Local risk assessments update
At the end of 2016 we undertook a number of visits to assess how operators were embedding two social responsibility codes which came into force in April 2016:
- the requirement for premises to undertake a local risk assessment
- the requirement to participate in a multi-operator self-exclusion scheme.
Feedback on the findings in relation to how effectively the self-exclusion scheme has been implemented will be shared separately.
In respect of local risk assessments we undertook a dip sample of nearly 70 operators across the betting, bingo, casino and arcade sectors, involving over 100 premises in total throughout Great Britain.
The findings were mixed and highlighted that both operators and licensing authorities are still adjusting to this new requirement and that in many cases further work is required for it to become a useful means of mitigating the local risks to the licensing objectives.
Visits to gambling premises
The findings from this exercise varied but in particular we found that in a large number of premises the local risk assessment was held at the head office not on the premises, and the local staff were both unfamiliar with it and had not been involved in its preparation. Where it was held at head office, it had to be sent through to the premises on request either at the time of the visit or subsequently.
This pattern was found in both large and smaller operators although the risk assessment was more likely to be held on the premises and staff involved in its production in smaller operators. We also noted that staff in (smaller) operators that were not part of a trade body were typically unfamiliar with local risk assessments. In a number of instances staff viewed the local risk assessment as a managerial tool only, rather than something they might have a role in developing and maintaining. We would encourage operators to ensure premises staff play an active role in the development and ongoing maintenance of risk assessments as they will be most familiar with the local area and potential risk factors.
We did not dwell on the content of the risk assessment itself in any detail during our visits as it is the local licensing authority who is best placed to comment on whether the relevant local risks have been addressed. However, it was evident in relation to a number of operators that the content was generic for each premises, irrespective of location, and that little reference had been made to the local landscape. Again operators are encouraged to better reflect the local landscape by involving local staff, taking in to account information in the local Statement of Policy and/or having a discussion with the LA.
We acknowledge that both operators and licensing authorities are still adjusting to this new requirement. We have shared with LAs a number of examples where councils have set out their expectations for local risk assessments, and identified local risks in their Statements of Policy which we hope will encourage other councils to consider including more information when they next update their statements. The Local Government Association is similarly encouraging LAs to consider the local risks in the form of a local area profile which will help operators ensure their local risk assessments address all premises-specific concerns.
Local risk assessments are intended to be live documents and will need to revisited and refreshed on a premises by premises basis as local circumstances change. Operators are encouraged to engage with the relevant LA when updating a premises risk assessment to discuss their expectations about the assessment and to be more reflective of the local risks, rather than just including the companywide policies and procedures in relation to the licensing objectives.