Written evidence submitted by the Responsible Gambling

Strategy Board (GA 75)


This submission is relevant to the second issue in the Committee's terms of reference (how effectively the Gambling Act is protecting the young and vulnerable).


· The Responsible Gambling Strategy Board (RGSB) was set up by the Gambling Commission in late 2008 to advise the Commission and, in turn, the Department of Culture, Media and Sport (DCMS), on Research, Education and Treatment (RET) elements needed to support a national responsible gambling strategy and associated funding requirements.

· During 2007/08, the Gambling Commission, at the request of the DCMS, conducted a consultation process intended to rationalise the processes by which funding for RET relating to gambling-related harm was solicited and disbursed. The Commission recommended that there should be a clear separation between the formulation of RET strategy, the generation of income for their implementation, and the actual commissioning and funding of RET activities.

· The Gambling Commission considered that, since the creation of the RGSB was essential regardless of whether funds are raised voluntarily or via a levy, the costs of supporting the Board (currently £250k per annum) should be met from gambling industry licence fee income.

· The RGSB is an independent, expert, body which advises the Commission (and through them the government) on the RET elements in a national responsible gambling strategy. RGSB determines and recommends to the Responsible Gambling Fund (RGF) (after consultation with stakeholders and experts) what RET is required to reduce harm from problem gambling as part of an overall national responsible gambling strategy, and the levels of funding necessary to deliver the recommended priorities.

· Since the publication of the 2009 RGSB Initial Strategy and Priorities, the Board has developed and identified strategic priorities in relation to its three principal areas of focus, namely RET in the field of responsible gambling.

· RGSB provides the Gambling Commission, DCMS and the wider public with advice and information needed to develop policies and practices to reduce the incidence and impact of gambling-related harm relating to individual gamblers, their families, other social networks, and wider society.

· RGSB’s priorities also form the basis of the strategy and priorities (and framework) provided to RGF, which is responsible for funding organisations and individuals to meet those priorities via the delivery of RET programmes. The three workstreams are intimately connected, and sometimes overlap.

· The findings from RGF’s work - from commissioned research, findings from data collection and analysis, conclusions of external evaluations and learning from funded projects - will in due course help the RGSB to refine its strategy and advice and to communicate externally (proactively and in response to consultations), thus creating a virtuous loop of learning, policy development and improved delivery (of harm prevention and treatment).

· RGSB’s overall ‘direction of travel’ remains as it was in 2009, with due regard paid and acknowledged in Strategy 2010 to the areas identified as priorities, and those that required further consideration. Treatment development has been progressed significantly, with the first steps relating to harm prevention work requiring longer consideration and featuring more highly in the second operational year.

· The context in which RGSB operates is one of a very popular legitimate activity that provides entertainment and enjoyment for millions of people, but, because of the nature of gambling, requires protection for the vulnerable and constant scrutiny to ensure a proper balance is maintained.

· RGSB acknowledges that the majority of people who gamble do so responsibly. This desirable state of affairs is considerably aided by a gambling industry which is committed to promoting responsible gambling and by the regulations and requirements to which operators adhere.

· The challenge to understand ‘causality’ (how and why some individuals become problem gamblers) is one which the RGSB recognises and continues to consider how it can be approached. The work of the expert panels, and the strategic direction these give RGSB and RGF, is focused on both establishing and getting behind the correlations (between characteristics of those affected, their gambling activities, specific attributes of the latter) to be able to target prevention and treatment better. RGSB is committed to working closely with the gambling industry in this difficult area and welcomes the opportunities to bring independent researchers, external opinions and those with the sector knowledge together for this purpose.


The public health agenda

1. The need to recognise gambling-related harm as a public health issue was a key theme of the 2009 RGSB Strategy. A public health approach places a strong emphasis on targeted, segmented, and tailored harm prevention aimed at different groups. Population ‘segments’, and the usual level and nature of intervention associated with them, can be summarised as follows:

· general population - universal or primary prevention

· at-risk and vulnerable groups - secondary prevention

· those experiencing gambling-related harm or ‘affected others’ [1] - tertiary prevention, ‘moving into' treatment activities.

2. The provision of effective support services for those experiencing gambling-related harm and their ‘affected others’ is also a key feature. Underpinning a public health approach is an understanding that all stakeholders (including central and local government, industry, clinicians, communities, etc, as well as gamblers themselves), have a role to play in preventing and minimising gambling-related harm.

Problem gambling or gambling-related harm?

3. RGSB consciously favours the use of the term gambling-related harm in preference to problem gambling. Unlike the phrase problem gambling, which focuses primarily on the individual player, gambling-related harm has a more comprehensive reach. It refers to the negative impacts of gambling across a range of areas, moving beyond the directly-affected gambler to include their families, wider social networks and community. This general term is meant to embrace two key inter-related areas:

· The negative effects of individuals’ behaviours, particularly excessive expenditure of money and/or time spent on gambling

· The impact of problematic gambling on individuals, on affected others, family, professional or other social networks, communities and society.

4. There is general agreement that clearer identification of specific social groups who may be vulnerable to, or who are currently experiencing, gambling-related harm, will assist in the design and delivery of targeted harm prevention and treatment packages. The British Gambling Prevalence Survey 2010 provides new data, as will the findings from RGF’s treatment funding, which the RSGB will be taking account of in the coming year.

Progress to date

5. The development of broad strategies for RET, plus specific recommendations in relation to areas of concern are summarised below.

Education and Harm Prevention

6. The evidence base on the effectiveness of harm prevention and education is limited. RGSB looks to RGF to enhance the evidence base via systematic data collection in all harm prevention programmes, and robust monitoring and evaluation that takes an outcomes-based approach and includes criteria against which effectiveness can be measured. RGSB will be drawing on developments in social marketing and behavioural change in respect of the education/harm prevention programmes that it might recommend RGF should consider.

7. Harm prevention aims to reduce the strength of risk factors that may predispose people to gambling-related harms and increase the factors that are likely to protect them from such harms. These factors can be individual, familial, linked to the local community or environmental. Protective factors include individual resilience, which may be developed by, for example, an increase in knowledge, skills, improvement in responsible attitudes to gambling, and a sense of self-efficacy. It therefore makes sense to take a broad approach to harm prevention activities.

8. The Board recognises the harm prevention initiatives that the industry has a role to play in supporting, such as self-exclusion. The Education and Harm Prevention Panel is exploring how such initiatives might be strengthened, and is compiling materials dealing with self-exclusion, pre-emptive avoidance of harm, and self-limitation of potentially problematic gambling behaviour. Collating such a resource bank will enhance RGSB’s understanding regarding levels of and barriers to deployment of relevant strategies, and possible technological and/or training approaches that would assist consumers and gambling industry staff in increasing take-up and understanding better the role and inter-relationship of consumer, operator and regulator in relation to gambling activity.

9. A range of harm prevention strategies is required for different target groups. For example, an intervention which might influence adults may have little effect on teenagers; there is no ‘one-size-fits-all’ solution to the challenges of prevention.

10. RGSB does not regard gambling-related harm prevention and gambling education as occurring only as discrete activities taking place at certain points in a linear continuum. For example, while children and young people are likely to benefit from some education and information about gambling, and can be helped to understand the concept of problem gambling before they are likely to participate in gambling activities, the benefits of integrating education about gambling with other educational topics (such as avoiding risk-related harm in general) merits further exploration. Gambling-related harm prevention and education may need to be refreshed throughout the school years, and is also likely to be necessary for people who may already have experienced (or are experiencing) problems with gambling.

11. This view is consistent with approaches in other risk taking behaviours such as (excessive) drinking, where prevention and education are often embedded in a ‘life skills’ approach, although it is important to make clear that this analogy is drawn in the context of gambling-related harm only. In these other fields, there is also an understanding that prevention activities are often needed in support of recovery, which often involves multiple relapses before reaching the successful long-term management of a problem.


12. RGSB’s research strategy is concerned with providing the evidence base to ensure that effective education/harm prevention and treatment programmes can be delivered. The four main questions to be addressed by the research programme are:

1) What risk factors are associated with and cause gambling-related harm? How can those who have experienced harm be identified?

2) What happens to people and those they interact with and to society as a whole as a result of gambling-related harm?

3) How can we prevent gambling-related harm and help people to avoid, reduce or eliminate harm from their gambling?

4) How can the evaluation of treatment and education/harm prevention activities undertaken in Britain and internationally inform funding decisions, regulatory formulation, policy implementation and best practice in Britain?

13. Findings regarding treatment outcomes, patterns and types of need, client perspectives, client profiling, etc, grounded in daily practice, will provide valuable information to support the planning and targeting both of research programmes and the funding of treatment, education, and harm prevention initiatives.

14. This practical emphasis will continue to be applied during 2011/12, when evaluation findings commissioned by RGF of directly-funded services and data collected from a range of agencies will be available for consideration.

15. There is a limited pool of ‘specialist’ gambling researchers in Britain. It is, therefore, important to provide support (through, for example, studentships, mentoring, developmental workshops) to encourage new researchers from a range of disciplines to develop an academic interest in gambling studies. There is a need to build capacity for research both within the field and amongst those outside it, who may carry out or contribute to the evidence base.


16. Education/harm prevention and treatment services form part of a continuum, in terms of their relevance for individuals who have experienced and/or are at risk of gambling-related harm. The activities that make up harm prevention overlap with treatment activities, and the Board has identified opportunities for achieving treatment aims through some harm prevention activities (such as information giving) and achieving harm prevention aims through some treatment activities. The most obvious areas of overlap are prompt identification and intervention, and the RGF has workstreams underway focusing on these.

17. The systematic collection of data in treatment services to measure treatment outcomes and contribute to the evidence base on the effectiveness and impact of interventions and services is a key area. RGSB is anticipating that the Data Reporting Framework being implemented by RGF will be informing future treatment strategy during 2011/12, and is concerned if this is to be delayed after the collaborative work which went into its development. The Treatment Panel has begun to identify and evaluate the effectiveness of brief interventions.

The tripartite system

18. RGSB was established by, and is accountable to, the Gambling Commission, for which it acts in an advisory capacity. RGSB’s current Chair is Baroness Julia Neuberger, and its members comprise experts from a range of relevant fields, acting in an individual capacity.

19. While RGSB, The GREaT Foundation and RGF are formally independent of each other, they work towards common aims and have shared values. So far as RGSB is concerned, these aims are primarily set out in its Strategy documents. As noted, GREaT’s function is to generate income from the gambling industry to fund these priorities. RGF’s function is to distribute those funds in pursuit of those priorities, having taken RGSB’s advice on them into account.

20. There is therefore significant interaction between all three bodies, which benefits not just the work of each one of them, but also the fulfilment of their overall common objectives. This congruence is in particular reflected in the shared secretariat of RGSB and RGF (which reached its full staff complement of 2 full time equivalent staff in June 2010), and in the regular contact between these bodies and GREaT.

Panels and forums supporting RGSB’s work

21. RGSB has established three expert Panels to inform its, and RGF’s work, whose focus corresponds to the three RET priorities. The work of the Board members on the expert Panels has been complemented by the valuable contributions of a number of external Panel members and observers. The gambling industry is represented among RGSB’s membership, in order that it might benefit from those individuals’ practical knowledge of the sector. The regular cycle of Panel and Board meetings is supplemented by other discussion and consultation opportunities, and Board members have sought contributions from a range of other sources in order to supplement their own understanding of the approaches needed to support a credible and effective RET strategy. These sources include submissions, meetings, discussions, forum events, and national and international research.

2011/12 and beyond

22. In general, RGSB’s initial priorities have proved to be durable over the past year. Much has been learned regarding the pace of change as we have worked through the process of supporting the translation of strategic objectives into actions. A key task is to ensure that turning the Board’s 2009 and 2010 aspirations into reality during 2011/12 and beyond is carried out in an effective and thorough manner that will be subject to transparent evaluation.

23. When the tripartite arrangement was established, it was agreed that GREaT, with the support of the gambling industry, would endeavour to raise £5m, £6m and £7.2 m respectively for the first three financial years of its existence. £5m was to be guaranteed as a minimum for each period. RGSB anticipates that by autumn 2011, as the first three year funding targets come up for review, with detailed further information from a number of sources, it will be in a better position to inform discussions about quantum of funds. However, this is dependent on the findings from RGF’s funded work being presented to the RGSB, and the RGF has been delayed in some aspects of its development work. In particular new data collection frameworks have not yet been implemented. It is hoped that this will soon be resolved.

24. The quantum of funding for each of the individual RET workstreams beyond 2011/12 has not yet been reviewed as, once again, insufficient evidence currently exists to support a recommendation to RGF regarding potential deviation from current allocations (whereby over 70% was allocated to treatment services in 2009/10). However, RGSB is aware that many of its areas of interest, as expressed in the work that the RGF is now commissioning, make less distinction between individual workstreams than might have been assumed in the past. In particular, the emphasis of the pilot programmes on prompt problem identification, (the Gambling Risk and Harm Minimisation projects) in which RGF is investing significant sums, is intended to have a preventative as well as a therapeutic function.

June 2011

[1] In its primary sense, ‘affected others’ is a term generally understood to mean partners, other family members, close friends, etc.

Prepared 1st August 2011