Redaction of identity and address verification documents

Request

1. Does the UK Gambling Commission (UKGC) require licensed operators to accept only fully unredacted identity and address verification documents?
2. Does the UKGC permit customers to submit partially redacted documents where all necessary verification details (name, address, date of birth) remain visible?
3. Is there any formal UKGC policy or guidance document that states gambling operators must reject identity documents that have non-essential details (such as licence numbers or bank transactions) redacted?
4. Has the UKGC ever issued guidance or regulatory action against operators for accepting redacted identity documents?

Please provide any official documentation, policies, or regulatory notices that clarify the UKGC's stance on the acceptance of redacted identity documents.

Response

Thank you for your request which has been processed under the Freedom of Information Act 2000 (FOIA).

In your email you have requested:

1. Does the UK Gambling Commission (UKGC) require licensed operators to accept only fully unredacted identity and address verification documents?
2. Does the UKGC permit customers to submit partially redacted documents where all necessary verification details (name, address, date of birth) remain visible?
3. Is there any formal UKGC policy or guidance document that states gambling operators must reject identity documents that have non-essential details (such as licence numbers or bank transactions) redacted?
4. Has the UKGC ever issued guidance or regulatory action against operators for accepting redacted identity documents?

For identity verification by remote (online gambling) operators, we have not specified any policy or any expectations in respect of redacted documents. The response to our consultation on age and identity verification for remote gambling, published February 2019, outlines our position.

Our Licence Conditions and Codes of Practice (LCCP) were amended as a result of that consultation. Licence Condition 17 states what remote operators must do in respect of customer identity verification, while social responsibility codes 3.2.11 (remote operators except lotteries) and 3.2.13 (remote lotteries) outline the requirements in respect of age verification.

Operators must comply with licence conditions and social responsibility codes, as a condition of their operating licence.

For age verification by non-remote gambling operators, our social responsibility codes provide some specific requirements in respect of identity documents.

For non-remote casinos, Social Responsibility Code 3.2.1 requires the following in respect of a casino supervisor:

A supervisor must implement the following procedures:

a. checking the age of customers who appear to be, or are suspected of being, underage

b. refusing entry to anyone unable to produce an acceptable form of identification, for example one which

• contains a photograph from which the individual can be identified
• states the individual’s date of birth
• is valid
• is legible and shows no signs of tampering or reproduction

There are similar requirements for other types of non-remote operator. Social Responsibility code 3.2.3 for adult gaming centre operators, social responsibility code 3.2.5 for bingo and facility entrainment centre operators, and social responsibility code 3.2.7 for betting operators require the following:

Licensees must only accept identification which:

• contains a photograph from which the individual can be identified
• states the individual’s date of birth
• is valid
• is legible and has no visible signs of tampering or reproduction.

Review of the decision

If you are unhappy with the service you have received in relation to your Freedom of Information request you are entitled to an internal review of our decision. You should write to FOI Team, Gambling Commission, 4th floor, Victoria Square House, Victoria Square, Birmingham, B2 4BP or by reply to this email. 

Please note, internal review requests should be made within 40 working days of the initial response. Requests made outside this timeframe will not be processed.

If you are not content with the outcome of our review, you may then apply directly to the Information Commissioner (ICO) for a decision. Generally, the ICO cannot make a decision unless you have already exhausted the review procedure provided by the Gambling Commission. 

It should be noted that if you wish to raise a complaint with the ICO about the Commission’s handling of your request for information, then you are required to do so within six weeks of receiving your final response or last substantive contact with us.

The ICO can be contacted at: The Information Commissioner’s Office (opens in a new tab), Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.

Information Management Team
Gambling Commission