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Unreasonable behaviour policy

1. Summary

The Gambling Commission is committed to providing a professional, fair, and efficient service. It is important that we can communicate effectively with everyone who contacts us. We therefore do not normally limit the contact that people have with us.

We recognise that some people may struggle to communicate with us, due to disability or other reasons, and where this is the case, we will make all reasonable adjustments to ensure access to our services. Furthermore, we understand that people may contact us at times when they feel angry, upset, or distressed.

When individuals contact the Gambling Commission to make enquiries, provide information or raise a complaint, we believe that they should be listened to by staff, should be understood, and should be given an opportunity to explain their case or query. In return, we expect those who contact us to behave appropriately and to treat our employees with courtesy, consideration, and respect, to allow them to carry out their work.

The Commission has a duty of care to those who work at the Commission to ensure that there are clear and effective processes in place to handle instances of unacceptable behaviour from those who contact us.

This policy enables us to deal with unacceptable behaviour by people who contact the Commission. It sets out what we consider to be unacceptable and outlines the steps we may take to deal with such behaviour. It applies to everyone who contacts us.

2. What behaviours are unacceptable?

It is difficult to produce a comprehensive list of actions that would be considered unacceptable, but examples are given under these two broad headings:

Aggressive and/or abusive behaviour

This consists of behaviour (written or verbal) that we consider might cause employees to feel intimidated, humiliated, offended, bullied, or harassed. For example (not an exhaustive list):

  • threats
  • abuse
  • offensive language which is disparaging against any individual or group based on any protected characteristic listed in section 4 of the Equality Act 2010 (opens in a new tab)
  • derogatory remarks
  • offensive language
  • rudeness
  • making inflammatory statements
  • raising unreasonable and unsubstantiated allegations
  • derogatory, abusive, or insulting comments made about Commission staff online or in the media
  • harassing, abusing, or threatening Commission staff on their personal social networks.

Some of the behaviours outlined are unlawful and we will consider whether these should be formally reported to the police.

Unreasonable demands and communication

Individuals may make unreasonable demands on the Commission through the amount of information they seek, the nature and scale of the service expected, or the volume of correspondence generated. Examples may include:

  • requesting responses in unreasonable timescales
  • insisting on speaking with certain members of staff
  • adopting a "capture-all" approach by contacting many staff members and third parties
  • repeatedly copying the Commission in to emails with other parties or sending copies of information which has already been provided.

Communication may be considered unreasonable if, for example, individuals:

  • continually contact us while we are in the process of looking at a matter
  • make a number of approaches about the same matter without raising new issues
  • refuse to accept a decision made where explanations for the decision have been given
  • refuse to accept and/or follow the Commission’s procedures
  • continue to pursue complaints/issues which have already been investigated and determined
  • continue to raise unfounded or new complaints arising from the same set of facts
  • refuse to accept that certain issues are not within the Commission’s scope/remit or powers
  • continue to contact us repeatedly about the same or similar issues when we are unable to add any further information to that which has already been provided.

We accept that persistence is not necessarily a form of unacceptable behaviour. What amounts to unreasonable demands will depend on the circumstances of the complaint and the seriousness of the issues raised.

However, individuals who will not accept a decision taken in relation to their query, or persistently contact us about the same issue, can generate unreasonable demands, taking up a disproportionate amount of the Commission’s time and resources. This can affect our ability to provide a service to other members of the public.

3. How we will manage unacceptable behaviour

If we consider that someone’s behaviour is unacceptable, we will tell them why and ask them to change it. If that behaviour, or other unacceptable behaviour continues, we will issue a warning. This will include deciding whether to restrict the person’s contact with us. This covers all forms of communication, including verbal, written and social media.

Any staff member who directly experiences threats or verbal abuse has the authority to deal with that immediately, including ending that communication. In most cases we would expect the staff member to provide a warning about the behaviour and explain

the reasons they consider it unacceptable. However, if the behaviour is extreme and potentially threatens the safety or welfare of our staff, then we have the option of informing the police or other body without notifying the person. In these circumstances, the Commission may issue a warning and a proportionate restriction at the same time, if appropriate.

In all other cases, where we experience unacceptable behaviour, we will only consider restricting communication with someone if we have already given them a warning and an opportunity to change their behaviour. We will explain why we consider the behaviour to be unacceptable and how we want the person to communicate with us.

If we do decide that we need to manage how a person can communicate with us, then the action we take may include, but is not limited to, any or all of the following:

  • contact may be limited to being conducted in writing only
  • contact may be limited to a specified number of times per month
  • contact may be limited to a specific individual within the Commission
  • contact may be limited to a specific email address or telephone number within the Commission
  • we may restrict the issues that we will communicate about
  • correspondence may be logged but not acknowledged or responded to
  • we may block social media users and remove social media comments from Commission channels in line with our Social Media House Rules. We may also report activity to social media platforms where it breaches their codes of conduct, and/or the relevant authorities.

The precise nature of the unacceptable behaviour, action taken, and the length of any restriction imposed should be appropriate and proportionate to the nature and frequency of the person’s contact with us at that time. The above list is not exhaustive as each case is determined on its own merit. Restrictions will be tailored to the required circumstances, taking into consideration any reasonable adjustments.

A decision to restrict someone’s contact with us can be made by a member of Commission staff nominated by the CEO (Chief Executive Officer).

On occasions we may consider a person’s behaviour is vexatious or unreasonable when making a Freedom of Information request or Subject Access Request. In these circumstances, we will follow the guidance provided by the Information Commissioner’s Office (ICO) (opens in a new tab).

4. Recording and reviewing decisions

If we decide to restrict access, we will be transparent and inform the person concerned in writing where possible. We will explain why the decision has been made, how it affects future contact with us, how long any restrictions will last and what the person can do to have the decision reviewed.

We will keep accurate and up to date details of all people who fall within the scope of this policy. The information that we hold on each case will include the details of the case, the action that has been taken and the reasons why the action was deemed appropriate and proportionate.

Information about contact restrictions will be shared with Commission staff on a need-to-know basis. Details will be shared to the relevant teams who deal with correspondence from members of the public, and to individual staff where they have previously been contacted by a person who is the subject of a restriction.

We will reconsider all restrictions in place at the end of the restriction period. Should we decide to alter the restriction, we will update the Commission staff who have been informed of the restriction and inform the person subject to the restriction. Any additional unacceptable behaviour encountered will then follow this policy. In these circumstances, we may decide not to issue a further warning, but instead put in place immediate further restrictions as are appropriate and proportionate.

If someone wishes to challenge our use of this policy, then they can do so by raising a complaint about our service. The complaint will be reviewed at Stage Two of the Commission Complaints Policy by someone other than the person who applied the restriction. If they decide to revise the restriction, then our records will be updated, and the person will be informed.

August 2021

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