Setting the agenda for responsbile gambling

The national Responsible Gambling Strategy Board (the “Board”) recently published its new strategy (the “Strategy”) aimed at minimising harm over the next three years.

The Strategy was published following a public consultation and covers all forms of gambling. It is designed to set the agenda on responsible gambling for a wide range of stakeholders, including gambling operators, and sets out a vision of what a “desirable outcome” would look like. This makes it essential reading for anyone in the UK gambling industry.

The previous strategy, covering the period 2013-2016, was published in December 2012. There have been a number of developments since the previous incarnation. These include the marked change to the responsible gambling agenda, the move to a point-of-consumption licensing regime, significant technological change affecting the structure of the industry and products offered to consumers in Great Britain, substantial growth in advertising, and increased public concerns about the maximum (£100) size of stakes on B2 gaming machines.

The Board

The Board provides independent advice to the Gambling Commission (the “Commission”), and through it to the Government, on a national responsible gambling strategy. The members are appointed for their expertise, not to represent any particular group, and work within the context of the view that gambling should be regarded as a legitimate leisure time activity. Part of the Board’s role is to provide advice on how best to achieve its statutory obligation to achieve an appropriate balance between regulatory requirements intended to reduce harm, and the desirability of giving players the freedom to choose how to spend their leisure time.

Sir Chris Kelly KCB chairs the Board and the other members have a range of expertise on the gambling industry, socially responsible gambling, public health, addiction and counselling services and research.

No powers

The Board has no powers to implement any of its recommendations directly; its recommendations are implemented by the gambling industry through its social responsibility programmes, the Commission through its regulatory activities and the Responsible Gambling Trust.

Strategy objectives

The overarching aim of the Strategy is to minimise gambling-related harm; such harm goes wider than that experienced by problem gamblers, and includes their families, their employers, their communities and society more widely.

The Strategy has five priority objectives, as below, for the next three years to help move closer to the Board’s vision of what the future should look like in relation to responsibility in gambling:

• to develop more effective harm minimisation interventions, in particular through further experimentation and piloting of different approaches;
• to improve treatment through better use of knowledge, data and evaluation;
• to build a culture where new initiatives are routinely evaluated and findings put into practice;
• to encourage a wider range of organisations in the public and private sector to accept their responsibility to tackle gambling-related harm; and
• to progress towards a better understanding of gambling-related harm and its measurement.

12 priority actions

To achieve its five priority objectives, the Board has identified 12 priority actions, as below, that are important in progressing the priority objectives over the next three years.

Many of the actions are interconnected and in most cases they have already begun, or are planned. The Board believes that the key will be to implement effectively what is intended and to consolidate the gains.

This article is no substitute for reading the Strategy in detail as it sets out the background to each priority, the stakeholder tasked with lead responsibility, indicative timescale for completion and indicators of success. It is worth noting that the Strategy does not address the current hot (public and political) issue of maximum stake size on B2 gaming machines (also known as FOBTs),because the Board is providing its advice on this in the forthcoming triennial review of stakes and prizes.

Priority action 1: Understanding and measuring harm –

• This action involves research intended to create a more sophisticated understanding of the nature of harm associated with gambling.
• Success would involve moving away from more limited measurement tools, such as simply counting the number of problem gamblers.

Priority action 2: Engagement with relevant public sector bodies and other agencies to encourage greater acceptance of responsibility for delivering the strategy –

• This action calls for a broader range of organisations to use their skills, resources
and influence to minimise gamblingrelated harm.

Priority action 3: Consolidating a culture of evaluation –

• Evaluation helps improve understanding of what works, and in what circumstances.
• This action is designed to build on the progress that has been made to evaluate initiatives and use the findings to target the future use of resources.

Priority action 4: Increased understanding of the effects of product characteristics and environment –

• This action requires further work to understand the extent that product characteristics (for example, stake size or speed of play) and environmental characteristics (for example, premises location or layout) contribute towards gambling-related harm.

Priority action 5: Improving methods of identifying harmful play –

• This action calls for continued work to develop methods of identifying patterns of play that are linked to harm.
• Such methods include algorithms relating to remote or machine-based gambling, as well as other approaches such as training for staff to identify and respond to relevant behavioural patterns.

Priority action 6: Piloting interventions –

• It is important that the gambling industry continues to develop and improve ways of intervening when harmful play is identified.
• This action requires well-designed interventions to be piloted and evaluated.
• Approaches could include customer interaction, messaging or debit card blocking.

Priority action 7: Self-exclusion –

• The establishment of multi-operator self-exclusion schemes is under way. A number of sector specific schemes are already launched or in development, and earlier this year the Remote Gambling Association was tasked with developing and implementing the online scheme.
• This action requires the completion of this work and increasing the levels of awareness of self-exclusion schemes among gamblers, advice agencies and others so as to improve effectiveness.

Priority action 8: Education to prevent gambling-related harm –

• This action calls for better understanding of the effectiveness of steps that could be taken through education to minimise the risk of gambling-related harm.

Priority action 9: Building the quality and capacity of treatment –

• This action recommends continuation of effort to ensure that treatment for those that need it is as effective and welltargeted as possible.

Priority action 10: Widening and strengthening the research field and improving knowledge exchange –

• This action calls for greater effort to attract a wider range of researchers to fields of research relevant to this strategy.
• Crucial to success will be a demonstration of the independence and integrity of the commissioning process.

Priority action 11: Horizon scanning –

• This action recognises the need to understand how the gambling market, or factors which may affect it, are developing, and to identify emerging risks.

Priority action 12: Public engagement –

• This action calls for more effort to obtain the views of gamblers when developing initiatives designed to reduce gamblingrelated harm.

Next steps

The Board states that it is more “confident” about progressing responsible gambling and moving forward in a constructive way than it was three years ago, in part because of the changed behaviour of many in the industry. “Success will require sustained and unequivocal effort by all concerned…[a]ction has to take place in a measured way.” It will be important to monitor progress so that as change happens, it is possible to reflect and establish what does and does not work, and implementation can respond flexibly and appropriately.

“The most important next step for all stakeholders, including those that do not yet fully recognise the role they could and should be playing in this area, is to reflect on their own plans, assess the extent to which those plans measure up to the principles, objectives and priority actions set out in this strategy and make any necessary adjustments,” it has stated.

Problem gambling is a public health issue that affects our society. We must all share the responsibility to minimise the harm caused by gambling and we must not wait for others to take the lead.