The Responsible Gambling Strategy Board’s advice on the National Strategy to Reduce Gambling Harms 2019–2022
Part 1: Introduction and executive summary
Gambling, and the extent of the harms associated with it, is a significant public health issue for Great Britain. There has been some progress in tackling it in recent years, but not enough. We need a new, more robust approach.
We therefore welcome the Gambling Commission’s assumption of responsibility for the new National Strategy to Reduce Gambling Harms.
We believe that the chances of successful outcomes for the new strategy are greater than for its predecessors, for three main reasons:
- the Gambling Commission has resources, influence and enforcement powers to help facilitate action
- public opinion appears to be hardening towards gambling1
- while many have struggled fully to embed safer gambling into their corporate cultures,2 recent fines, other regulatory settlements and threatened action on personal licences3 have led to increased recognition among operators that doing nothing is no longer an option.
The new strategy should be built on twin pillars of prevention and treatment, supported by an effective research programme. The traditional terminology of research, education and treatment (RET) risks too narrow a focus. Prevention is much broader than education alone.
A new approach
Aim: Reduce gambling-related harms
Prevention and treatment are both supported by effective delivery of research, evaluation, and an implementation plan.
If it is to be successful, the new strategy will also need to:
- have greater focus, with fewer priorities
- adopt as its main objective the reduction of gambling-related harms, including those experienced by family, friends and others adversely affected by a gambler’s behaviour
- use a different mindset and terminology. Terms such as ‘problem gambling’ and ‘responsible gambling’ serve to diminish the severity of the issue. They also imply that fault rests solely or mainly with the individual. We know that to be far from the case
- take a more systematic and directive approach to implementation
- ensure that ownership of treatment and prevention is firmly taken by those best placed to exercise it.
Ten main recommendations about the new strategy are summarised in the following paragraphs. Many build on advice we have given previously. Others reflect activities already under consideration. We believe all work with the grain of the Gambling Commission’s three-year corporate strategy.4
Gambling is increasingly recognised as a public health issue. Recognition needs to be followed through with effective action. Gambling should be addressed in the same way as other significant public health issues – with a coherent strategy using a continuum of interventions, including some at population level, and more explicit recognition of the influences of product and environment as well as individual circumstances
We should stop making clear distinctions between ‘problem’ gamblers, those ‘at risk’ and other gamblers. There is a continuum of harm; and different people can move in and out of harm at different times.
The new strategy needs clear ownership and accountability. The Gambling Commission has both an appetite to address gambling-related harms and ability to address them. But if a continuum of prevention and treatment actions are to be brought to bear in a coherent way across Great Britain, a range of government departments and agencies need to take overall responsibility for their part of the strategy, with co-ordination from the centre.
Responsibility for the provision and quality assurance of treatment should rest with GB health departments, not, as at present, with a charity funded by voluntary donations. This will require a compulsory levy with a strong and transparent structure for the distribution of funds raised. The greater emphasis in the new NHS England Long Term Plan5 on mental health (including the need to address gambling-related harms) provides an important opportunity. The implications of a change in responsibility are complex and need to be thought through carefully. An Expert Review Group should be appointed to review how best to achieve the change and make recommendations, including how to channel funding.
The strategy requires a coherent framework of prevention initiatives. In the short-term, the Gambling Commission is well placed to oversee action from the gambling industry. But ideally ownership should be taken by GB governments, who have the greatest ability to co-ordinate action from the wide range of stakeholders necessary to implement an effective approach. Particular focus should be on those population groups at higher risk of harm, with awareness that the different characteristics of each group may require different approaches. The strategy also needs to recognise the potential importance of families and peers, supporting them in protective behaviour and helping them avoid adverse impacts from their own behaviour.
Too much emphasis on voluntary action by operators is unlikely to achieve the desired impact, or pace. The Gambling Commission needs to continue to be more active in giving guidance and leadership on, for example, interventions to be piloted or implemented more widely.
We need a further major push to embed a culture of evaluation in both prevention and treatment, focusing on impact and not just process. The Gambling Commission should review the steps already taken and identify what further could be done to explain good evaluation practice to operators, create more opportunities for independent evaluation of safer gambling initiatives and develop opportunities to share findings between operators and others. The Gambling Commission and Government should lead by example in evaluating the impact of policy and regulatory changes affecting gambling.
There are significant concerns about the potential impact of gambling advertising and marketing on vulnerable groups, particularly children and young adults. There should be further consideration of appropriate controls, applying the precautionary principle and drawing on evidence from the marketing of products like alcohol and tobacco.
The Gambling Commission should take responsibility for the commissioning of the research necessary to underpin the strategy, and resource itself accordingly. The commissioning of other research relevant to gambling should be undertaken by an arms-length body.
A compulsory levy on the industry should be introduced to replace the present voluntary arrangements and fund prevention, treatment and underpinning research on a greater scale, with a strong and transparent structure for the distribution of the funds raised.
1The proportion of people who believe gambling is ‘conducted fairly and can be trusted’ has reduced from 48.8% in 2008 to 33% in 2017. Among people who have gambled in the past twelve months, the proportion reduced from 60.7% to 37.5%. Although in 2017, the majority (64%) of people still supported the statement ‘people should have the right to gamble whenever they want’, 80% thought ‘there are too many opportunities to gamble nowadays’, 71% believed it is ‘dangerous for family life’, and 57% thought ‘gambling should be discouraged’. Only 15% supported the statement ‘on balance, gambling is good for society’ Gambling participation in 2017: behaviour, attitudes and awareness, Gambling Commission, February 2018.
3 Gambling Commission takes widespread regulatory action against online casino operators and senior management, Gambling Commission, November 2018
5 NHS Long Term Plan, NHS, January 2019
Structure of this advice Next section
Part 2: The extent of the problem and lessons learnt
Last updated: 8 September 2021
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