Hospice Lotteries Association Conference 2024 - Sarah Gardner speech
13 September 2024
This speech was delivered by deputy chief executive Sarah Gardner at the Hospice Lotteries Association Conference on 12 September 2024.
Please note: This is the speech as drafted and may slightly differ from the delivered version.
Hello, thank you for that introduction and thank you everyone for being here today. I would also like to start by saying well done to your new Chair, Trudi Ogden and the team on what has clearly been a successful Conference this week. Now I appreciate we are in the last session of the Conference and there is not much that now stands between you, lunch and the trip home so I understand the last thing many of you will want now is too much information from the regulator! Happily though, I am sure many of you have already spent some time in the excellent workshops run by my colleagues, Claire, Louise and Joanne during the conference. They do a really brilliant job both for us at the Commission and for all of you in the sector, so I am sure they will have covered all the critical detail you need to know. If you have not yet had chance, their last session is coming up before lunch so I would really recommend that. For all their hard work this week and all year round, the team have my thanks - and I am sure yours too.
Now as those of you who were able to join those workshops know, the Gambling Commission, as the regulator for gambling across Great Britain, works with Local Authorities to regulate the Lotteries like yours as well as the wider Society Lotteries sector. So having the chance to be with you here today and give you an update is really valuable.
So what will I be talking about today? Well it has been a busy few years in gambling across Great Britain. Following the publication of the 2023 Gambling Act Review White Paper in we have made great progress getting on with its implementation. So I will give you an update on that and pull out some of the most important points for your sector. I will also update on some other changes the Commission has recently introduced that impact on your organisations too. Looking further ahead I will touch on how the Commission sees the years ahead and how we are preparing for those in our new Corporate Strategy. This happily leads on to the importance we place on our relationships with you and how that can foster collaboration going forwards. And of course, I look forward to your questions later as well. But first I thought I would briefly reflect on what our statistics are saying about the sector today.
And before I do, I should point out that the statistics I am about to share are from the first annual report we have ever published using our new methodology for participation and prevalence data. We are calling the new methodology the Gambling Survey for Great Britain (GSGB) and I will talk a little more about that in a moment. But first the stats.
The Annual Report published data from the GSGB – as we of course have started to call it – which was conducted using a push-to-web approach, with data collected from 9,804 adults aged 18 years and older living in Great Britain. Fieldwork was carried out between July 2023 and February 2024, consisting of two waves. The headline rate from the Annual Report, of overall participation in any gambling activity in the last 4 weeks was 48 percent. And interestingly, especially for everyone in this room, the most commonly reported activities after the National Lottery of which 31 percent of people had participated, buying tickets for other charity lotteries like yours was second on 16 percent and buying scratchcards third on 13 percent. So the products that all of you are providing and in turn raising funds for good causes are some of the most popular ways for people up and down the country to gamble. And of course that covers the mix of lotteries you offer. Draw-based tickets make up the majority when we look at society lotteries as a whole, though this is mostly now through remote means and largely online. 14 percent of people buy a draw-based game ticket from society lotteries remotely whilst 6 percent buy one physically, either in person or by post.
These statistics tell us the important story of the society lotteries sector across Great Britain and who is playing them. We also for the first time, due to the scale of GSGB, have numbers for participation by nation and region across the country as well. Which when we consider the importance of your role in our communities I think is really fascinating. I will talk more about your role in a few moments but I just wanted to dwell on the GSGB before I move on.
First of all, if you find this type of thing interesting, I would encourage you to go and have a look at the data on our website. For the first time we have been able to dig into the impacts of gambling – both positive and negative – beyond the headline figures and combined with our evolving Consumer Voice research it will make a really powerful tool for us in the years ahead. This is a new methodology though and so although the Annual Report contains our official statistics for gambling, all the numbers within the Annual Report are a new baseline. They can not be compared to what has come before. What is more, next years' Annual Report will be bigger again, with around 20,000 respondents. That will make it the biggest participation and prevalence survey of its kind in the world and an even more important source of data on gambling for not just the Commission but for the wider sector, including you too.
Some of you though may have heard of some disquiet from some commentators about it and may have picked up on some arguing the Commission has acted rashly in adopting the new methodology. If you have I want to reassure you that this is not the case. The GSGB started its development via a consultation all the way back in December 2020. Since then, over the years that have passed since then, we have invested significant resources - money, people and time – and worked alongside experts in the field, to develop the best consumer gambling survey that we can. Through our stakeholder engagement we have also made sure to keep industry, those with lived experience, academics and policy makers and others informed at every step of the journey.
The GSGB is the largest and most detailed survey of its kind in the world today and the depth of information it will deliver will allow us to have a better understanding of gambling than ever before. And that covers both the range of products offered – including lotteries – the reasons people play and the impacts that gambling has. To satisfy ourselves that we had done everything we could to do this right, we commissioned an independent review of the methodology by a leading expert, Professor Patrick Sturgis of London School of Economics and this was published in February this year. Professor Sturgis has some key recommendations for the Commission to consider to ensure the quality and robustness of the statistics continues to build confidence and I can assure you, we will deliver against those.
The Commission is pleased he has described our work developing this methodology as ‘exemplary in all respects’ and we agree with him that persisting with the former approach is no longer viable. But we also note the risks he identified in having a new methodology and the caution that should be applied when seeking to draw precise conclusions, including the potential for the over-reporting of participation and prevalence of harms as the survey is refined over time.
But to be clear as I and other colleagues have been this year already, there is no turning back the clock on how we gather this data and it would be wrong to think otherwise. Professor Sturgis makes clear, previous methodologies are no longer delivering like they used to. So if you have heard some ask the question ‘why now?’ the answer is that it is simply not credible to persist with a methodology that was outdated and had the gaps in evidence we have experienced. We are clear: the Commission has taken the steps we have in order to both safeguard and improve our data and we will continue to do so. Because better data and better evidence will mean better regulation and better outcomes. Not just for consumers, but for organisations like you and the good causes you raise money for.
Which brings me back to the importance of your work. This data clearly tells us, as I said earlier, just how important your lotteries are to the good causes you raise money for and the communities you support. Alongside the National Lottery, Society Lotteries raise significant amounts for good causes up and down the country and you all should be recognised for your efforts and for the public good your work leads to, year in and year out. Whilst we don’t monitor the totals for smaller society lotteries, it’s worth pointing out that in the year to March 2023, large Society Lotteries raised £421.7 million for good causes. That is slightly up on the year before and a 14.6 percent increase on the last pre-pandemic stats we have.
But none of this can be taken for granted. In order to continue to play the positive role in our communities that you do, the public needs to retain confidence in you and the rules that govern your work. And those rules need to keep up with the world we live in – however much or fast it changes at times. The Commission of course has an important role in that, as the national regulator for the lotteries sector. Likewise, the Gambling Act Review that was kicked off back in 2020 and the White Paper that was published last year is something that impacts all of you as well. So let me tell you a bit more about where we are with it.
Now it has not been a quiet year for politics of course but as you would expect, the Commission continues to work closely with Department for Culture, Media and Sport (DCMS) on a whole range of topics and areas and that will not change going forwards. The Gambling Act Review White Paper was a far-reaching piece of work that looked at every part of the gambling sector in Great Britain. As a result, its implementation will take time, especially true when there are so many recommendations. It is also fundamental to our approach at the Commission that where we have to consult on changes to our rulebook, that we take any and all consultation responses into consideration before making changes. But that has not stopped us making significant progress in the 18 months since the White Paper was published, including on things that matter to your organisations.
The first round of consultations that the Commission published last Summer received a huge response, which took time to analyse. But at the start of May, we published our responses to them. For those of you who somehow do not avidly check our website every day for news on Gambling Commission consultations, a quick recap of what that first round covered. The areas consulted on were:
Financial risk and vulnerability
Remote games design
Improving consumer choice on direct marketing
Strengthening age verification in premises
Personal management licences.
Now whilst much of this won’t be of direct concern for your organisations, the consultations did have the potential to have an impact on you. The most significant one being the consultation topic on direct marketing. Our consultation topic on direct marketing, or cross-selling, has led to us announcing measures designed to make gambling businesses provide customers with options to opt-in to the product type they are interested in receiving and the channels through which they wish to receive marketing. The aim is to empower customers by giving them more control over the direct gambling marketing they wish to receive and ensure they do not receive marketing that they do not want.
This is a good moment to highlight how consultation responses matter too. Originally, we included land-based and lotteries sectors in these changes. But we had significant and well evidenced responses through the consultation from these sectors regarding why the changes would not have been the right action at this time. Specifically, for the lotteries sector we received feedback that it would seriously impact their ability to raise vital funds and retain customers and would have limited impact given the narrow range of gambling products, leading to little need for society lotteries to ‘cross-sell’ in the first place. Given the complexities faced by such operators and our focus on the remote gambling marketing, we therefore decided we will not include land-based gambling and the lottery sectors in scope of this requirement.
Now this does not mean that the Gambling Act Review contains nothing else for you and your organisations to pay attention to. I know my colleagues have covered other areas in the workshops at this Conference already – and again you have one last chance to attend their workshop if you have not already! And the Commission will continue to keep you notified on any matters that we progress that will have an impact. And we know there are important areas that interest you that sit with Government. Whilst the responsibility for reviewing Free Draws and Prize Competitions sits with DCMS, as do work on the proposed Statutory Levy and Ombudsman, we will of course continue to support the Department as required.
Before I move on from regulatory changes, I also wanted to highlight one area where, whilst not actually a Gambling Act Review topic, the Commission has rolled out changes that matter to you. And that is the area of our Regulatory Returns.
Regulatory Returns are the core data that all of you, as organisations that provide gambling under a Commission licence, have to provide to us each year. For Society Lotteries it sits alongside the data from lottery submissions. Earlier this year we announced we are moving to collect this data quarterly from all operators instead of the previous set up that only asked for data annually for many operators. Whilst we have heard the feedback that may create more work for you we have, we have also heard the view from some of you here that it can be easier to pull this data together on a more frequent basis. If nothing else, that goes to prove that a regulator can not please all of the people all of the time! So where we have ended up on this is that while we concluded the quarterly frequency was important, at the same time we also reduced the number of questions many operators have to answer. So more returns but less to return. These changes came into force on the 1 July 2024 for all licensees.
What this means is that the first set of quarterly regulatory returns – those relating to the quarterly return period 1 July 2024 to 30 September 2024 - must be submitted by all licensees by 28 October 2024. If this is somehow new information to you or any of you hearing this today have any questions, please do ask us about it. Either today with me and the team, or you can get in touch with us through our website. We want to help you get this right, and it is vital for our work that we do, so do speak up if you have any questions or issues.
We want to support you with getting things right. Especially when we are all going through a time of change. And that is something we have been doing quite a bit of thinking about alongside what our place looks like in a changing and digital world. This is reflected in our Corporate Strategy, titled ‘Gambling Regulation in a Digital Age’ which was published back in April.
Our Corporate Strategy, which sets out our strategy through to 2027, presents a series of commitments under the following areas of strategic focus. They are:
using data and analytics to make gambling regulation more effective
enhancing our core operational functions
setting clear evidence-based requirements for licensees
being proactive and addressing issues at the earliest opportunity
regulating a successful National Lottery.
All of this of course go along side continuing to deliver our core regulatory work over the next three years as well. One other important aspect of the new strategy is how our approach to stakeholder engagement runs throughout the strategy. As does our commitment to transparency as well. A key point that the Corporate Strategy has a focus on, that demonstrates the importance of this is our work to tackling illegal gambling. Everyone at the Commission understands how unfair competition that the lotteries sector faces from illegal lotteries online and on social media sites, is a concern to everyone here. And clamping down on these is definitely a part of our work in this space.
And I can explain this with some numbers. In 2023 the Commission issued 452 cease and desist and disruption notices. This included 291 cease and desists notices to illegal websites and 161 referred to Facebook for closure, resulting in 212 instances where supply was disrupted (79 online websites and 133 Facebook closures). Running alongside using our own powers, we also work closely with stakeholders to deliver results. One important example is our work with His Majesty's Revenue and Customs (HMRC). The close working relationship we have with them means that where we have been tackling illegal Facebook lotteries, not only has this seen those lotteries shut down by the Gambling Commission, but the organisers have found themselves paying £600K in penalties to HMRC as well. I think this demonstrates the impact we can have by working collaboratively with stakeholders, including all of you.
Delivering on the commitments set out in the Strategy between now and 2027, will ensure that we improve the way we work to ensure gambling is safer, fairer and crime-free for the benefit of consumers, the wider public, and licensees. And we look forward to working with all of you on that where the society lotteries sector has a role to play as well.
The Gambling Commission is your national regulator. But I hope in what I have discussed today, you agree with me that this does not mean we have to have a confrontational approach to each other most of the time. The rules we set and your work to comply with them helps keep public confidence in your work. This helps deliver for the good causes you support. And through the work we have planned: implementing the 2023 White Paper, our own Corporate Strategy and day to day work with the sector, we can make gambling safer, fairer and crime free. But we need your help. Staying compliant with our rules yes but also keeping us informed on your work and the threats and innovations you see. And we want to keep engaging with you too and together we can make sure you keep delivering for your communities.
Thank you.
Last updated: 17 September 2024
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