Memorandum from Technical Systems Testing
North America Inc (DGB 77)
Technical Systems Testing (TST) is an internationally
recognised Accredited Testing Facility (ATF) offering a full range
of testing and consultation services for Terrestrial (traditional
land-based) and Interactive Gaming, Wagering, Lottery, e-Commerce
and Information Technology (IT) industries.
Working closely with Jurisdictional Regulators,
Operators and Manufacturers, organisations such as TST play a
key role in the regulatory process as independent third party
laboratories contracted to test, evaluate and verify the fairness,
security and auditability of gaming systems and equipment in the
United Kingdom, Canada, the United States and Australia. With
this in mind, we wish to respectfully present the comments outlined
in this letter in order to highlight the importance of independent
testing and evaluation of gaming systems and equipment as part
of the draft legislation.
TST has had an opportunity to review the Department
for Culture, Media and Sport Gambling and National Lottery Licensing
Division Draft Gambling Bill November 2003. In relation to Article
5, Section 56 (Consideration of application: general principals)
we address the following specific sections:
(1) In considering an application under
section 55 the Commission—(c) shall consider the suitability
of any gaming machines to be used in connection with licensed
activities,
and
(5) The statement (of the principals to
be applied in considering applications under section 55) must
also, in particular, specify the kind of evidence to which the
Commission will have regard in considering the suitability of
the gamming machine or other equipment and that evidence may include:
(a) the result of a test carried out by a
person at the request of the Commission; and
(b) the opinion of any person.
TST is concerned that gaming in general and
remote gaming in particular, is perceived as exploitive and insalubrious.
In many cases this perception is well deserved because gaming
is conducted in jurisdictions where regulatory practices are little
more than a fade to delude the unsuspecting player. In order to
ensure the good reputation of the United Kingdom is maintained
and players are protected, we believe that world best practice
in gaming regulation and control is mandatory. This includes,
but is not limited to:
(a) adequate technical requirements to ensure
that gaming is conducted in a manner that is fair, secure and
auditable; and
(b) testing and certification of gaming systems
against these requirements by Accredited Testing Facility (ATF)s,
with relevant experience and references, which are totally independent
of gaming Operators and Manufacturers I Suppliers.
TST believes that the UK can benefit by looking
to jurisdictions such as Nevada in the USA, Australia and Alderney
for guidance in this respect. In relation to remote gaming, Alderney
has been particularly successful in maintaining integrity without
compromising business efficacy.
December 2003
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