrawal or refusal of any application for a licence or other permission made by the licensee, or in the case of a licensee which is a body corporate, any group company of theirs, to a gambling regulator in another jurisdiction. In the case of a withdrawal or refusal of the application, the licensee must also notify the reasons for such withdrawal or refusal. (This condition does not apply to applications for licences or other permissions to carry on activities which would fall outside the scope of a Gambling Commission operating licence if carried out in Britain or with customers in Great Britain.) 10. Any investigation by a professional, statutory, regulatory or government body (in whatever jurisdiction) into the licensee-s activities, or the activities of a person in a ‘key position-, where such an investigation could result in the imposition of a sanction or penalty which could reasonably be expected to raise doubts about the licensee-s continued suitability to hold a Gambling Commission licence. 11. Any criminal investigation by a law enforcement agency in any jurisdiction in which the licensee, or a person in a ‘key position- related to the licensee, is involved and where the Commission might have cause to question whether the licensee-s measures to keep crime out of gambling had failed. 12. The referral to the licensee-s Board, or persons performing the function of an audit or risk committee, of material concerns raised by a third party (such as an auditor, or a professional, statutory or other regulatory or government body (in whatever jurisdiction)) about the provision of facilities for gambling: a summary of the nature of the concerns must be provided. 13. The imposition by the licensee of a disciplinary sanction, including dismissal, against the holder of a personal licence or a person occupying a qualifying position for gross misconduct; or the resignation of a personal licence holder or person occupying a qualifying position following commencement of disciplinary proceedings in respect of gross misconduct against that person. 14. The commencement (in whatever jurisdiction) of any material litigation against the licensee or, where the licensee is a body corporate, a group company: the licensee must also notify the outcome of such litigation. 15. The making of a disclosure pursuant to section 330, 331, 332 or 338 of the Proceeds of Crime Act 2002 or section 19, 20, 21, 21ZA, 21ZB or 21A of the Terrorism Act 2000 (a suspicious activity report): the licensee should inform the Commission of the unique reference number issued by the United Kingdom Financial Intelligence Unit of the National Crime Agency in respect of each disclosure and for the purposes of this key event the five working day period referred to above runs from the licensee-s receipt of the unique reference number. The licensee should also indicate whether the customer relationship has been discontinued at the time of the submission. Gambling facilities 16. Any security breach to the licensee-s environment that adversely affects the confidentiality of customer data; or prevents the licensee-s customers, staff, or legitimate users from accessing their accounts for longer than 12 hours. 17. Where a gaming system fault has resulted in under or overpayments to a player (this includes instances where a fault causes an incorrect prize/win value to be displayed). 18. In the case of remote gambling, the commencement or cessation of trading on website domains (including mobile sites or mobile device applications) or broadcast media through which the licensee provides gambling facilities (including domains covered by ‘white label- arrangements). In this condition: ‘body corporate- has the meaning ascribed to that term by section 1173 of the Companies Act 2006 or any statutory modification or re-enactment thereof - in respect of a company, ‘holding company- and ‘subsidiary- have the meaning ascribed to that term by section 1159 of the Companies Act 2006 or any statutory modification or re-enactment thereof - a ‘group company- is any subsidiary or holding company of the licensee and any subsidiary of such holding company. > Read additional [guidance on the information requirements](/guidance/lccp-Information-requirements/guidance-to-operators-on-display-of-licensed-status-key-events-general) contained within this section. > > ## References

1776

15.2.1 - Reporting key events

References

https://www.gamblingcommission.gov.uk/licensees-and-businesses/lccp/condition/15-2-1-reporting-key-events

1 Key events are to be reported to us online via the [‘eServices-](/service/operator-eservices) digital service on our website.

1777

12.1.1 - Anti-money laundering - Prevention of money laundering and terrorist financing

https://www.gamblingcommission.gov.uk/licensees-and-businesses/lccp/condition/12-1-1-anti-money-laundering-prevention-of-money-laundering-and-terrorist

Applies to: All operating licences except gaming machine technical and gambling software licences 1. Licensees must conduct an assessment of the risks of their business being used for money laundering and terrorist financing. Such risk assessment must be appropriate and must be reviewed as necessary in the light of any changes of circumstances, including the introduction of new products or technology, new methods of payment by customers, changes in the customer demographic or any other material changes, and in any event reviewed at least annually. 2. Following completion of and having regard to the risk assessment, and any review of the assessment, licensees must ensure they have appropriate policies, procedures and controls to prevent money laundering and terrorist financing. 3. Licensees must ensure that such policies, procedures and controls are implemented effectively, kept under review, revised appropriately to ensure that they remain effective, and take into account any applicable learning or guidelines published by the Gambling Commission from time to time.

1778

Reminder to licensees regarding white label gambling websites

https://www.gamblingcommission.gov.uk/licensees-and-businesses/page/reminder-to-licensees-regarding-white-label-gambling-websites

The Gambling Commission is reminding remote operating licence holders of their obligations when operating gambling websites, including white labelled sites. The responsibility for compliance sits with the licence holder and cannot be transferred to any other party. Failure to ensure that at all times: * a licensee-s business is conducted in a way which minimises the risk to the licensing objectives * our [Licence Conditions and Codes of Practice (LCCP)](/licensees-and-businesses/lccp/online) are being complied with. ! **Warning Failure to ensure these may bring into question the suitability of an operator to hold a licence.** Licensees must know their customers and be able to demonstrate knowledge, oversight and proactive interactions where appropriate. Any interventions must be completed in a timely manner

1779

Reminder to licensees regarding white label gambling websites

SRCP 1.1.2 - Responsibility for third parties

https://www.gamblingcommission.gov.uk/licensees-and-businesses/page/reminder-to-licensees-regarding-white-label-gambling-websites

SRCP 1.1.2 - Responsibility for third parties makes clear that licensees are responsible for the third parties that they contract with. It also requires licensees to ensure that any contracted third parties conduct themselves in so far as they carry out activities on behalf of the licensee as if they were bound by the same licence conditions and subject to the same codes of practice as the licensee. The Commission expects that licensees will obtain the necessary assurance by conducting adequate due diligence on the third party to ensure (amongst other things) that they are competent and reliable. Any licensee that relies on a third party to conduct any aspect of the licensee-s business related to the licensed activities must ensure it has sufficient oversight and controls in place to ensure that all activities are carried out in accordance with the [Licence Conditions and Codes of Practice (LCCP)](/licensees-and-businesses/lccp/online) , notably, but not exclusively, social responsibility and anti-money laundering requirements. ! **Warning Failure to maintain adequate control of third parties can result in regulatory action including suspension or the loss of the operating licence.** Finally – operators are aware that a licence is required to provide facilities for gambling (unless a specified exemption applies). Operators must ensure that their arrangements with third parties do not result in an offence under [section 33 of the Gambling Act 2005 (opens in a new tab)](https://www.legislation.gov.uk/ukpga/2005/19/section/33) . The Commission intends to publish further guidance in due course. --- Last updated: 28 January 2021 Show updates to this content No changes to show.

1780

1.1.1 - Qualified persons – qualifying position

https://www.gamblingcommission.gov.uk/licensees-and-businesses/lccp/condition/1-1-1-qualified-persons-qualifying-position

Applies to: All operating licences, except ancillary remote licences, issued to small-scale operators 1. In this condition the terms ‘small-scale operator-, ‘qualifying position- and ‘qualified person- have the meanings respectively ascribed to them by the Gambling Act 2005 (Definition of Small-scale Operator) Regulations 2006. 2. Schedule X [1](#111-1) lists those individuals notified to the Commission as qualified persons. 3. If, whilst the licensee remains a small-scale operator, an individual begins or ceases to occupy a qualifying position in relation to the licensee, the licensee must within 28 days apply to the Commission under section 104(1)(b) of the Act for amendment of the details of the licence set out in Schedule X [1](#111-1) . 4. An application for amendment under section 104(1)(b) of the Act may be made in advance of an individual beginning or ceasing to occupy a qualifying position provided it specifies the date from which the change to which it relates is to be effective. 5. In this condition ‘qualified person- has the same meaning as in the Gambling Act 2005(Definition of Small-scale Operator) Regulations 2006. ## References

1781

1.1.1 - Qualified persons – qualifying position

References

https://www.gamblingcommission.gov.uk/licensees-and-businesses/lccp/condition/1-1-1-qualified-persons-qualifying-position

1 The schedules mentioned here will be attached to individual licences.

1782

1.1.2 - Qualified persons – tracks

https://www.gamblingcommission.gov.uk/licensees-and-businesses/lccp/condition/1-1-2-qualified-persons-tracks

Applies to: All non-remote general betting operating licences issued to small-scale operators 1. Schedule Y [1](#111-1) to this licence lists those of the licensee-s employees whose details have been provided to the Commission as authorised by the licensee to accept bets on the licensee-s behalf on a track otherwise than under the supervision of a qualified person present on the same track. 2. Should the licensee wish to add an individual to the list or remove the name of an individual from the list the licensee must make application to the Commission under section 104(1)(b) of the Act for amendment of that detail of the licence. Any employee the licensee wishes to add to the list may act unsupervised pending amendment of the licence provided a valid amendment application has been lodged with the Commission. 3. In this condition ‘qualified person- has the same meaning as in the Gambling Act 2005 (Definition of Small-scale Operator) Regulations 2006. ## References

1783

1.1.2 - Qualified persons – tracks

References

https://www.gamblingcommission.gov.uk/licensees-and-businesses/lccp/condition/1-1-2-qualified-persons-tracks

1 The schedules mentioned here will be attached to individual licences.

1784

1.2.1 - Specified management offices – personal management licences

https://www.gamblingcommission.gov.uk/licensees-and-businesses/lccp/condition/1-2-1-specified-management-offices-personal-management-licences

Applies to: All casino, bingo, general and pool betting, betting intermediary, gaming machine general, gaming machine technical, gambling software and lottery managers licences, except ancillary remote licences 1. Subject to 6 and 7 below, licensees must ensure: 1. that each individual who occupies one of the management offices specified in 2 below in respect of the licensee or in connection with the licensed activities holds a personal licence authorising the performance of the functions of that office (hereafter ‘a personal management licence-); and 2. that at least one person occupies at least one of those offices 2. The specified management offices are those offices (whether or not held by a director in the case of a licensee which is a company, a partner in the case of a licensee which is a partnership or an officer of the association in the case of a licensee which is an unincorporated association) the occupier of which is by virtue of the terms of their appointment responsible for: 1. the overall management and direction of the licensee-s business or affairs 2. the licensee-s finance function as head of that function 3. the licensee-s gambling regulatory compliance function as head of that function 4. the licensee-s marketing function as head of that function 5. the licensee-s information technology function as head of that function in so far as it relates to gambling-related information technology and software - oversight of the day to day management of the licensed activities at an identified number of premises licensed under Part 8 of the Act or across an identified geographical area - in the case of casino and bingo licences only, oversight of the day to day management of a single set of premises licensed under Part 8 of the Act. 3. The person responsible for the licensee-s gambling regulatory compliance function as head of that function shall not, except with the Commission-s express approval, occupy any other specified management office. 4. Licensees must take all reasonable steps to ensure that anything done in the performance of the functions of a specified management office is done in accordance with the terms and conditions of the holder-s personal management licence. 5. Where an individual is authorised by a personal licence and that licence comes under review under section 116(2) of the Act, the operating licensee must comply with any conditions subsequently imposed on that licence by the Commission about redeployment, supervision, or monitoring of the individual-s work and any requirements of the Commission in respect of such matters applicable during the period of the review. 6. Paragraphs 1 to 5 above shall not apply to a licensee for so long as the licensee is a ‘small- scale operator- as defined in the Gambling Act 2005 (Definition of Small-scale Operator) Regulations 2006 (‘the Regulations-). 7. During the period of 3 years commencing with the date on which a licensee ceases to be a small-scale operator paragraphs 1 to 6 above shall apply subject to the proviso that the phrase ‘each individual- in paragraph 1a shall not include any individual who was a ‘qualified person- (as defined in the Regulations) in relation to the licensee 28 days immediately prior to the licensee ceasing to be a small-scale operator.

1785

1.2.2 - Specified management offices – casino personal functional licences

https://www.gamblingcommission.gov.uk/licensees-and-businesses/lccp/condition/1-2-2-specified-management-offices-casino-personal-functional-licences

Applies to: All non-remote casino operating licences, except ancillary remote licences. 1. In addition to paragraphs 1 to 6 in licence condition 1.2.1, licensees must ensure that if any of the following operational functions: 1. dealer in respect of casino games 2. cashier 3. inspector 4. security staff employed to watch gaming 5. supervisor of gaming activities is performed in connection with the licensed activities, it is performed by an individual who holds a personal licence authorising performance of the function (hereafter ‘a personal functional licence-). Licensees must take all reasonable steps to ensure that anything done in the performance of those functions is done in accordance with the terms and conditions of the personal functional licence.

1786

1.2.3 - Specified management offices – lottery personal management licences

https://www.gamblingcommission.gov.uk/licensees-and-businesses/lccp/condition/1-2-3-specified-management-offices-lottery-personal-management-licences

Applies to: All lottery operating licences issued to non-commercial societies and local authorities 1. Subject to 5 below, licensees must ensure that the individual who occupies the management office specified in 2 below in or in respect of the licensee or in connection with the licensed activities holds a personal licence authorising the performance of the functions of that office (hereafter ‘a personal management licence'). 2. The specified management office is that director-s post in the case of a licensee which is a company, that partner in the case of a licensee which is a partnership, or that office in a licensee which is an unincorporated association or local authority, the occupier of which has overall management responsibility for the promotion of the lottery. 3. Licensees must take all reasonable steps to ensure that anything done in the performance of the functions of a specified management office is done in accordance with the terms and conditions of the holder-s personal management licence. 4. Where an individual is authorised by a personal licence and that licence comes under review under section 116(2) of the Act, the operating licensee must comply with any conditions subsequently imposed on that licence by the Commission about redeployment, supervision, or monitoring of the individual-s work and any requirements of the Commission in respect of such matters applicable during the period of the review. 5. Paragraphs 1 to 4 above shall not apply to a licensee for so long as the licensee is a ‘small- scale operator- as defined in the Gambling Act 2005 (Definition of Small-scale Operator) Regulations 2006.

1787

2.1.1 - Access to (and provision of data from) key equipment

https://www.gamblingcommission.gov.uk/licensees-and-businesses/lccp/condition/2-1-1-access-to-and-provision-of-data-from-key-equipment

Applies to: All remote casino, bingo and betting licences other than ancillary licences and remote betting intermediary (trading room only) licences 1. Licensees must, on request, permit an enforcement officer to inspect any of their remote gambling equipment and/or provide to the Commission copies of data held on such equipment in such format and manner as the Commission may request.

1788

3.1.1 - Peer to peer gaming

https://www.gamblingcommission.gov.uk/licensees-and-businesses/lccp/condition/3-1-1-peer-to-peer-gaming

Applies to: Remote casino licences (except ancillary remote and casino (game host) licences) All licensees who provide facilities for peer to peer gaming in circumstances in which they do not contract directly with all of the players using those facilities (‘network operators-) must have, put into effect and monitor the effectiveness of, policies and procedures designed to ensure that: 1. every player using the facilities in Great Britain (‘a domestic player-) is doing so pursuant to a contract entered into between that player and the network operator, or that player and another holder of a Gambling Commission remote casino operating licence; 2. every player who is not a domestic player but who participates in a game of chance in which a domestic player also participates is doing so pursuant to a contract between that player and the network operator, or that player and another holder of a Gambling Commission remote casino operating licence, or a gambling operator not licensed by the Gambling Commission through which participants use the facilities outside Great Britain and which: 1. holds all licences or permissions (if any) required in relation to its provisions of facilities for peer to peer gaming by the laws of the state or states in which it is domiciled or incorporated; 2. has been approved by the network operator, after conducting due diligence enquires into those individuals who appear to the network operator to have a material financial interest in it, as suitable to provide those facilities; and in particular, 3. has in place policies and procedures in respect of the identification of customers which in the network operator-s reasonable opinion satisfy requirements as to the customer due diligence broadly equivalent to those set out in Directive 2005/60/EC (‘the Third Money Laundering Directive-) or any subsequent replacement for re-enactment thereof; 3. the arrangements between the network operator and any remote casino licence holder through which domestic players access their facilities, and with gambling operators not licensed by the Gambling Commission through which players use their facilities outside Great Britain, provide in clear terms which operator is to be responsible for the handling of which categories of customer complaint and dispute; in particular such arrangements must provide how a dispute involving players from more than one jurisdiction is to be handled; 4. the network operator-s arrangements for the sharing of information both with any remote casino licence holder through which domestic players access their facilities and with gambling operators not licensed by the Gambling Commission through which participants use the facilities outside Great Britain are such as to enable all parties to discharge effectively their respective regulatory obligations, in particular in relation to: 1. prevention of money laundering; combating the financing of terrorism; and where applicable, the Proceeds of Crime Act. 2. investigation of suspected cheating, 3. combating of problem gambling, and 4. investigation of customer complaints.

1789

3.1.2 - Other networks

https://www.gamblingcommission.gov.uk/licensees-and-businesses/lccp/condition/3-1-2-other-networks

Applies to: All remote casino, bingo, and betting licences (except ancillary remote and host licences) 1. Subject to 2 below, all licensees who provide facilities for gambling, other than peer to peer gaming, in circumstances in which they do not contract directly with all of the participants using those facilities (‘network operators-) must have, put into effect and monitor the effectiveness of policies and procedures designed to ensure that: - every participant using the facilities in Great Britain (‘a domestic customer-) is doing so pursuant to a contract entered into between that player and the network operator, or that player and another holder of a Gambling Commission remote operating licence of the same kind as that held by the network operator (‘a relevant licence-); - the arrangements between the network operator and any holder of a relevant licence through which domestic customers access their facilities, and with gambling operators not licensed by the Gambling Commission through which customers use their facilities outside Great Britain, provide in clear terms which operator is to be responsible for the handling of which categories of customer complaint and dispute; in particular such arrangements must provide how a dispute involving customers from more than one jurisdiction is to be handled; - the network operator-s arrangements for the sharing of information both with any holder of a relevant licence and with gambling operators not licensed by the Gambling Commission through which participants use the facilities outside Great Britain are such as to enable all parties to discharge effectively their respective regulatory obligations, in particular in relation to: 1. prevention of money laundering; combating the financing of terrorism; and where applicable, the Proceeds of Crime Act, 2. investigation of suspected cheating, 3. combating of problem gambling, and 4. investigation of customer complaints. - Paragraph 1 above does not apply to the provision to the holder of a non-remote bingo operating licence (H) of facilities for the playing of games of bingo organised by H in premises in respect of which a bingo premises licence has effect (eg the National Bingo Game).

1790

3.1.3 - Hosting

https://www.gamblingcommission.gov.uk/licensees-and-businesses/lccp/condition/3-1-3-hosting

Applies to: All casino (game host), bingo (game host), general betting (host) (real events) and general betting (host) (virtual events) licences 1. Subject to 2 below, all licensees who provide facilities for gambling in circumstances in which they do not contract directly with any of the participants using those facilities (‘hosts-) must ensure that: - every participant using the facilities in Great Britain (‘a domestic customer-) is doing so pursuant to a contract entered into between that player and the holder of a Gambling Commission remote casino, bingo, general betting (real events) or general betting (virtual events) operating licence (‘a relevant licence-); - the arrangements between the host and any holder of a relevant licence through which domestic customers access their facilities, and with gambling operators not licensed by the Gambling Commission through which customers use their facilities outside Great Britain, provide in clear terms which operator is to be responsible for the handling of which categories of customer complaint and dispute; in particular such arrangements must provide how a dispute involving customers from more than one jurisdiction is to be handled; - the host-s arrangements for the sharing of information both with any holder of a relevant licence and with gambling operators not licensed by the Gambling Commission through which participants use the facilities outside Great Britain are such as to enable all parties to discharge effectively their respective regulatory obligations, in particular in relation to: 1. prevention of money laundering; combating the financing of terrorism; and where applicable, the Proceeds of Crime Act, 2. investigation of suspected cheating, 3. combating of problem gambling, and 4. investigation of customer complaints. - Paragraph 1 above does not apply to the provision to the holder of a non-remote bingo operating licence (H) of facilities for the playing of games of bingo organised by H in premises in respect of which a bingo premises licence has effect (eg the National Bingo Game).

1791

4.1.1 - Segregation of funds

https://www.gamblingcommission.gov.uk/licensees-and-businesses/lccp/condition/4-1-1-segregation-of-funds

Applies to: All remote operating licences, except gaming machine technical, gambling software, host, ancillary remote bingo and ancillary remote casino licences 1. Licensees who hold customer funds must ensure that these are held in a separate client bank account or accounts. 2. In this condition ‘customer funds- means the aggregate value of funds held to the credit of customers including, without limitation: - cleared funds deposited with the licensee by customers to provide stakes in, or to meet participation fees in respect of, future gambling, - winnings or prizes which the customer has chosen to leave on deposit with the licensee or for which the licensee has yet to account to the customer, and - any crystallised but as yet unpaid loyalty or other bonuses, in each case irrespective of whether the licensee is a party to the gambling contract.

1792

4.2.1 - Disclosure to customers

https://www.gamblingcommission.gov.uk/licensees-and-businesses/lccp/condition/4-2-1-disclosure-to-customers

Applies to: All operating licences, except gaming machine technical, gambling software, host, ancillary, remote bingo, and ancillary remote casino licences 1. Licensees who hold customer funds must set out clearly in the terms and conditions under which they provide facilities for gambling information about whether customer funds are protected in the event of insolvency, the level of such protection and the method by which this is achieved. 2. Such information must be according to such rating system and in such form the Commission may from time to time specify. It must be provided in writing to each customer, in a manner which requires the customer to acknowledge receipt of the information and does not permit the customer to utilise the funds for gambling until they have done so, both on the first occasion on which the customer deposits funds and on the occasion of any subsequent deposit which is the first since a change in the licensee-s terms in relation to protection of such funds. 3. In this condition ‘customer funds- means the aggregate value of funds held to the credit of customers including, without limitation: 1. cleared funds deposited with the licensee by customers to provide stakes in, or to meet participation fees in respect of, future gambling; 2. winnings or prizes which the customer has chosen to leave on deposit with the licensee or for which the licensee has yet to account to the customer; and 3. any crystallised but as yet unpaid loyalty or other bonuses, in each case irrespective of whether the licensee is a party to the gambling contract.

1793

5.1.2 - Payment methods services

https://www.gamblingcommission.gov.uk/licensees-and-businesses/lccp/condition/5-1-2-payment-methods-services

Applies to: All remote casino, bingo and betting operating licences, except ancillary, host and remote betting intermediary (trading room only) licences 1. Licensees must only accept payment from customers using their gambling facilities in Great Britain by a method which involves the provision of payment services as defined in Schedule 1 Part 1 of the Payment Services Regulations 2009 (SI 2009 No 209) if the provider of those services is a ‘payment service provider- within the definition of that term in regulation 2 of those Regulations.

1794

6.1.2 - Use of credit cards

https://www.gamblingcommission.gov.uk/licensees-and-businesses/lccp/condition/6-1-2-use-of-credit-cards

Applies to: All non-remote general betting, pool betting and betting intermediary licences, and all remote licences (including ancillary remote betting and ancillary remote lottery licences) except gaming machine technical, gambling software and host licences 1. Licensees must not accept payment for gambling by credit card. This includes payments to the licensee made by credit card through a money service business.

1795

9.1.1 - Rules of casino games

https://www.gamblingcommission.gov.uk/licensees-and-businesses/lccp/condition/9-1-1-rules-of-casino-games

Applies to: All non-remote casino operating licences 1. Licensees must not offer or permit to be played casino games that appear on any list of games prohibited by the Commission.

1796

9.1.2 - Prohibited bingo prize games

https://www.gamblingcommission.gov.uk/licensees-and-businesses/lccp/condition/9-1-2-prohibited-bingo-prize-games

Applies to: All non-remote bingo operating licences 1. Licensees must not offer or permit to be played prize gaming games that appear on any list of games prohibited by the Commission.

1797

10.1.1 - Tipping – personal licence holders

https://www.gamblingcommission.gov.uk/licensees-and-businesses/lccp/condition/10-1-1-tipping-personal-licence-holders

Applies to: All non-remote casino operating licences 1. Licensees must only permit tipping of staff holding personal licences where a tronc system is operated; that is to say, where all tips are pooled and distributed amongst the employees concerned. A separate tronc may be operated for each of a number of categories of licensed staff.

1798

11.1.1 - Lotteries – societies and local authorities

https://www.gamblingcommission.gov.uk/licensees-and-businesses/lccp/condition/11-1-1-lotteries-societies-and-local-authorities

Applies to: All lottery operating licences issued to non-commercial societies or local authorities 1. Licensees must ensure that at least 20% of the proceeds of any lottery promoted in reliance on the licence are applied to a purpose for which the promoting non-commercial society is conducted or the promoting local authority has power to incur expenditure. 2. For the purposes of this condition: 1. the proceeds of any lottery promoted in reliance on this licence must not exceed £5,000,000 and subject to 11.1.1 2b, the aggregate of the proceeds of lotteries promoted wholly or partly in a calendar year in reliance on the licence must not exceed £50,000,000. 2. In 2020 the aggregate of the proceeds of lotteries promoted wholly or partly in a calendar year may not exceed £31,331,475. 3. The rules of any lottery promoted in reliance on this licence must be such as to ensure: - that it is not possible for the purchaser of a ticket in the lottery to win by virtue of that ticket (whether in money, money's worth, or partly the one and partly the other and including any winnings arising from a rollover) more than: 1. £25,000 2. if more, 10% of the proceeds of the lottery. - that membership of the class among whom prizes are allocated does not depend on making any payment (apart from payment of the price of a ticket). - A lottery promoted in reliance on this licence must not be linked to any other lottery, free draw or prize competition. - For the purposes of this condition: - two or more lotteries are linked if any of them is so structured that a person who wins a prize in that lottery will also win a prize in some or all others, unless the maximum amount which a person can win is no more than £500,000 in aggregate. In determining whether two or more lotteries are linked it is immaterial how many of them are promoted in reliance on this licence. - a lottery is linked to a free draw or prize competition if: 1. a person-s participation in, or his being allocated a prize in, the lottery is a means of establishing his eligibility to enter the draw or competition and 2. the arrangements for the lottery and/or the draw or competition are such that a person may win more than £500,000 in aggregate as a result of his participation in the lottery and the draw or competition. - If a lottery, whilst not a linked lottery, has the feature that by selecting the same numbers in the lottery and in one or more other lottery or lotteries the participant in those lotteries may win prizes which, in aggregate, exceed £500,000, no advertisement for, nor other marketing of, the lottery may make any reference to that feature. - Licensees must ensure that each person who purchases a ticket in a lottery promoted on behalf of a non-commercial society in reliance on this licence receives a document which: - identifies the promoting society; - states the name and address of a member of the society who is designated, by persons acting on behalf of the society, as having responsibility within the society for the promotion of the lottery; and - either states the date of the draw (or each draw) in the lottery, or enables the date of the draw (or each draw) in the lottery to be determined. - Licensees must display ‘licensed by the Gambling Commission- and details of the Gambling Commission website on lottery tickets. - The price payable for purchasing each ticket in a lottery promoted in reliance on this licence: - must be the same; - must be shown on the ticket or in a document received by the purchaser; and - must be paid to the promoter of the lottery before any person is given a ticket or any right in respect of membership of the class among whom prizes are to be allocated. - For the purposes of these conditions, reference to a person receiving a document includes a reference to a message being sent or displayed to him electronically in a manner which enables him, without incurring significant expense or delay, to: - retain the message electronically; or - print it. - Licensees must lodge with the Commission a description of, and a copy of the rules of, any lottery intended to be promoted in reliance on this licence, and any amendment to the rules of a lottery previously notified to the Commission, at least 28 days before any tickets in such lottery, or amended lottery, are put on sale. [1](#1111-1) - Lottery tickets must not be sold to a person in any street. For these purposes ‘street- includes any bridge, road, lane, footway, subway, square, court, alley or passage (including passages through enclosed premises such as shopping malls) whether a thoroughfare or not. But, by way of exception, tickets may be sold in a street from a static structure such as a kiosk or display stand. Tickets may also be sold door to door. Licensees must ensure that they have any necessary local authority permissions, such as a street trading licence. - Accurate accounting records must be kept in relation to all lotteries promoted in reliance on this licence showing: - the total proceeds of each lottery; - the amount allocated to prizes in each lottery; - the amount of proceeds allocated to expenses, and details of those expenses, for each lottery; - the amount applied directly to the purposes of the society or purposes for which the local authority has power to incur expenditure as the case may be; and - the number of sold and unsold tickets in each lottery. - Such records must be made available to the Commission for inspection on request and retained for at least three years from the date of any lottery to which they relate. - In addition, in respect of each lottery promoted in reliance on this licence, a lottery submission must be sent to the Commission within three months of the date of determination of the lottery or, in the case of an ‘instant lottery-, within three months of the last date on which tickets in the lottery were on sale providing the information set out in paragraph 13 above. Every such submission must contain or be accompanied by a declaration that the information given in it is correct and must be shown to have been approved before submission by: - the holder of a personal management licence - a ‘qualified person- as defined in the Gambling Act 2005 (Definition of Small-scale Operator) Regulations 2006 or - except where the licensee is a local authority, the designated person named on the lottery tickets as having responsibility for the promotion of the lottery. - Where a society or local authority instructs an External Lottery Manager to make the submission on their behalf, they must ensure that the details on the submission are verified and approved by one of the people named above from the relevant society or local authority. - For any calendar year in which the cumulative proceeds of lotteries promoted in reliance on this licence exceed £1,000,000 the licensee must provide the Commission with written confirmation from a qualifying auditor confirming that the proceeds of those lotteries have been fully accounted for in their annual audited accounts. Such confirmation must be provided within ten months of the date to which the accounts are made up. - A qualifying auditor means a person who is eligible for appointment as a statutory auditor under section 1212 Companies Act 2006 or any statutory modification or re-enactment thereof but, in the case of a lottery promoted by or on behalf of a non-commercial society, is not: - a member of the society - a partner, officer or employee of such a member or - a partnership of which a person falling within a or b is a partner. > Read additional [guidance on the information requirements](/guidance/lccp-Information-requirements/guidance-to-operators-on-display-of-licensed-status-lccp-notifications) contained within this section. > > ## References

1799

11.1.1 - Lotteries – societies and local authorities

References

https://www.gamblingcommission.gov.uk/licensees-and-businesses/lccp/condition/11-1-1-lotteries-societies-and-local-authorities

1 These matters are to be reported to us online via our ‘eServices- digital service on our website [digital@gamblingcommission.gov.uk](mailto:digital@gamblingcommission.gov.uk)

1800

11.2.1 - Lotteries – managers

https://www.gamblingcommission.gov.uk/licensees-and-businesses/lccp/condition/11-2-1-lotteries-managers

Applies to: All lottery operating licences issued to external lottery managers 1. Licensees must ensure that at least 20% of the proceeds of any lottery promoted in reliance on the licence are paid to the promoting non-commercial society or local authority to apply to a purpose for which the promoting society is conducted or the local authority has power to incur expenditure. 2. For the purposes of this condition: - the proceeds of any lottery promoted in reliance on this licence may not exceed £5,000,000 and subject to 11.2.1 2b, the aggregate of the proceeds of lotteries promoted wholly or partly in a calendar year on behalf of the same non-commercial society or local authority in reliance on the licence may not exceed £50,000,000. - In 2020 the aggregate of the proceeds of lotteries promoted wholly or partly in a calendar year on behalf of the same non-commercial society or local authority in reliance on the licence may not exceed £31,311,475. - The rules of any lottery promoted in reliance on this licence must be such as to ensure: - that it is not possible for the purchaser of a ticket in the lottery to win by virtue of that ticket (whether in money, money's worth, or partly the one and partly the other and including any winnings arising from a rollover) more than: 1. £25,000 2. if more, 10% of the proceeds of the lottery- that membership of the class among whom prizes are allocated does not depend on making any payment (apart from payment of the price of a ticket). - A lottery promoted in reliance on this licence must not be linked to any other lottery, free draw or prize competition. - For the purposes of this condition: - two or more lotteries are linked if any of them is so structured that a person who wins a prize in that lottery will also win a prize in some or all others, unless the maximum amount which a person can win is no more than £500,000 in aggregate. In determining whether two or more lotteries are linked it is immaterial how many of them are promoted in reliance on this licence. - a lottery is linked to a free draw or prize competition if: 1. a person-s participation in, or his being allocated a prize in, the lottery is a means of establishing his eligibility to enter the draw or competition and 2. the arrangements for the lottery and/or the draw or competition are such that a person may win more than £500,000 in aggregate as a result of his participation in the lottery and the draw or competition. - If a lottery, whilst not a linked lottery, has the feature that by selecting the same numbers in the lottery and in one or more other lottery or lotteries the participant in those lotteries may win prizes which, in aggregate, exceed £500,000, no advertisement for, nor other marketing of, the lottery may make any reference to that feature. - Licensees must ensure that each person who purchases a ticket in a lottery promoted in reliance on this licence on behalf of a non-commercial society, receives a document which: - identifies the promoting society - states the name and address of a member of the society who is designated, by persons acting on behalf of the society, as having responsibility within the society for the promotion of the lottery - either states the date of the draw (or each draw) in the lottery, or enables the date of the draw (or each draw) in the lottery to be determined. - Licensees must display ‘licensed by the Gambling Commission- and details of the Gambling Commission website on lottery tickets. - The price payable for purchasing each ticket in a lottery promoted in reliance on this licence: - must be the same - must be shown on the ticket or in a document received by the purchaser - must be paid to the promoter of the lottery before any person is given a ticket or any right in respect of membership of the class among whom prizes are to be allocated. - For the purposes of these conditions, reference to a person receiving a document includes a reference to a message being sent or displayed to him electronically in a manner which enables him, without incurring significant expense or delay, to: - retain the message electronically or - print it. - Licensees must lodge with the Commission a description of, and a copy of the rules of, any lottery intended to be promoted in reliance on this licence, and any amendment to the rules of a lottery previously notified to the Commission, at least 28 days before any tickets in such lottery, or amended lottery, are put on sale. [1](#1121-1) - Lottery tickets must not be sold to a person in any street. For these purposes ‘street- includes any bridge, road, lane, footway, subway, square, court, alley or passage (including passages through enclosed premises such as shopping malls) whether a thoroughfare or not. But, by way of exception, tickets may be sold in a street from a static structure such as a kiosk or display stand. Tickets may also be sold door to door. Licensees must ensure that they have any necessary local authority permissions, such as a street trading licence. - Licensees must have arrangements in place to ensure separation between lottery proceeds they hold on behalf of non-commercial societies or local authorities and their own trading income and that such lottery proceeds are legally protected by means of separate bank accounts having trustee status or equivalent legal protection for each society or local authority in the event of the licensee-s insolvency, in which event the proceeds will be paid to the society or local authority. - Licensees must ensure that following the determination of a lottery all lottery proceeds are properly allocated between prizes, expenses and profits and have procedures in place designed to ensure that lottery profits belonging to non-commercial societies or local authorities whose lotteries they manage in reliance on this licence are accounted for in a timely manner to the society or local authority. ## References