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Consultation response

Changes to information requirements in the LCCP, regulatory returns, official statistics, and related matters

Parts I and II of the consultation response that sets out our position in relation to the information the Gambling Commission requires licensees to provide us.

Contents


Proposal 14: Changes to code 3.2.1, 3.2.3, 3.2.5 and 3.2.7 (access to gambling by children and young persons)

Proposal

We proposed to amend social responsibility codes 3.2.1, 3.2.3, 3.2.5 and 3.2.7 (access to gambling by children’s and young persons). We do not currently specify the form or manner of reporting test purchasing results. Consequently, there is a broad variety of formats in the data submissions we receive. This makes it difficult for us to collate and analyse those results, and therefore to evaluate the effectiveness of policies and procedures to prevent underage gambling. We are planning to develop a standard format for the reporting of test purchase results, which we will publish for further informal consultation with relevant licensees in due course.

Consultation question

Question 1.14. Do you agree with the proposed changes to the code provisions?

Respondents' views

The proposal to amend these four social responsibility code provisions to allow us to standardise the reporting of test purchasing was widely supported. There was agreement on the need to ensure the protection of children and young people, and the role of test purchasing in doing this. Several respondents added that standardisation of reporting would enable better quality quantitative data to be produced on the scale and effectiveness of test purchasing.

There were requests that the standardised form or manner should be designed with industry participation (including third party testing providers). It was also suggested that:

  • different formats may be required for specific sectors
  • the reporting process be semi-automated (for example a system which allowed licensees to upload a standardised Comma-Separated Values (CSV) file) to avoid the administrative burden of manual data entry
  • that test purchasing be conducted by a third-party supplier, rather than by a licensee, to enhance the integrity of the process.

Our position

We have not yet designed the standardised format but commit to including representatives from the gambling industry, third-party age verification testing providers and local authorities in the design process. We acknowledge that different formats may be required for specific sectors.

In respect of collection systems, we similarly want to design an approach which is proportionate. We do intend to set-up either a semi-automated system (for example a CSV file upload), an automated system (for example using an Application Programming Interface (API)), or both, but interim arrangements may be required while we build these systems.

Any further changes to test purchasing arrangements are outside the scope of this consultation.

Where licensees do not comply with these social responsibility code provisions, or allow a child or young person to gamble, we will act in accordance with the principles contained within our Licensing, compliance and enforcement under the Gambling Act 2005: policy statement (opens in new tab).

The following changes will take effect from 31 October 2020.

Final wording of amended social responsibility code 3.2.1, 3.2.3, 3.2.5 and 3.2.7 (access to gambling by children’s and young persons)

Social responsibility code provision 3.2.1
Access to gambling by children and young persons – casinos SR code
All non-remote casino licences

1 - 8 [No change]

9 Licensees must conduct test purchasing or take part in collective test purchasing programmes as a means of providing reasonable assurance that they have effective policies and procedures to prevent underage gambling, and must provide their test purchase results to the Commission, in such form or manner as the Commission may from time to time specify.

Social responsibility code provision 3.2.3
Access to gambling by children and young persons – AGC SR code
All adult gaming centre licences

1 - 7 [No change]

8 Licensees in fee category C or higher must conduct test purchasing or take part in collective test purchasing programmes, as a means of providing reasonable assurance that they have effective policies and procedures to prevent underage gambling, and must provide their test purchase results to the Commission, in such form or manner as the Commission may from time to time specify.

Social responsibility code provision 3.2.5
Access to gambling by children and young persons – bingo and FEC SR code
All non-remote bingo and family entertainment centre licences

1 -6 [No change]

7 Licensees in fee category C or higher must conduct test purchasing or take part in collective test purchasing programmes, as a means of providing reasonable assurance that they have effective policies and procedures to prevent underage gambling, and must provide their test purchase results to the Commission, in such form or manner as the Commission may from time to time specify.

Social responsibility code provision 3.2.7
Access to gambling by children and young persons – betting SR code
Paragraphs 1, 2 and 4 - 7: all non-remote betting and remote betting intermediary (trading rooms only) licences
Paragraph 3: all non-remote betting licences (except general betting (limited) licences) and remote betting intermediary (trading rooms only) licences
Paragraph 8: non-remote pool betting licences
Paragraph 9: non-remote general betting (standard) licences in fee category C or above

1 - 8 [No change]

9 Licensees must conduct test purchasing or take part in collective test purchasing programmes, as a means of providing reasonable assurance that they have effective policies and procedures to prevent underage gambling, and must provide their test purchase results to the Commission, in such form or manner as the Commission may from time to time specify.

Previous section
Proposal 13: Changes to licence condition 15.3.1 (general and regulatory returns)
Next section
Proposal 15: Changes to social responsibility code provision 6.1.1 (complaints and disputes)
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