Tackling gambling related harm: A whole council approach

Harmful gambling is increasingly cited as a public health issue which requires a broad response; that is to say, traditional approaches that focus on single interventions do not tend to work at a population level.

Community safety

Licences, regulations and trading standards

19 Oct 2023

LGA

10.71

Foreword

There is increasing awareness about the harms that can be caused by gambling and its impact on families and local communities, as well as the individuals directly affected by it. The prevalence of high street gambling premises; the significant increase in gambling advertising since the introduction of the Gambling Act in 2005; and the rise in online gambling have all contributed to societal concern about gambling in the UK and the harm that can be associated with it.

Gambling related harms are now widely recognised as a public health issue which require a broad response. Harmful gambling is a complex problem with many different but often interlinked factors - no single measure is likely to be effective on its own in addressing it.

Consequently, many organisations have a part to play in addressing the harms caused by gambling, not least the gambling industry itself. There are several ways in which councils can try to prevent and support those individuals and families who are experiencing harm from gambling and reduce population exposure to gambling. This is in addition to their statutory licensing responsibility to try to prevent local gambling premises causing harm through their products or practices. There are, however, often limited resources available for gambling harm prevention interventions at a local level, however relatively low-cost interventions can have a significant impact.

For example, councils will be coming into contact with people negatively impacted by gambling through a range of services, including housing and homelessness, financial inclusion, children’s services and addiction services. Yet few councils have data on where harmful gambling has been a contributory or additional factor in these cases. This leads to a lack of understanding about the needs of our communities, and we are therefore less able to prevent and address gambling related harms, or to take full advantage of the support that is available to those affected by harmful gambling through the third sector and NHS led treatment system.

Having the support of elected members and the chief executive in changing our understanding of harmful gambling and its impacts is vital. It sends a clear signal that addressing harmful gambling is a priority, not just for public health and licensing but across the whole council and its wider stakeholders, thereby facilitating cooperation across departments and with local communities and partners.

In 2018 the LGA and Public Health England developed this document to provide an overview of harmful gambling and how councils can try to help local residents who are impacted by it. This updated version reflects the advances that have been made in tackling gambling related harm and supporting those affected by it in the five years since. Despite this progress, we know from our work on two of the LGA’s policy boards that this issue remains of concern to councillor colleagues up and down the country, and that there is still more to do. We hope you find this guidance useful in understanding how councils can strengthen their work in this area.

Cllr Heather Kidd
Chair, LGA Safer and Stronger Communities Board

Cllr David Fothergill
Chair, LGA Community Wellbeing Board

Executive summary

'Harmful gambling’ is an umbrella term to describe any frequency of gambling that results in people experiencing harm. Gambling products can be very addictive, and widespread persuasive marketing and advertising can have negative impacts. Harmful gambling can impact on an individual’s physical and mental health, relationships, housing and finances, and affect a wide range of people, such as families, colleagues, employers and wider local communities.

Gambling industry voices tend to frame gambling as being a harmless leisure activity that is a personal choice and something individuals should enjoy ‘responsibly.’ They do not focus on the addictive and harmful products and practices used by gambling operators to maximise profits. This can lead to narratives which suggest the individual experiencing harm is a ‘problem’, and this stigma often leads to gambling harms being hidden.

Whilst anyone can be negatively affected by gambling related harms, harms are not distributed equally. Increased exposure can make certain people more vulnerable to the harms caused by gambling, for example: children and young people, people with mental health issues, homeless people, and those living in deprived areas. Often operators specifically target these groups, for example by locating premises in the most deprived areas.

Research, education and treatment of harmful gambling is primarily commissioned and delivered by the Gambling Commission, GambleAware, and the NHS. Because of GambleAware’s role in distributing voluntary industry donations, some stakeholders have expressed concern about potential conflicts of interest due to the potential influence of the gambling industry, although GambleAware emphasise the steps they have taken to ensure their independence.

Councils are not responsible for providing treatment for harmful gambling, but there are a range of ways in which different services can support people into the right treatment and support, including embedding knowledge and awareness of gambling within existing services, giving it parity of esteem with other issues- such as alcohol or substance misuse- and setting the tone of how gambling is discussed within a local area.

District and unitary (licensing) authorities have a statutory role regulating local gambling premises and various tools to try to prevent gambling related harm occurring in premises: developing maps highlighting locally specific gambling risks; preparing local licensing policies setting out expectations of gambling businesses, and undertaking compliance visits to assess whether they are meeting these expectations. This activity is funded through the fees licensing authorities charge for licences. Planning teams can also play an important role in relation to local gambling premises through the council’s Local Plan.

Gambling may also be driving demand for other council service areas, including children’s, family and adult social services, treatment and early intervention services, homelessness and wider housing services and financial inclusion and debt advice services.

Councils should ensure that frontline staff are provided with training so they can have conversations about gambling harms, raise awareness and support people to access help such as the NHS gambling treatment clinics. Councils can also seek to work with local partners and build links with support organisations to help develop specific local referral pathways and ensure these can be accessed from across the full range of local services. As frontline awareness and identification of the harms that can be caused by gambling develops, councils should ensure they capture data about it, to help understand the extent of harmful gambling, impacts and costs associated with it.

Public health teams can play a role in ensuring that this data, and related data on groups who may be at an elevated risk of gambling related harms, is collected and shared. They can also work with local partners in the community and voluntary sector, and through integrated care boards and integrated care partnerships, to develop a coherent approach to harmful gambling, including focused preventative work. Crucially, councils and public health leads can also have an important role in reframing how gambling harms are described and leading effective communications on this issue to challenge stigma and negative perceptions relating to gambling harm, as this stigma can prevent people from talking about their gambling or seeking help.

The Gambling Act 2005

The Gambling Act 2005 underpins the legislative approach to betting and gambling in the UK. The Act changed the underlying approach to gambling from permitting but not encouraging it, to increasing the opportunities for adults to gamble, and treating it as a leisure activity. This significantly liberalised the gambling regime, for example, by enabling gambling operators to advertise across all media platforms and creating an ‘aim to permit’ new gambling premises. These changes, coupled with technological advances, have led to significant increases in gambling participation and gambling related harms.

In 2023, the Government published the Gambling Act Review White Paper which sets out the Government’s plans for reforming gambling legislation. The changes proposed by the White Paper are referred to throughout this guidance.

Understanding gambling related harms

Since the first version of this guidance was published, the evidence base on harmful gambling has increased. In 2021 Public Health England published a comprehensive gambling-related harms evidence review, which we refer to throughout this section. This research will be a helpful tool for councils to build the case around why a public health approach to gambling is required, as well as providing guidance on gaps in knowledge and how to deal with these. We are also expecting further comprehensive research on ‘harmful gambling: identification, assessment and management’ to be published by the National Institute for Health and Care Excellence in spring 2024, and this will also be helpful to councils when published.

However, it is important to note that while this research was a comprehensive review, it was only able to review the evidence available. Because of issues with gambling not being considered through a public health lens until relatively recently and a lack of independent funding, there is a dearth of UK data/evidence on the broader social and environmental factors and the full extent of the harms experienced (especially in terms of financial harms). Councils can therefore play an important role by ensuring they improve data gathering relating to gambling whenever possible to grow the UK evidence base.

Definitions of harmful gambling

'Harmful gambling’ is an umbrella term to describe any frequency of gambling that results in people experiencing harm. It includes those gambling at elevated risk of harm (low risk and moderate risk in the screening tools) as well as those experiencing ‘problem’ gambling. Gambling related harm is a broad concept that impacts a wide range of people, including families, colleagues, employers, and those within the wider community who may not have been involved in gambling themselves. Harms may include financial hardship, relationship breakdown, domestic abuse, mental health problems and suicidal thoughts.

It is important to note that anyone can be negatively affected by gambling. Gambling behaviours occur along a continuum, with possible harms dependent on the level of exposure. Research shows that there are features of some gambling products which make them more addictive, like continuous play.

Research has highlighted the importance of language when discussing gambling harms. Councils should be mindful of this when discussing gambling harms and avoid stigmatising language, which can include terms like 'problem gambler' and 'gambling addict.' Stigmatising terms can lead to narratives of the individual experiencing harms as the 'problem' rather than them ‘having’ a problem or illness, caused by the practices and products of the gambling industry. It is therefore important to ensure services do not shame or blame people who gamble and use first-person language in research and campaigns to highlight that gambling disorders are mental disorders, not an identity. Tackling Gambling Stigma has produced a number of different resources which councils may find helpful. Other research has stressed the importance of carefully examining narratives that seek to portray the individual as the problem, rather than looking at the harmful effects of gambling products, industry practices and gambling environments.

Prevalence of harmful gambling

The Gambling Commission’s most recent survey on gambling participation found that, in the year to March 2023, overall participation in any gambling activity was 44 per cent. The survey also found that 0.3 per cent of people experience ‘problem’ gambling and that the rate of those gambling at a moderate level of risk is 1.2 per cent and low level of risk is 1.8 per cent. Councils should also note that 0.9 per cent of young people experience ‘problem’ gambling and 2.4 per cent experience gambling at elevated levels of risk. Due to limitations in how this data is collated, it is likely these estimates are conservative, and may not capture some vulnerable population groups such as homeless people and students. A YouGov (2020) survey found that approximately 3.6 million (7 per cent) adults and children in Great Britain are negatively affected by someone else’s gambling.

Research also shows that gambling harms are not equally distributed across England and that certain areas experience higher rates of harmful gambling, with the North West and North East having the highest prevalence of at-risk gamblers, while the South West has the lowest prevalence.

Analysis by Public Health England in 2021 suggested that whilst the highest rates of gambling participation are among people who have higher academic qualifications, people who are employed, and among relatively less deprived groups, the socio-demographic profile of gamblers appears to change as gambling risk increases, with harmful gambling associated with people who are unemployed and among people living in more deprived areas. The analysis found that the National Lottery is the most common type of gambling across all age groups, except among younger people where scratch cards are more common. Football pools and electronic gaming machines are more common among people under 35 years of age compared with older age groups. Men are also more likely to gamble than women, and this difference is most obvious for online gambling where 15 per cent of men participate, compared to 4 per cent of women.

Circumstances which can increase the risk of gambling related harm

Harmful gambling often involves participation in seven or more types of gambling, such as online gambling, casino and bingo games, electronic gambling machines in bookmakers, sports and other event betting, betting exchanges and dog racing. Anyone can be negatively affected by gambling related harms, whether directly or indirectly. Consequently, councils should seek to prevent exposure at a population level to harmful gambling products and practices. However, some individuals may find certain circumstances, such as mental ill health or economic circumstances, are worsened by gambling, and this can widen inequalities as harmful products and practices are being targeted at those least able to withstand the harms.

In 2015-16, Westminster City Council commissioned Geofutures to undertake a literature review to ascertain what characteristics, activities or groups could be at greater risk to gambling related harm and to use that information to create a gambling vulnerability index for the city. The results were published in two reports in 2016. Since then, a number of other research studies have been undertaken into the impact of gambling on groups that may be more vulnerable to the harms caused by gambling. For example, a 2023 study estimates that at least one in ten homeless people experience clinically significant ‘problem’ gambling or a gambling disorder. As a result, Westminster has revised the gambling vulnerability index devised by Geofutures to take account of new findings and more recent data on the resident population and services within the city that may indicate at risk groups. The key at risks groups or behaviours are set out below:

Young people
unemployed and constrained economic circumstance
area deprivation
homeless
mental ill health
substance abuse/misuse
personality traits/cognitive distortions
people experiencing gambling harms who are seeking treatment.

Further detail on these findings can be seen within the Council’s Local Area Profile, as well as their statement of principles, which we discuss in further detail in the ‘licensing authority function’ section below.

Councils may also be interested in the work of GambleAware and University College London, who have produced maps of Great Britain which estimate gambling harm prevalence in each local authority and parliamentary constituency area, as well as usage of and reported demand for treatment and support for gambling harms. In addition, a map showing Index of Multiple deprivation (IMD) across GB has been created to compare against gambling prevalence, as well as a map showing where National Gambling Support Network providers operate and their contact information.

Impact of harmful gambling

The harm that gambling can cause often extends beyond the individual who is directly affected. Research from YouGov suggests that the most severe impacts of harmful gambling were felt most by immediate family members whose physical, mental and emotional health and wellbeing may be severely affected. Almost half (48 per cent) of people who were affected by a spouse or partner’s gambling reported a severe negative impact. This was followed by people affected by the gambling of a parent (41 per cent) and the gambling of a child (38 per cent). In some cases, gambling harm can impact across local communities (for example, where harmful gambling is associated with crime or homelessness) and society as a whole (in terms of the costs that may be created by harmful gambling).

Individuals experiencing harms from gambling, or their families or carers, rarely present to health or social care services with harmful gambling as their presenting condition, and it can manifest in a range of different ways, including physical and mental health problems, relationship breakdowns as well as social care and financial issues. These can include:

Health	Relationship	Social and financial resources
heart palpitations sleep disturbances/insomnia increased blood pressure headaches anxiety / depression self-harm and suicidality substance misuse feelings of stigma/ shame.	domestic abuse relationship difficulties and breakdown loss of trust loneliness social isolation neglect/ abandonment anti-social behaviour.	poor concentration money issues / debts housing issues work or school problems reduced productivity criminality use of food banks.

The relationship between gambling and suicides or suicidality has received much research attention in recent years. Review studies have mapped the quantitative occurrence of suicide attempts, suicides, and self-harm among gamblers, and found a positive association, particularly among younger people. While suicide is generally multi-faceted and influenced by various factors, it is evident that gambling can be a prominent contributor, playing a pivotal role in some cases without which the suicide would not have occurred. Councils should therefore consider the potential links between their work to tackle gambling related harms and suicide prevention to ensure services are joined up and frontline staff are able to signpost to support. By acknowledging and addressing the connection between gambling, suicide, and contributing risk factors such as debt, homelessness, deteriorating relationships, family dysfunction and poor mental health, councils can enhance the provision of support for people experiencing gambling related harms. The Gambling Act Review has pledged to impose a specific reporting requirement on gambling licensees to notify the Gambling Commission if they become aware of a customer’s suicide, even if there is not an obvious link to their gambling.

The upcoming Suicide Prevention Strategy is an opportunity for central government to obtain cross departmental and cross sector support to ensure that the harms of gambling are intrinsically linked to suicide prevention going forward and that DHSC, DCMS and the Gambling Commission deliver stronger messaging in this area. As part of the new Suicide Prevention Strategy, central government should announce a continuation of funding for local suicide prevention plans as the NHS Long Term Fund approaches the end of its final year.

OHID research from 2023 on the economic cost of gambling related harms estimates that the annual economic burden of harmful gambling is approximately between £1.05 – 1.77 billion. £412.9 million of this economic burden is a direct cost to government, however this is likely to be an underestimate due to a lack of available evidence. At the council level, there is a need to develop an understanding of the scale and nature of gambling and the harms and costs that are directly associated with this. Manchester City Council has estimated that the economic burden of gambling in Manchester was around £15.3m in 2022 (£9.59m direct costs plus £5.71m in further societal costs).

Framework for prevention and support for gambling related harms

National approach to tackling and preventing gambling related harm

Policy responsibility for gambling primarily rests with the Department for Culture, Media and Sport (DCMS) at government level, however there is some cross-government engagement, with departments such as the Department of Health and Social Care (DHSC) being involved in treatment of gambling related harms. Additionally, regional branches of the Office for Health Improvement and Disparities also take an active interest in tackling gambling related harms, with some working closely with councils and Directors of Public Health.

The Gambling Commission is an independent non-departmental public body sponsored by DCMS, that was set up under the Gambling Act 2005 to regulate commercial gambling in Great Britain in partnership with licensing authorities. Its work is funded by fees set by DCMS and paid by the organisations and individuals they license, and, in respect of National Lottery functions, by a grant from the National Lottery Distribution Fund. The Commission’s strategic objectives for 2021-2024 focus on protecting children and vulnerable people from being harmed by gambling, a fairer market and more informed consumers, and keeping crime out of gambling.

GambleAware is a UK wide charity which commissions research, education and a national treatment service to help minimise gambling-related harm. The organisation is wholly funded via voluntary donations and regulatory settlements in lieu of fines from the gambling industry, and as such, this has led to significant concern amongst some stakeholders about potential conflicts of interest. However, given GambleAware’s significant role in treatment in particular, it is important to reflect their role on this issue. Observers from DCMS and the Gambling Commission attend all meetings of GambleAware’s Board, and for several years GambleAware has had no gambling industry representatives on their boards of trustees.

The NHS also has a crucial role and has established a number of specialist clinics which have significantly increased the amount of treatment available to support those experiencing gambling related harms. More information can be found on their website.

The Gambling Act applies the ‘polluter pays’ principle, and as such, the gambling industry provides voluntary donations to GambleAware. All gambling operators are required by the conditions of their licence to make a donation towards research, education and treatment and this is enforced by the Gambling Commission, but the amount they donate is ultimately up to them. The suggested donation is 0.1 per cent of profits, and in 2022, the industry donated £34.7 million. The Gambling Act Review pledged to reform the voluntary system and introduce a mandatory levy, something the LGA has long called for to fund a significant expansion of research and treatment. However, it should be noted that some public health colleagues are not in favour of a mandatory levy because, for example, they do not think it will reduce harms or guarantee independence of funding. The statutory levy paid by operators will be collected and distributed by the Gambling Commission under the direction and approval of HM Treasury and DCMS ministers. The amount of the levy will be determined by a consultation. At the time of writing, it is not clear when the mandatory levy will be introduced.

In recent years, the Gambling Commission has taken a more active role in commissioning research using funding secured from regulatory settlements. This funding is secured from regulatory action against an operator that has breached its licence conditions, and where the Commission has decided to accept a payment in lieu of the financial penalty. The Commission will then distribute this funding to projects that align with its strategy.

Research

Historically there have been challenges associated with researching gambling related harms. Some academics and public health stakeholders have expressed concern that industry funded research has resulted in a gambling evidence base that is narrow in scope, methodologically weak, and that focuses on problematising individuals while deflecting attention from harmful products, industry practices, and the effects of gambling liberalisation.

However, over recent years, this has started to change with the Behavioural Insights Team and the National Institute for Health and Care Research now undertaking research in this field, alongside several universities who have established research groups looking at gambling, including the University of Glasgow, the University of Bristol, the University of Lincoln, the London School of Hygiene and Tropical Medicine, the University of Birmingham, and others.

The Gambling Act Review has also pledged to introduce several welcome and important changes to how research on gambling related harms is conducted. In addition to introducing a mandatory levy on gambling operators to pay for research, education and treatment, the Government will also co-host workshops with UK Research and Innovation (UKRI), Innovate UK and Research England, to stimulate interest and investment in gambling research. This aims to build capacity and start filling the key evidence gaps identified by PHE’s evidence review. The Gambling Commission will also consider how operator data could be made available in anonymised form for use by researchers and following a review of its fees in 2024, the Commission will also take an enhanced role in directly commissioning research to inform regulation based on its ongoing assessment of regulatory priorities to prevent harm.

If councils would like to access data sets on gambling, the best source of information is the data collected by the Health Survey for England, which describes gambling participation and the prevalence of at-risk and harmful gambling. The Gambling Commission also has a range of statistics and research which may be of interest to councils. Additionally, gambling related harms will feature in the Adult Psychiatric Morbidity Survey, a survey undertaken by NHS Digital, and councils can also access the gambling treatment framework statistics.

Councils can also help with expanding the evidence base on gambling related harm, and should ensure they capture data about it, to help understand the extent of harmful gambling, impacts and costs associated with it. It is good practice to build data collection into any local projects exploring gambling related harms.

Education

There are many initiatives which seek to prevent gambling harms through educating young people. These programmes aim to support young people to understand the facts about gambling and gaming, how the industry works, and to help them to build their critical thinking skills and avoid harm. However, councils should note that some stakeholders believe some education programmes reproduce the 'responsible gambling' agenda, while problematising children and young people and deflecting from the harmful nature of gambling products, as well as there being a lack of robust evaluation to assess the effectiveness of education programmes.

Nevertheless, there are a number of different initiatives which councils may be interested in. For example:

Gambling With Lives is currently piloting an education programme that is aimed at preventing gambling harm in young people by raising awareness of the risks of engaging with harmful gambling products. The materials provided by the programme are based on academic research into what’s successful in education and awareness-raising in drugs, tobacco, and alcohol programmes. The programme focuses on how addictive products are designed and the methods and impact of gambling industry marketing practices. Crucially, the materials make clear that gambling disorder is a clinically diagnosable mental health condition. The programme has been designed to run as a four-part lesson and is being piloted at schools across England and Northern Ireland before potentially being rolled out across the UK.
GambleAware has developed a Gambling Education Hub Service across England and Wales which aims to help reduce gambling harms among young people. This programme includes toolkits, training and peer-based theatre performances.
There may also be some local education programmes taking place in your area. For example, in Greater Manchester, Gambling with Lives worked with Lancashire Cricket Foundation and the Greater Manchester gambling harm reduction programme to deliver a lived experience-led education and awareness programme for young people aged 14-16 in Trafford, Manchester and Salford. This programme supported 58 children.

Other programmes are aimed at frontline staff, such as those delivered by the charity GamCare. Alongside the treatment services GamCare provides (detailed below), they also deliver training to frontline organisations who in the course of their work may come into contact with people affected by gambling related harms, including youth facing professionals; housing workers; people working in the criminal justice system, and for sports clubs and organisations. GamCare is also engaged in outreach programmes working directly with young people to build critical thinking and resilience around issues relating to gambling.

Councils may also be interested in a project led by the Beacon Counselling Trust which has developed a ‘Workplace Charter’, which seeks to reduce harms in the workplace from gambling through education, support and referral to treatment. Wigan Council has signed up to the charter to support its employees who may be negatively affected by gambling.

University of Bristol researchers tested whether existing 'responsible gambling' messages, such as ‘when the fun stops, stop’ work and designed and tested possible alternatives. They found existing 'safer gambling' messages raise awareness but are ineffective and do not change the behaviour of people who gamble. This research highlights the need to destigmatise gambling harms, and that messages should aim to produce a positive emotional response and avoid evoking negative emotions such as shame. For those at risk of harms, messaging should signal ways to identify signs of harmful gambling and it is also important that messages are provided for people affected by someone else’s gambling. Councils may find this research useful when designing local gambling education campaigns.

Many stakeholders are concerned about the conflict of interest that surrounds the industry being responsible for promoting ‘safer gambling messages’ whilst simultaneously trying to promote its products. Consequently, the Gambling Act Review has pledged that DHSC, DCMS and the Gambling Commission will work together, drawing on public health and social marketing expertise, to develop a robust approach to informational messaging throughout the user journey, replacing industry owned safer gambling messaging. Once appropriate campaigns and messaging are developed, the Commission will consult on further requirements for gambling operators to engage with and apply the new messaging appropriately alongside product-based information in order to inform and empower consumers.

Treatment

Currently treatment for gambling is provided through a network of NHS specialist gambling treatment services, fully funded by NHS England (NHSE), and through a network of third sector providers who are commissioned via Gambleaware.

NHS services

NHS England have committed to open 15 clinics by the end of 2023, which will ensure each region in England is represented by a specialist service. These clinics provide treatment for those experiencing the highest levels of harm and generally offer cognitive behavioural therapy, both one to one and in group settings, as well as more bespoke services to enable an individual to continue on their recovery journey. The services also provide help to people close to those with a gambling addiction, such as family, partners, and carers. Professionals can refer people experiencing gambling related harms into NHS services, but people can also self-refer directly into these clinics. As specialist NHS services, referrals are welcomed from any individual worried about their gambling, including those with other co-existing mental health needs, addictions or who have had previous treatment (through any provider) that has not been successful. The NHS Long Term Plan committed to invest in and expand NHS gambling clinics, so further clinics could be opened in the future. When all 15 clinics are open, the NHS hopes to treat 3,000 people a year.

NHS Services

There are currently four regions represented by eight NHS specialist gambling clinics currently in operation. These are:

The Northern Gambling Service with clinics in Leeds, Manchester and Newcastle. More information is available on Northern Gambling Service website. Contact number: 0300 3001490. Email:

[email protected]
The London Gambling service which also hosts the National Children and Young Persons Gambling and Gaming Clinic. More information can be found on The London Gambling Service Website. Contact number: 020 7381 7722. Email:

[email protected]
The West Midlands Gambling Service with clinics in Stoke on Trent and Telford. More information can be found the West Midlands Gambling Service website. Contact number: 0300 123 0996. Email:
[email protected]
The Southern Gambling Service with a clinic in Southampton. More information can be found on the Southern Gambling Service website. Email: [email protected]

These services are now fully funded by the NHS. This followed feedback from clinicians who were concerned about a perceived conflict of interest and some patients who felt uncomfortable receiving treatment funded by the gambling industry. Despite no longer receiving funding from GambleAware, the NHS is still working closely with GambleAware to ensure that there is an agreed referral criteria for service users who would benefit from treatment delivered by the NHS Specialist Gambling Clinics and a clear route back to community-based services that will support service users with their long-term recovery. In the future, this work will be supported by money raised through the statutory levy, which will ensure all those experiencing the varying degrees of gambling-related harms are able to access the support they need when they need it.

Case study: Greater Manchester Combined Authority (GMCA) and Gambling with Lives - Chapter One resource

Chapter One provides independent information, support, and training for anyone affected by gambling. This resource has been developed in partnership between the Greater Manchester Combined Authority (GMCA) and Gambling with Lives- a charity which supports families who have experienced gambling related suicides, with input from people of lived experience and clinical experts.

The access point to Chapter One is an online hub which facilitates access to and awareness of evidence-based treatment for those experiencing gambling related harms, as well as information, training, and tools for those supporting them. As part of this, users are also signposted to information and education on gambling that is free from gambling industry influence.

Chapter One is a response to a number of existing limitations in how local authorities tackle gambling related harms. These include frontline workers lacking the capacity or resources to effectively signpost to the full range and variety of support available to those experiencing gambling related harms, and those looking to support them; that existing hubs and sites are often unclear and unengaging; and the prevalence existing, industry-controlled narratives which obscure the causes of gambling addiction.

The approach of Chapter One is one which emphasises a holistic information offer to service users which is presented in a clear and engaging way: that information on support for yourself or others, and important information about the gambling industry are all crucial aspects of tackling gambling related harms, and therefore should all be clearly available in one place.

As part of its holistic approach, each section clearly contextualises itself within the wider picture of gambling and related harms. It emphasises dimensions of gambling related harms that are not typically explored by other services, particularly around clinical understandings of gambling’s adverse impact on the brain, in contrast to industry funded narratives which emphasise individual responsibility and contribute to stigma.

Future iterations of the Chapter One resource will include a section dedicated to professionals supporting individuals who may be experiencing harm because of gambling. This will include clear referral pathways, information, and resources to support someone within service and promotional materials to raise awareness of the risks and causes of gambling related harms.

Importantly, Chapter One is a service in which is informed solely by clinical expertise, and those with lived experience of gambling related harms. Its funding is derived from regulatory settlements from the Gambling Commission and is therefore free from gambling industry influence.

Third sector services

The third sector provision is the National Gambling Support Network (previously National Gambling Treatment Service or the ‘NGTS’) which is commissioned by GambleAware. Councils should note that the Gambling Act Review has pledged to introduce a statutory levy paid by operators and collected and distributed by the Gambling Commission under the direction and approval of HM Treasury and DCMS ministers. That places the future of Gambleaware in an uncertain position, given that the charity is funded by voluntary industry donations. As such, the system outlined below could change over the coming years.

The National Gambling Support Network (NGSN) is a network of third sector organisations, providing free, confidential support for people who gamble and for affected others. The network is funded by Gamcare who are commissioned by GambleAware. It has a specific focus on early intervention, adopts a regional-first approach, and also has clear referral routes which allow local providers to triage individuals into the treatment service that is right and appropriate for them. GamCare are a useful point of contact for local authorities interested in exploring harmful gambling and comprehensive information is also available on their website.

The National Gambling Helpline is generally the primary entry point into the third sector delivered gambling treatment service network, and many people can be helped through interventions offered by the Helpline’s advisers. The National Gambling Helpline is run by the charity GamCare and deals with more than 41,000 calls each year. It provides one to one information, advice and emotional support to callers: where needed, extended support via call backs can be offered by helpline advisers. The helpline will refer through to further support, however there are concerns that it does not sufficiently signpost to NHS services.

Councils may also be interested in the services provided by the Gordon Moody Association, which also provides specialist support for those experiencing high levels of gambling harms. The Gordon Moody Association is a charity providing residential treatment services for men aged 18 and above in Beckenham, Dudley, and Manchester. The residential treatment programme begins with an initial two-week assessment followed by 12 weeks of treatment and all clients live at the centre full time for the duration of their stay. In 2022, the Gordon Moody Association opened a residential treatment service for women in the West Midlands. They also run an international online support and advice service for problem gamblers through the Gambling Therapy website. There are also other charitable organisations offering similar support, which can be seen further down in this chapter.

As part of GambleAware’s commissioning intentions for 2022 and beyond, they have stated their intention to develop ‘regional alliances’ which will provide opportunities for councils and Integrated Care Systems (ICSs) to take a greater role in determining GambleAware’s future commissioning activity with the third sector. The regional alliances will also aim to integrate with local systems and support councils to understand what the NGSN is, how they can support people to access it, and how and where their services can work alongside it. This will help to ensure that service users are able to access the right service, at the right time.

Councils have an important role to play in implementing this work. This role has also been identified in a piece of work published in 2021 by Gambling with Lives which details what a joined-up pathway for harmful gambling could look like. Gambling with Lives is currently commencing the next phase of work, which will design a set of educational materials for health and social care system stakeholders including GPs, Citizens Advice Bureaus, mental health providers, and housing providers to inform them of the risks of gambling, who to refer to and provide access to the most appropriate screening tools. It also seeks to ensure frontline professionals across services are aware of gambling harm and how to effectively treat it, and to ensure councils are able to promote self-exclusion schemes.

Alongside the treatment and support funded through GambleAware and the NHS, other charities also provide support to people experiencing gambling related harm and those around them, some of which are listed below.

Gamblers Anonymous runs local support groups for people experiencing gambling harms and advocates the same 12-step approach to recovery as Alcoholics Anonymous. Gamblers Anonymous also offers help and support via their website, including a forum, chat room and literature. Anyone who is seeking help for harmful gambling is able to attend meetings.

Gam-Anon is an organisation dedicated to supporting the husbands, wives, partners, relatives or close friends of someone who gambles in a harmful way. Like Gamblers Anonymous, meetings are held throughout the country, with online support also available.

Betknowmore UK are a London based organisation working to raise awareness and deliver support services for people experiencing gambling harms and those around them. The support services are currently only available in London.

New Beginnings provides specialist support for women affected by gambling harms.

GamLEARN (the Gambling Lived Experience and Recovery Network) supports and empowers those who have experienced gambling related harm. Their services are free to access to those who are in active recovery, or an affected other.

GamFam are a lived experience charity which supports those affected by gambling related harms.

The debt charity, StepChange, offers support with any debt problems that may have arisen due to gambling.

Taking a public health approach to tackling gambling harms

Many councils are now taking a public health approach to tackling gambling harms, such as councils in Yorkshire and the Humber and Greater Manchester, and this is something the LGA fully supports. Councils may also be interested in the Australian City of Monash Council’s gambling policy, which explicitly takes a public health approach to tackling gambling harms and is well regarded amongst public health stakeholders.

A public health approach looks at issues from a societal rather than an individual level. It is a way of thinking and acting collectively to address a problem that can damage health and wellbeing, rather than seeing something through a single or narrow lens (for example, looking at something simply as a financial issue).

Public health approaches have successfully been applied to a range of other socially complex and long-standing problems, such as serious violence and alcohol related harm. They employ methods such as systems mapping and modelling using data, intelligence, research, evaluation and participatory methods to assess problems, inform interventions and increase opportunities for action to avoid or reduce health harm.

Generally a public health approach is led by public health teams and adopts a multi-agency approach across partners with similar goals, with a particular focus on prevention. The core principles of the approach are:

understanding the problem at a population level
framing the problem as part of a complex and interdependent system
collating data and evidence of what works
being prevention focused
protecting health and wellbeing
encouraging multi-agency working
addressing inequalities, social justice and human rights.

In relation to gambling, a public health approach can be defined as “one based on collective action to advance the public good by promoting health, equity, and social justice, and by adopting a broad and population-level perspective to gambling harms. Achieving this approach will, in part, require the public health community to engage fully with this issue, advancing counter-discourses to those that have become common, while recognising that policy and social change are complex and context-dependent.” The Faculty of Public Health and Association of Directors of Public Health have produced some recommended actions which could be adopted to enable councils to take a public health approach to tackling gambling harms.

As this document has highlighted, many council teams and services will come into contact with people experiencing gambling related harms. It is therefore crucial that councils are using all of the tools at their disposal to prevent gambling harms from occurring and ensuring that staff are trained and able to signpost people experiencing harms to support. Just as we have seen with tactics used by the tobacco industry, councils need to be cognisant of tactics that seek to undermine evidence and promote personal responsibility.

The role of public health teams

There is now widespread recognition that gambling related harms are public health issues and Public Health England’s (now the Office for Health Improvement and Disparities) evidence review will be a useful tool for councils seeking to evidence the need to develop a public health response to gambling harm. To deliver a public health approach, councils should ensure there is a partnership between public health and other council teams using national rules and regulations to their full advantage. However, the LGA is clear that a public health response does not equate to local public health funded services having a responsibility for providing treatment for gambling harms. Councils are not currently funded to provide support for individuals experiencing problems with gambling under the terms of the transfer of responsibility to local government in 2014 and are not a core part of the treatment framework outlined in an earlier section of this document.

Nevertheless, both local government and health services can do more to ensure that gambling related harms are prevented through careful consideration of contextual factors which can influence gambling and the potential harms it might cause (for example, by ensuring a council’s licensing policy or local plan is robust on gambling related harms issues) and to ensure that people experiencing harms from gambling are identified - whether through primary or secondary care, or through council services – and are signposted to support and treatment.

It is clear that public health teams can play a strategic role in relation to harmful gambling and should consider the overlaps between gambling harms and other local public health issues, given the high levels of comorbidity with mental health problems and the negative financial, health and relationship impacts of harmful gambling on the individual and those around them.

A number of local authorities have undertaken local reviews to understand the extent of gambling harm in their local area. For example, in 2022 the Greater Manchester Combined Authority published a strategic needs assessment which brings together the best available local and national evidence to describe the extent and impact of gambling related harms in Greater Manchester. Other examples include Devon County Council’s spotlight review to understand the extent of gambling harm in the county and Stockton’s Adult Social Care and Health Select Committee’s review which built a local evidence base on gambling harms. The Gambling Commission signposts to a list of resources which may help councils to build an evidence base on gambling harms in their area. However, when undertaking this work, councils should be mindful that any local review is likely to be an underestimate of levels of local gambling related harms because stigma and under-recognition of the risks and harms from gambling mean it is often under-reported and hidden.

Local public health teams can also engage with the issue by identifying and promoting local pathways of care and treatment provision, taking steps to tackle the stigma surrounding gambling related harms, and raising awareness of the issue. Public health teams can also help by promoting positive stories of recovery, which can be very effective, and councils should consider involving lived experience groups with this work. Taking such steps may support local residents to talk about any gambling related harms that they may be experiencing, which will help with tackling stigma. Councils may find the public health framework for gambling related harm reduction, produced by Directors of Public Health in Yorkshire and the Humber, particularly helpful.

It is important to increase public health team’s awareness of gambling related harms so they can support services to recognise the signs of harmful gambling, assess and signpost to appropriate support. The Royal Society of Public Health has produced resources (funded by Gambleaware) to support those working with members of the public to understand and better respond to gambling related harms.

The Gambling Commission has produced a briefing note on the issues where it believes public health can play a role, including supporting the licensing authorities with developing a statement of licensing policy (considered in the previous section) and working with local health professionals to increase awareness of the issue. Councils may also find research from 2022 on policies and interventions to reduce harmful gambling helpful. The research identified 40 universal and targeted measures to tackle harmful gambling, which they believe, if implemented, could substantially strengthen regulatory controls while providing new resources.

Case study: Task and Finish Group on Gambling Harms in Barnsley

It is becoming increasingly well recognised that harmful gambling is a public health issue associated with harms to individuals, their families, their friends, and wider society. However, due to the lack of local, regional and national data and the complexity of quantifying the metric of ‘gambling related harm’, it is often less understood in comparison to other public health issues such as smoking, obesity, or alcohol misuse.

As such, Barnsley Council’s Overview and Scrutiny Committee established a Gambling Task and Finish Group (TFG) to investigate gambling related harm in Barnsley. This included considering the key challenges around gambling and gambling related harm; the support services available in the borough and beyond; and what the future plans are in terms of this agenda.

The TFG met with Public Health, Licencing Officers, local agencies and organisations, the NHS, national charities, and service providers. As a result of their investigations, the TFG has developed 12 recommendations to support further improvement on this agenda. These recommendations will be a catalyst for action in Barnsley, with a focus on improving our understanding of the prevalence and degree of gambling, problem gambling and gambling related harm, raising awareness more broadly, maintaining regulation, and improving access to services.

What councils can do:

Contribute data and insight to the development of local area profiles to support licensing statements of policy.
Ensure public health teams are aware of gambling related harm and can support services to screen, assess and signpost to appropriate support.
Identify local organisations providing treatment and support to assist with signposting.
Identify appropriate referral pathways.
Work through integrated care boards and integrated care partnerships to develop a coherent approach to harmful gambling, include focused prevention work with potential high-risk groups.
Integrated care boards and integrated care partnerships should be encouraged to raise awareness of harmful gambling amongst primary care professionals and work with local authorities to signpost to local and national support services, as well as integrating externally commissioned treatment services into existing local services, for example, integration within Primary Care Networks.
Mental Health Service Providers should consider how they can best identify harmful gambling and provide access to specialist support, particularly for young people presenting through child and adolescent mental health services (CAMHS). .

How councils’ regulatory tools can help tackle gambling-related harm

All councils have a role to play in relation to harmful gambling. For example, county or unitary authorities may become involved through their public health teams, and different council services at both tiers of local government should have awareness of the issue of harmful gambling and potential interaction with their work. However, licensing authorities (district and unitary councils) also have a statutory role in regulating premises based gambling licensing.

Remote (online) gambling and non-remote gambling

Councils’ statutory role in gambling licensing applies to gambling in premises, referred to as non-remote gambling. Remote gambling is the legal term for gambling undertaken other than in a premises, typically over the internet and therefore more commonly known as online gambling. This is regulated by the Gambling Commission.

With the wide availability of smartphone usage, online gambling is now a core part of the overall gambling market. Gambling Commission statistics for 2022 show the proportion of people gambling online has significantly increased compared to the previous year, with the long-term trend continuing to show steady growth. Growth has been seen particularly for National Lottery draws and online slots and/or instant win games.

There is concern about the impact of online gambling in increasing the availability of gambling. While non-remote gambling is restricted by hours of opening, someone with a smartphone or other access to the internet can gamble at any hour of the day. This risk is exacerbated by game design which encourages continuous play, direct notifications, data harvesting, gambling incentives, ‘VIP’ schemes, direct marketing through email, advertising across several platforms including gaming websites and social media, and the ability to register accounts on multiple platforms. There are also specific challenges associated with applying under-age checks and self-exclusion measures to online gambling. GAMSTOP is a resource that has therefore been developed to help people restrict their online gambling.

The Gambling Act Review has proposed measures to safeguard against gambling related harms. These include online protections, such as player set deposit limits, stake limits, and background checks on individuals who may be experiencing gambling harms, as well as advertising protections, such as reviewing the targeting of free bets, giving customers greater control over the marketing they receive, and strengthening informational messaging on gambling harms, in a campaign that will be led by Government.

Councils’ regulatory role and the measures outlined in this section apply only to non-remote gambling. However subsequent sections of the document focusing on the steps that can be taken to prevent gambling related harm and support those experiencing it apply equally to harmful gambling issues linked to premises based or online gambling (or, for many people harmed by gambling, a combination of both).

Licensing authority functions

The LGA has produced a comprehensive guide to councils’ gambling licensing functions in our councillor handbook on gambling licensing; further guidance is also available in the Gambling Commission’s Guidance to Licensing Authorities. This document therefore provides a summary specific to harmful gambling: further resources are listed at the end of this guidance.

As with alcohol licensing, licensing authorities are:

required to develop an overarching statement of principles (referred to as the statement of policy) setting out how they will approach gambling regulation in their areas
responsible for issuing gambling premises licences, monitoring compliance with the terms of these licences and the wider Gambling Act, and taking enforcement action if necessary
required to have regard to the Gambling Act’s licensing objectives, one of which is protecting children and other vulnerable people from being harmed or exploited by gambling.

Licensing statement of policy, local area profile and risk assessments

The statement of policy and local area profile are intended to help prevent gambling related harm occurring. They provide an opportunity to set out the local approach to gambling regulation, expectations of gambling operators and specific local circumstances. Local area profiles should be separate to statement of licensing policy, so that they can be easily updated: a consultation process is required to update statements of policy, which are legally required to be updated every three years. Local area profiles are not a mandatory requirement, but the Gambling Commission and the LGA strongly encourage all licensing authorities to produce one.

The local area profile should identify different parts of the local area where there may be greater or specific risks of gambling related harm, whether because of: the people likely to be in that area (for example, where there is a treatment centre or hostel); the other types of businesses in the area (for example, in an area with a vibrant night time economy, or where there are already multiple gambling premises); or because of the characteristics of an area (for example, if there are pre-existing issues with anti-social behaviour or crime).

Authorities can draw on some of the existing research highlighted in the first section of this document to identify groups with higher levels of vulnerabilities due to their personal circumstances, coupled with their local knowledge of relevant issues and premises. This can help identify additional measures or protections that may need to be applied in those areas. For example, Leeds City Council’s statement of policy describes research undertaken on behalf of the authority into gambling related harm by Leeds Beckett University in 2016 and identifies those persons who may have increased vulnerability to gambling harm. It goes on to provide examples of measures that could be offered by applicants to mitigate harm, including measures such as reduced opening hours, training staff in gambling harm prevention, and outlining the amount and content of gambling harms support advertising that should be in the premises, including advertising of local treatment support.

To help develop their statements of policy, authorities should consult widely and with those who may have an insight or relevant data on any local risks or issues, including:

organisations working with people who are affected by gambling related harms, such as lived experience groups or local third sector organisations
advocacy organisations, such as the Citizen's Advice Bureau
homelessness and housing services / associations
local public and mental health teams and safeguarding boards
the police
local businesses
other tiers of local government, if applicable.

Licensing authorities may draw on GamCare data about the number of national helpline calls received from a specific area, or the numbers of people treated in certain areas (this information could be accessed from the national treatment framework, which is hosted by the University of Manchester, but would not include data on NHS services). However, as support services may be accessed anonymously these are unlikely to be fully comprehensive: the number of people seeking treatment locally may reflect awareness of its availability and the current map of local providers rather than the actual level of local need, and support services are poorly accessed at the moment, with people waiting, on average, for around ten years before seeking support. Licensing authorities may have access to other data which may suggest heightened vulnerability to gambling harms. For example, the council could have data which shows levels of deprivation in an area, the amount of looked after children, children with lower education attainment, youth offences, and alcohol related harm (such as numbers of people drinking at harmful levels, numbers of alcohol premises, levels of alcohol related crime, anti-social behaviour and alcohol related admissions to hospital).

Some licensing authorities have used mapping tools to help inform their local area profiles. For example, Westminster Council has produced an interactive map of the council’s Local Area Profile for gambling which highlights the groups who may be at heightened risk to gambling related harm, vulnerable locations and current gambling premises within the City.

Authorities should also use their statements of policy to identify what they expect gambling operators to do to uphold the licensing objectives. Gambling businesses are required to undertake risk assessments for each of their premises. These must take the statement of policy into account, so it is important that authorities use their policies to set clear guidelines for operators.

Risk assessments are not required to be shared with licensing authorities (unless a business is applying for a new premises licence or to vary an existing one) but authorities can ask to receive copies of them and can also require that they are kept on the relevant premises. This is a good way to check that the assessments are locally tailored and owned by premises managers rather than being a tick box exercise undertaken by regional or head office.

Some councils have published a blog which provides advice on how to scrutinise new gambling premises applications, which may be of interest.

Councils should note that the Gambling Act Review contains a commitment to consult on introducing cumulative impact assessments into gambling licensing legislation. Whilst the LGA would have preferred to abolish ‘the aim to permit’ altogether, the introduction of cumulative impact assessments will be a welcome development that the LGA has long called for. Cumulative impact assessments are used to regulate alcohol premises under the Licensing Act 2003 and are a tool which give councils greater scope to refuse an application for an alcohol licence in areas where there are concerns that the density of premises in a particular area is having a negative impact on the licensing objectives.

The white paper states councils will be required to identify high risk zones in their gambling licensing policy and local area profile, and that gambling applicants will need to prove they will not add to the risk of harms in a local area. A cumulative impact assessment will also create a presumption against granting new licences in areas where there is already a saturation of gambling premises. These changes will require amendments to primary legislation, and the Government is committed to doing this when parliamentary time allows.

Case study: Statement of principles for gambling in Westminster

The Fairer Westminster Strategy pledged to “adopt a gambling policy to protect vulnerable residents and visitors from gambling harm”. Consequently, Westminster’s 2022-2025 statement of principles for gambling provides greater clarity, detail and scope on what the council will consider when determining applications for new gambling premises and varying existing premises under the Act.

The new policy builds on the requirements for gambling operators to fully assess the associated risk of their gambling operation, which includes the premises, the gambling activity and its location on the licensing objectives under the Act. It includes new approaches that use the findings from the Local Area Profile for gambling risk in Westminster. Areas that the local area profile identifies as being at greatest risk of gambling harms have been designated as Gambling Vulnerability Zones. In these areas, new applications will receive a greater degree of scrutiny to ensure they are aligned with the principles of the Gambling Act and the council’s statement of policy. It also outlines a number of steps applicants will be expected to take to assess risks within their application for a licence, permit or other permission and mitigate against any harmful impacts. Existing operators will also be expected to review their gambling risk assessments and ensure that they have taken account of the Local Area Profile and the new policy.

Working with gambling businesses

Gambling operators must comply with the Gambling Commission’s licensing conditions and codes of practice (LCCP). The social responsibility code requires them to have and put into effect policies and procedures to promote socially responsible gambling: these should reduce the risk of and seek to identify harmful gambling. Licensing authorities should ensure that businesses are meeting these obligations and encourage them to strengthen their approaches to social responsibility.

The requirements on gambling premises under the social responsibility code are based upon key areas:

Provision of objective information about the protection and support available to people who gamble- for example, the availability of time / monetary limits for players, and information on where to get help and advice about gambling.
Customer interaction – licensees are required to have policies and procedures in place governing customer interaction where there are concerns that a customer is displaying signs of harmful gambling. These will include staff training, and the types of behaviour that may trigger an intervention or where staff may consider refusing services to customers. They should also have a log book which records any customer interaction that takes place, and council officers should be able to inspect this during premises inspections.
Layout of premises – operators must ensure that the layout of a gambling premises supports the effective supervision of the premises.
Self-exclusion - licensees must have procedures for self-exclusion that ensure that individuals who wish to self-exclude from gambling are prevented from participating in gambling. Self-exclusion schemes are now required to operate on a multi-operator basis, meaning that an individual who self-excludes from one operator should be able to self-exclude from all operators offering the same type of gambling in the same locality. Trade bodies for different sectors of the gambling industry have led on the development of multi-operator self-exclusion arrangements for each sector. In practice, self-exclusion can be complex and there can be loopholes which may enable an individual to continue gambling, even if a self-exclusion scheme is in place. The Gambling Act Review contains a commitment for Government to work with operators to strengthen these schemes.

Alongside the mandatory requirements, many sections of the industry have developed their own voluntary codes to promote ‘responsible gambling’, which local premises may also implement. GamCare also work with operators to provide certification which demonstrates the measures gambling businesses have in place to protect people from gambling-related harm. GamCare also provides training courses for industry to support staff to identify customers who may have an issue with gambling.

Licensing authorities can work proactively with local businesses to support them with their obligations in this area, or to encourage them to adopt best in class measures, for example by making this a requirement through the statement of policy or specific premises licensing conditions.

Additionally, a number of licensing authorities have worked with local gambling premises to develop Betwatch or other partnership / code of practice schemes. These are likely to have a wider focus than harmful gambling – for example, they may focus on reducing any anti-social behaviour associated with local premises – but can provide a useful forum for engaging with the industry and understanding any specific local work on harmful gambling. However, officers should be mindful of conflict-of-interest concerns when engaging with gambling businesses, and should scrutinise and be transparent about who they engage with.

Compliance and enforcement work

Licensing authorities should use their compliance and enforcement work to help ensure that local gambling premises are fulfilling their social responsibility requirements. Statements of policy must set out how authorities will exercise their inspection functions, including inspection activity (and what pre-planned visits will cover) and dealing with non-compliance by premises. There are a number of issues in relation to harmful gambling which authorities may wish to review during pre-planned or proactive compliance visits:

details of training policies and training undertaken by staff
records of refusals to serve or admit on age grounds
the premises’ approach to managing self-exclusion, how the premises fulfils the requirement to participate in multi-operator schemes and numbers of people currently self-excluded
involvement / impact of any work in local gambling or Betwatch schemes
confirming that appropriate signage and information is in place.

The Gambling Commission publishes information on licensing authority activity in this area. With some returns showing limited or no compliance and inspection work by authorities, it is encouraging authorities to be more active, for example through additional compliance visits or test purchasing operations.

Test purchasing

Many councils already operate their own underage test purchasing through trading standards and / or licensing teams, particularly in response to complaints or intelligence. It is important to remember that test purchasing exercises should be conducted in gambling premises and other places where gambling machines may be available, such as fruit machines in pubs and bowling alleys. Larger operators are now responsible for conducting and taking part in underage testing and sharing these results with the Gambling Commission; licensing authorities may choose to ask for copies of test purchasing results as part of their local risk assessment expectations and use this evidence to help target their own activity in this area.

In 2019 a review of pubs in England and Wales showed 84 per cent of them failed to prevent under 18-year-olds from playing on fruit machines. Staff in licensed premises are expected to stop children playing on the machines and there should be clear signage indicating the age restriction. Authorities should have a plan in place for dealing with test purchase failures; for example, requiring a premises to undertake certain measures to address this and undergo a follow-up test within a specified amount of time. A second failure would be expected to lead to enforcement action.

The Gambling Act review pledges to give councils increased powers in relation to gambling machines in alcohol licensed premises. Subject to consultation by the Gambling Commission on any changes to its code of practice, the additional powers for councils could include the ability to cancel the entitlement to additional gaming machines, vary the permit to change the number of machines allowed, or even remove the automatic entitlement to site gaming machines where there is a failure to prevent underage gambling. The changes to the code of practice for clubs and pubs would also be reflected in Gambling Commission guidance to licensing authorities.

Case study: Test purchasing in Southend

Southend-on-Sea is a seaside town and has been a popular holiday destination for many decades where visitors can enjoy blue flag beaches, an award-winning fairground and many other attractions. Situated along a stretch of the promenade is the ‘Golden Mile’ containing restaurants, pubs and several amusement arcades, some of which include ‘Adult Gaming Centres’ (AGC) operating gambling machines restricted to players over 18 years.

Officers from the trading standards and licensing teams at Southend City Council embarked on a test purchase operation to measure the effectiveness of these arcades in preventing young people under 18 years from playing on age restricted games. Letters were sent to the identified premises, informing them of the visits, without mentioning exactly when they would be taking place. Two 16-year-old volunteers were recruited and were briefed by officers on the procedures of the operation, where the safeguarding of the young persons is always the priority.

The volunteers were accompanied by two staff members and were tasked with entering the AGC area and playing on a machine located within it. One officer was assigned to be located in close proximity to the volunteers, to be able to witness any subsequent actions and be prepared to intervene if necessary. The second officer remained outside the premises to meet the volunteers on exit, thus ensuring that they were in sight of an officer at all times.

In all the premises, access to their AGC was through a barrier and adequate signage for age requirements was on display. In the majority of visits the volunteers were challenged by staff after 2-3 minutes, in which time they played 3-5 games. Staff asked for the ages of the volunteers or whether they could provide appropriate ID. The volunteers are at all times required to answer truthfully and they were consequently asked to leave the area. However, in one large arcade, the volunteers were able to enter the restricted area and played on machines for over five minutes, unchallenged by any member of staff. When it became clear to the officer within that nobody was going to intervene, he signalled to the volunteers to leave the premises.

A second letter was sent to all the arcades visited, informing them of the results, and a written warning was given to the arcade that failed. Officers will carry out a follow-up visit to that particular premises and if it fails for a second time, formal action will follow.

Case study: Age verification technology and test purchasing in Southampton

Southampton City Council were concerned that alcohol licensed premises in Southampton were failing to prevent young people from accessing on site gambling machines, as evidenced by a higher than national average test purchase failure rate. Consequently, officers in Southampton began engagement with the premises tested including with senior management at a number of pub group chains to discuss how to address this issue. The alcohol licensed premises involved were very co-operative and keen to stop young people from accessing gambling machines and were aware this is an ongoing issue of concern to the council. They discussed the different options available and agreed to install age verification software into the gambling machines. This software is based on facial recognition technology which prevents anyone who appears under 25 from using gambling machines. If an individual has ID to prove they are over 18, staff can enter a code into the gambling machine to allow access.

This scheme has been highly successful and premises staff have praised this initiative as it has assisted them in their day-to-day work. Failed premises were retested and positively the test purchase failure rate fell to 33 per cent. Notably, in venues with the age verification software, there have been no test purchase failures.

What councils can do:

Ensure there is an up-to-date local area profile and statement of licensing policy in place for the local area.
Set out best practice expectations of local gambling operators and risk assessment processes.
Use compliance visits and enforcement tools appropriately.
Consider underage sales testing, age verification technology and local partnership schemes such as Betwatch.
Encourage local gambling businesses to apply for Gamcare’s Safer Gambling Standard and undertake the Gamcare training courses.

Location of premises and the planning authority role

Betting shop clustering, and more recently clustering of bingo halls and adult gaming centres on the high street, have been a significant concern for councils and the public. Research from 2021 by the University of Bristol suggested that the UK’s most deprived areas have more than 10 times the number of betting shops than the most affluent parts of the country, where the harm from problem gambling may be exacerbated. While statistics show that the number of betting shops has reduced since the reduction of B2 gaming machine stakes, there is concern about the clustering of other types of premises: University of Bristol research found the correlation with deprivation was strongest for bingo halls, followed by family entertainment centres.

Currently, neither the planning or licensing frameworks have provided clear options for refusing new or additional gambling premises. The Gambling Act includes a statutory aim to permit licence applications which has made it difficult to refuse new licence applications, even in locations which the council and local residents believe are inappropriate. However, the Gambling Act Review contains a pledge to introduce cumulative impact assessments which, when introduced, will create a presumption against granting new licences in areas where there is already a saturation of gambling premises and there are concerns that granting another licence will negatively impact upon the licensing objectives.

There have been similar challenges in using the planning system to limit the opening of gambling premises. A number of councils previously sought to use Article 4 Directions to remove permitted development rights to convert other types of premises into betting shops without the need for planning permission. However, changes to the planning system in 2015 effectively introduced this approach across all areas. As a result of the change, betting shops in England are now classed as sui generis (a use that does not fall within any use class). This means that any new betting shop must apply for full planning permission. The only exception to this relates to a new betting shop tenant moving into a unit formerly used (as its last known use) as a betting shop. In this circumstance, the new tenant would be able to operate under the previous user’s planning use class.

This means that planning authorities now have some powers to manage the opening of new or additional betting shops in their areas. If an authority wished to refuse a new application for planning permission, however, it would still need to do so by reference to its local plan and associated evidence base. Local plans need to be approved through examination by the national planning inspectorate, and councils would need a robust evidence base to include restrictions on betting shops.

There are some examples of this being done. In 2022, Bradford City Council’s planning team refused an application for a new gaming centre in an area of the city with high levels of deprivation on public health grounds. A partnership of Bradford Council’s Public Health department, the Reducing Inequalities Alliance - Bradford and Craven Health and Care Partnership and the multiagency Bradford Gambling Harms Reduction Partnership lodged an objection to the planning application, highlighting significant concerns about the location of the planned gaming centre which was within 50 metres of five other gambling premises, near the Citizen’s Advice centre, very close to schools, colleges and the university, as well as to drug and alcohol treatment services which are in close proximity. The gambling operator has since appealed the decision.

Additionally, in 2022 an adult gaming centre was refused permission to move into a new premises in Lincoln. A fashion shop on Lincoln High Street vacated a premises, and a gambling operator submitted an application to change the ground floor’s use, install signs and operate for 24 hours, seven days a week. The City of Lincoln Council’s planning department refused this application, arguing it could lead to unacceptable levels of disturbance and anti-social behaviour. The council also highlighted that three betting offices and two adult gaming centres were nearby, and that the application had received a significant number of objections from local residents.

Case study: Newham’s Local Plan

Since 2016 Newham council has adopted a pioneering cumulative impact approach in their Local Plan, which introduces limits to numbers of betting shops (and hot food takeaways), ensuring they are separated from each other in the street scene. This policy prevents new betting shops from locating in areas where there are already three units of the same use within a 400m radius (typically a five-minute walk) and seeks to achieve a benchmark of 67 per cent of leisure uses in town centres being ‘quality leisure’ - excluding betting shops, amusement arcades and takeaways. Monitoring indicates that it has been highly successful in preventing new betting shops being established in areas of over-concentration, with no lost appeals and a significant reduction in the number of applications and appeals relating to gambling premises overall.

However, Newham’s residents consistently report that prevalence of established gambling premises (and hot food takeaways) continues to be a problem. The council recognises that the policy needs to evolve to help manage the impacts of changing gambling models, such as the growth in popularity in adult gaming centres, and to help promote responsible operation of these premises where their location is otherwise acceptable. The Local Plan Refresh (Reg. 18) therefore proposes to extend the cumulative impact approach to all gambling premises, as defined by the Gambling Commission, and to require through conditions: the display of information about debt advice services and/or gambling addiction charities; and that the operator signs up to, and operates in compliance with, any scheme(s) which promotes community safety.

What councils can do:

Update local plans to include planning policies relating to betting shops.
Consider whether and how planning policies relating to gambling premises should be included within local plans.

A council wide approach to identifying people impacted by gambling related harms and signposting to support

As stated previously, there are steps that councils can take to help identify people experiencing gambling harms (and those close to them) and assist and encourage them to access the support that is available from other organisations.

It is clear that a range of different council services will be interacting with those experiencing gambling harms, or people who are negatively impacted by it. These include:

Drug and alcohol treatment services, given high rates of co-morbidity between drug, alcohol and gambling harms
Homelessness services, given the prevalence of harmful gambling among the homeless population.
Wider housing services, given that harmful gambling can be a contributory factor in rent arrears.
Financial inclusion services, given that harmful gambling can be a contributory factor in financial problems.
Children’s services and adult social care, where harmful gambling may be a contributory factor to family breakdown and / or domestic abuse.

It can be challenging to understand the scale of harmful gambling in a local area, or how it is contributing to demand for local services. This is partly because harmful gambling is often hidden, connected with stigma and social embarrassment and therefore not admitted to, with few visible signs to make it obvious. But it can also be because the tools and knowledge are not in place to enable councils and their partners to screen for harmful gambling, often due to low awareness of the issue. These factors mean that many people experiencing harmful gambling are not accessing support – as highlighted by the gap between the estimated number of people experiencing gambling harms and those receiving treatment.

There are, however, some straightforward steps that councils can take to understand the scale of harmful gambling in their areas, and to start signposting people to the help they need. This is demonstrated by the below case study from Leeds City Council.

Case study: Harmful gambling in Leeds – research report and follow up

In 2016, Leeds City Council commissioned Leeds Beckett University to conduct a study of the prevalence of harmful gambling in the city, using funding from a social inclusion fund established alongside the grant of a premises licence for a large casino in the city centre. The subsequent work was led within the council by the financial inclusion team, which since 2014 had been working to support the council’s priority of tackling poverty and reducing inequality. The research by Leeds Beckett demonstrated a clear link between the council’s priority to tackle poverty and harmful gambling, as well as with the priorities in the council’s health and wellbeing strategy.

The research identified that rates of harmful gambling in Leeds were double the national average, with around 10,000 harmful gamblers in the city, and a further 30,000 at risk. The researchers estimated that harmful gambling rates in Leeds (and similar more urban and densely populated areas across London, the north and other metropolitan borough areas), at 1.8 per cent, are broadly twice the national average. Rates of at risk gambling were more consistent with the national average, at 5-6 per cent. Overall, the research found that around 7-8 per cent of people in Leeds were found to be either harmful or at risk gamblers, compared with a national average of 5-6 per cent.

In the context of above average rates of harmful gambling, there was a comparative lack of treatment support available, with just a single counsellor and a lack of awareness of the resource.

The research identified a lack of awareness among council staff and partner organisations about the issue of harmful gambling, and a need for staff in a range of services to be more familiar with the issue, including: customer contact, libraries, housing, schools, welfare and advice agencies, children’s centres and public health.

As a result of the research, Leeds has trained frontline staff to enable them to better support those affected by gambling harms and improved HR practices to support council staff affected by gambling harms. It also served as a basis for a number of different community outreach programmes. For example, the council worked with partners to increase their outreach in low income, ethnically diverse areas of Leeds to raise awareness of the risks that can be associated with gambling through businesses such as barber shops where community members socialise, as well as a programme in Armley Prison to support prisoners who may be affected by gambling harms. They have supported gambling awareness training for students and staff from colleges and universities, and participated in joint communications and campaigns during ‘Safer Gambling Week’ and major sporting events, such as Cheltenham Festival and the football World Cup. It has also enabled the licensing team to work with new gambling premises and evidence why conditions may be required as part of their licence and supported the establishment of a regional network for public health leads around gambling harms.

Identifying an organisational lead/s on harmful gambling

Councils may find it helpful to identify an organisational lead on harmful gambling, at member or officer level, to drive work on developing a council-wide approach to gambling related harm. This role may naturally fit with public health teams, although council licensing and financial inclusion teams have played a leading role in some places.

Develop a strategy

A council wide strategy on tackling gambling related harms can be a useful way of demonstrating a council’s commitment to tackling gambling harms, what role different teams can play, what areas the council should focus its efforts on and what the priorities are. Sheffield City Council is finalising its strategy on tackling gambling harms and has worked closely with lived experience groups to inform its approach.

Role of elected members

Elected members can play a key role in tackling gambling harms in their local communities and driving the council’s progress in tackling this issue. The LGA has produced a councillor handbook to support members with their role in the gambling licensing process. Additionally, the Centre for Governance and Scrutiny and the Gambling Commission has produced guidance for elected members in overview and scrutiny roles, including highlighting ‘10 questions to ask if you are scrutinising gambling harm’.

Recent trends suggest that most councils will not receive many applications for new gambling premises. However, members can still play a key role in scrutinising other aspects of gambling regulation, particularly ensuring test purchasing exercises are undertaken to prevent young people from accessing gaming machines in pubs and other licensed premises. As the test purchasing section of this document highlights, the test purchase failure rate in licensed premises remains high and is therefore a key area where improvements need to be made.

Councillors can also work with Cabinet members who may have an interest in tackling gambling harms, such as the Cabinet member for health and wellbeing or community safety, to drive progress within the council. This can ensure alignment with the council’s wider priorities.

Councillors also have a key role in ensuring gambling harms are recognised as an issue. Councillors are able to represent communities who may be affected by gambling related harms and they can encourage conversations across community settings. They can also influence and set the tone of how gambling is discussed within a local area, and it is therefore important that stigmatizing language is avoided which can lead to narratives of the individual experiencing harms as the 'problem' rather than them ‘having’ a problem or illness. Councillors can work with partners to ensure services do not shame or blame people who gamble and use first-person language to highlight that gambling disorders are not an identity.

Links to support organisations

An important early step is to establish contact with national and local organisations providing support to those experiencing gambling related harms, to understand the extent of provision and appropriate referrals within the local area. GamCare could be a first point of contact and reference point for understanding provision in the local area; similarly, links to local Gamblers Anonymous and GamAnon groups may be helpful. There may also be other local charities working with people experiencing harms caused by gambling, for example GamFam in Greater Manchester, Betknowmore in north London and New Beginnings which provides specialist support for women affected by gambling harms, which public health teams or local third sector organisations are likely to be aware of.

Working with local partners

Councils should also think about how they could take forward this work in conjunction with key local partners such as the police, health services, housing associations, faith and community groups and others to identify people who may have hidden needs related to gambling harms.

Councils may also wish to involve lived experience groups in their work. For example, Greater Manchester Combined Authority regularly engages with a lived experience group, GamHive, to inform and direct their programme of work.

Training for front line services – screening and signposting

A clear piece of learning from Leeds’ early work was the need to provide training for frontline staff who may be coming into contact with people experiencing harmful gambling or people negatively impacted by it – such as children’s and family services, or housing services. GamCare has developed a free training course for frontline staff and the Royal Society of Public Health has produced resources to support those working with members of the public. For some staff (particularly in partner organisations) it may be appropriate to provide training in some of the formal screening tools that are available, for example, the Problem Gambling Severity Index. Councils may also be interested in the work of Wigan Council, who have successfully developed a cross-authority gambling harms project team that has been working to take a whole council approach, and they have integrated and embedded gambling screening within their service offers.

The key outcome of this should be that relevant frontline staff are aware of the issue and clear about what to do if they identify someone who is experiencing gambling harms. Putting in place effective mechanisms to signpost or refer people to relevant support agencies will be a crucial part of this. As frontline staff begin to identify and refer people with gambling issues, or those affected by them, data on this should be collected and used to support local licensing statements.

Case studies: Screening for gambling harms in the criminal justice system

Cheshire criminal justice pilot scheme

GamCare and Beacon Counselling Trust undertook a pilot with the criminal justice system in Cheshire in which 250 individuals across the wider criminal justice system were trained to use the Lie/Bet screening tool. 760 individual screenings subsequently took place, with 99 positive results recorded; 29 of these people chose to receive an intervention from harmful gambling treatment services.

As part of the pilot, Cheshire police began to screen people for gambling issues at the point of arrest. The police force already screen people for drug or alcohol issues; when questions about gambling were added, 13 per cent of those arrested confirmed that they had experienced gambling related harms – prevalence thirteen times higher than the national average.

The pilot was successful and Cheshire police has subsequently embedded gambling screening into their practices. All staff involved in the custody process, including police officers, investigating officers and those working in probation, have been trained on the screening process. Staff are able to make referrals to appropriate agencies and signpost individuals to support services, such as the GamCare helpline.

Hertfordshire Problem Gambling Project

The Hertfordshire Problem Gambling Project was funded by the Hertfordshire Police and Crime Commissioner’s Innovation Fund from October 2018 to September 2020. The project took a ‘whole system’ approach to attempt to understand where best to intervene within the offender journey in order to identify and support individuals experiencing gambling related harms.

The first year of the project focused on building relationships with partner agencies within the criminal justice system to raise awareness of key issues, identify screening points and to develop referral pathways and an appropriate treatment offer. In the second year, Hertfordshire police continued to raise awareness of, and access to, support and treatment for those experiencing gambling related harms who were in contact with the criminal justice system in Hertfordshire.

Through this work, the police force has been able to support individuals experiencing gambling harms. For example, in HMP The Mount, 24 men were referred into treatment and following assessment, 14 screened positively for gambling related harm. Of those 14, 8 were treated, and 6 began but did not complete treatment due to them disengaging or leaving the establishment.

Gambling harms screening is now embedded into Hertfordshire’s custody process. Additionally, Hertfordshire have a dedicated GamCare Criminal Justice System Treatment Practitioner in post, who continues to raise awareness of the importance of this work and delivers treatment to those who need it.

Warwickshire PCC: embedding gambling harms into commissioning processes

The PCC for Warwickshire, Philip Seccombe, identified understanding and tackling gambling harm as a key priority in his police and crime plan. Through this work, the PCC intends to provide better support for people who may commit crime as a result of harmful gambling. Warwickshire is at an early stage in its journey on tackling gambling harms. However, there is a drive to ensure all frontline staff have training on gambling harms.

The PCC has also embedded knowledge of gambling harms into the requirements of all procurement bids, to ensure service providers have an understanding of gambling harm and are therefore able to understand and recognise it in service users and provide better support. The PCC’s team has worked closely with Warwickshire County council to ensure there is join up and alignment of work on this agenda.

Recent research shows nine out of 44 police forces now screen for gambling harms in the custody process, and 17 forces displayed some awareness of gambling harms. The Association of Police and Crime Commissioners (APCC) is working with police forces across the country to encourage forces to embed screening for gambling harms into their custody processes. The APCC has published a checklist for PCCs to support work on tackling gambling harms.

Councils should enquire about if any work on gambling harms is taking place within their local police force and see if there are any opportunities to align work and offer support to individuals affected by gambling in the criminal justice system.

Improving and collecting data

As processes for screening and signposting become embedded, it is important that councils and their partners build up the evidence base about the prevalence and nature of harmful gambling in the local area. Councils should consider the breadth of potential data sources they may have access to, for example, how many people who access financial support or food bank services are struggling with gambling harm. It is also important to also gather data on those who may be at elevated risk of harms to try and prevent harms from occurring. Developing a better understanding of local harmful gambling, the impact of harmful gambling on individuals, families and communities, and the cost of this to the public purse, will be extremely helpful – for example in terms of the licensing statement of policy and local joint strategic needs assessment. It will also help to provide evidence about any regulatory changes which may be required to help prevent and address harmful gambling.

Gambling advertising

Councils may also want to review to what extent gambling is advertised on council owned property and consider whether or not a ban might be appropriate. In 2021, Bristol City Council updated its advertising and sponsorship policy to include a prohibition of all gambling related adverts on council property, including billboards, digital screens, bus shelters, museums, libraries, parks and customer service points. This policy also restricts the advertising of other products which may have a negative public health impact, such as alcohol, pay day loans and fast food. The policy may have a significant financial impact, but Bristol council believes this will be offset by the potential public health benefits. There could be a significant role for elected members in driving this sort of approach.

Councils can also adopt other innovative projects to reduce gambling advertising. For example, Bolton Council is working with Bolton Wanderers Football Club to develop new policies and campaigns to restrict advertising of gambling at sporting events, and also to run engagement activities within local communities to tackle and prevent gambling harms.

Review your own council’s policies and practices

As a key public sector employer, councils can also lead by example with the development and implementation of policies to support employees who may be affected by gambling related harms, in the same way that councils will have policies in place to support staff experiencing other health issues. This could include access to counselling support, time off to attend recovery services, or provision of information and support. Councils could also review their internal policies in relation to using gambling as a fundraising mechanism, such as raffles and charity lotteries, and determine whether this is appropriate. Some councils are demonstrating good practice: for example, Leeds City Council has an internal HR policy to support staff negatively affected by gambling, as has North Ayrshire Council.

What councils can do:

Consider designating an organisational lead for harmful gambling issues.
Encourage elected member’s scrutiny of gambling harms work.
Awareness raising and training for relevant frontline staff and partner organisations.
Develop relationships with local treatment organisations and lived experience groups.
Implement screening processes and strengthen data collection.
Review to what extent council property is used to advertise gambling products.

Other resources and research

Resources and research

Tackling gambling related harm: A whole council approach

Foreword

Executive summary

The Gambling Act 2005

Understanding gambling related harms

Definitions of harmful gambling

Prevalence of harmful gambling

Circumstances which can increase the risk of gambling related harm

Impact of harmful gambling

Framework for prevention and support for gambling related harms

National approach to tackling and preventing gambling related harm

Research

Education

Treatment

NHS services

NHS Services

Third sector services

Taking a public health approach to tackling gambling harms

The role of public health teams

How councils’ regulatory tools can help tackle gambling-related harm

Licensing authority functions

Licensing statement of policy, local area profile and risk assessments

Working with gambling businesses

Location of premises and the planning authority role

A council wide approach to identifying people impacted by gambling related harms and signposting to support

Identifying an organisational lead/s on harmful gambling

Develop a strategy

Role of elected members

Links to support organisations

Working with local partners

Training for front line services – screening and signposting

Improving and collecting data

Gambling advertising

Review your own council’s policies and practices

Other resources and research

More publications about Community safety

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