On 25 April 2019, the Gambling Commission (the “Commission”) launched its three-year National Strategy to Reduce Gambling Harms (the “Strategy”). The Strategy will bring together health bodies, charities, regulators and businesses to reduce the harms caused by gambling.
William Moyes, chairman of the Commission commented:
This new strategy will provide us and our partners the opportunity to make faster progress to reduce gambling harms…The success of this strategy relies on everyone working together to reduce gambling harms through prevention and education, and treatment and support. Everyone has a role to play to combat gambling harms and I’m delighted that the health sector, charities and businesses are showing their commitment to get behind the strategy and make it a success”.
The Strategy identifies two priority areas:
- Prevention and education
This focuses on progressing towards a clear prevention and education plan with appropriate methods of intervention at population and individual level. It is intended that such methods will include:
- universal measures for the benefit of the whole population, including improved regulatory requirements, point of sale safer gambling messaging, gambling campaigns and gambling management tools;
- selective measures for the benefit of at-risk groups, including targeted population safer gambling campaigns, workforce education programmes for relevant sectors and professionals and education programmes for children, young people and other vulnerable groups; and
- indicated measures for the benefit of at-risk individuals, including self-exclusion, financial gambling blocks, customer interaction and brief interventions and online support by frontline staff in treatment, healthcare, debt advice and other settings.
The Commission has also noted that it must develop a better understanding of the impact of prevention and education methods on reducing gambling harms and has, therefore, stated that part of this plan will include an analysis of the effectiveness of such methods. This will be used to further refine approaches to prevention and education.
- Treatment and support
This aims to ensure the delivery and accessibility of the right treatment and support for users and a better understanding of the efficacy of various treatment methods.
It is suggested that treatment services should include: access to a national helpline; individual treatment; group treatment and support; online treatment and support; residential treatment; peer support; and support for affected others.
In this regard, the NHS has committed to the ‘NHS England Long Term Plan’, which commits to an increase in mental health services for patients with gambling problems. As part of this, the NHS will expand specialist clinics and work with partners to tackle problems at their source.
An implementation plan detailing the Commission’s approach to development in these two areas will be released early on in the first year of the Strategy. However, the Commission has stated that the two priority areas are to be delivered in four distinct ways:
- Regulation and oversight – ensuring the adoption of best practices through regulatory frameworks;
- Collaboration – working with businesses and key organisations to encourage a safer gambling environment through developing and improving existing practice and identifying new ways to reduce gambling harms;
- Evaluation – evaluating the effectiveness of approaches to reduce gambling harms to produce an evidence base for the widespread adoption of effective measures; and
- Research to inform action – widening the research base and improving the links between research and policy through taking steps towards the creation of a central data repository and exploring the establishment of a national research centre.
Public Health England will also be conducting the first review of evidence on public health harms relating to gambling. The review will look at the range and scale of gambling harms and identify the impact of gambling on people’s health and wellbeing.
The Strategy marks a further step towards regulation directed at the “harms” which problem gambling can cause and also gambling problems as a public health issue.
In particular, the Strategy focuses on safer gambling with the aim of reducing harms rather than the promotion of responsible gambling, a subtle but important change of focus. The Commission notes:
“Real progress requires all of us to change our mindset about the risks associated with gambling - we need to move away from solely counting problem gamblers towards understanding the harms that are being experienced, and ensure widespread adoption of measures that work to protect against those harms”.
This shift suggests that the Commission will be looking more closely at the level of harm caused by operators’ products and environments. A focus on harms is likely only to further the push for more stringent regulation, after all what level of “harms” as identified – if any - is acceptable? Equally, the focus on gambling problems as a public health issue may in time provide the political pretext for yet more taxation on the sector, so that the cost of health care is reimbursed. For the moment, though, these remain only theoretical.
Of more immediate significance, the Commission expects a combined effort across stakeholders to implement the Strategy. The Strategy is set out in broad terms and so provides limited direction to stakeholders seeking to support and deliver the strategy. Nevertheless, gambling operators will be expected to demonstrate how they are pursuing the strategy through raised standards in compliance, including evidence of ongoing trials and evaluation of safer gambling activities. This underscores that the Commission expects the industry to go above and beyond the strict letter of the Licence Conditions and Codes of Practice.
Finally, noting that the Strategy is dependent on sufficient and consistent funding, the Commission will support the implementation of a mandatory levy to support it.
A press release from the Commission about the Strategy can be accessed here.
A new website with further information on the Strategy can be accessed here.