Senet Group responds to UK Gambling Commission consultation on new National Responsible Gambling Strategy

Senet Group, the UK responsible gambling body, publishes its response to the UK Gambling Commission’s consultation on the new National Responsible Gambling Strategy, that will come into force from April 2019. The three-year national strategy, which will focus on reducing gambling harms, will require the collective effort of a wide range of stakeholders, in particular gambling operators and those at the forefront of customer engagement.

In its submission, the Senet Group emphasised the following points in relation to the draft strategy published by the Commission:

– Senet welcomes the proposed reduction in the number of strategic priority areas from the previous twelve to five in the new Strategy. This will provide greater clarity and focus on the shared objectives across the industry.

– Senet has called for an additional stage to be built into the strategy, to identify and clarify the desired outcomes associated with the key strategic themes. Without clearly articulated goals, it becomes difficult to assess progress or to focus cross-industry collaboration and action.

– Senet notes the change in the central aims of the strategy to focus on reducing gambling harms and that the definition of those harms will be assumed to be diverse and potentially long term, affecting resources, relationships, health and wider communities. Senet cautions that this approach should not undermine the importance of individual accountability as recognised in psychological research, and that the Commission might look to other sectors, such as alcohol regulation, where too wide a definition of harm has made it difficult to assess the impact of reduction strategies, due to other correlating factors and co-morbidities.

– Senet believes that the collective engagement of businesses across the entire Strategy will be vital, and for that reason proposes that the Commission’s strategic pillar named ‘Gambling Businesses’ be re-named ‘Collaboration’. Senet supports the Gambling Commission’s call for more effective cross- industry collaboration and believes that the customer insight business has to offer will be critical to ensuring that harm reduction strategies have the necessary operational and customer behavioural context to succeed.

– Senet supports the development of an industry data repository, but its recent experience in leading a data collaboration project would suggest that this is a complex challenge, where the comparability of data will necessitate clear research objectives.

The UK Gambling Commission is also conducting a formal consultation on Section 24 of the Gambling Act 2005, which relates to proposed amendments to the Licence Conditions and Codes of Practice (LCCP). Under these proposals, only accredited or approved organisations would be considered for funding towards Research, Education and Treatment (RET). The proposed approval process anticipates an independence provision, which will require organisations to demonstrate their independence from gambling operators. It’s not clear in the proposals what the independence test requires, and in Senet’s view, this approach could become a barrier to delivering the new strategy if too few organisations meet the independence test.

Senet has therefore strongly recommended that the Commission takes the opportunity to widen the basis of approved status to include ‘RET projects, campaigns or programmes’ that are clearly defined, adopt the evaluation protocols and deliver in support of the Strategy. This would unlock huge potential to get large scale programmes designed and implemented with multiple delivery partners, rather than create more bottlenecks and pressure on too few organisations.

Commenting on the submission, Gillian Wilmot, Chairman of the Senet Group, said:

“Elements of the gambling industry have contributed to an environment of mistrust and frustration in recent years, and delivery against the Commission’s objectives in the last three-year strategy has not been sufficiently coordinated across operators. However, companies are now making unprecedented efforts to reduce harms, and it’s critical that the customer insight and interaction they bring is put to good use in ensuring that harm reduction solutions have the operational context necessary to succeed and be implemented speedily.”