Draft
Gambling Bill
A response from
The Salvation Army
December 2003
The Salvation Army
101 Newington Causeway
London SE1 6BN
020 7367 4619
www.salvationarmy.org.uk
1. Executive Summary
- The Salvation Army welcomes the
Government's commitment to protect children and vulnerable people
from the negative effects of gambling. However, it questions the
level of demand for an increase in gambling opportunities. In
research conducted by NOP for The Salvation Army 93% of the British
public said that there are already enough opportunities to gamble
in the UK.
- It is a concern that children and
young people under the age of 18 will still be allowed to play
low-value fruit machines under the current proposals. The Salvation
Army thinks this runs counter to the Government's claim that gambling
should be for 'adults only'. 82% of the population think that
people under the age of 18 should not be allowed to play fruit
machines.
- Local people should be given the
power to influence planning decisions regarding the building of
new casinos. Over half of the people surveyed said they would
not be happy for a casino to open near to where they live.
- Substantial research should be
carried out before liberalisation of the gambling laws to judge
the likely consequences of the proposed regime. Deregulation should
not outpace research.
- Gambling with credit should not
be made widespread. There is already an identifiable problem with
consumer credit in the UK and enabling widespread gambling on
credit can only make that worse. 94% of the population thinks
that allowing people to gamble using credit cards would put people
at greater risk of incurring gambling debts.
- The Salvation Army welcomes the
proposal that the gambling industry should contribute towards
the cost of treatment for problem gamblers. However, it is concerned
that a figure of £3m is woefully inadequate given the likely
upsurge in the number of gambling opportunities and the almost
inevitable accompanying increase in problem gambling.
2. Introduction
The Salvation Army is grateful for
the opportunity to give its views on the Draft Gambling Bill.
It supports the licensing objectives outlined in the draft Bill
wholeheartedly, particularly the need to protect children and
vulnerable people from being harmed or exploited by gambling.
The Salvation Army is a Christian church
and the largest and most diverse provider of social care in the
UK after the Government. The Salvation Army works with many of
society's most disadvantaged people and aims to offer practical
help wherever the need is great. However, The Salvation Army is
also committed to the pursuit of social justice and it is this
that drives it to seek to influence public policy in ways that
protect the vulnerable.
The Salvation Army is happy to support
the specific comments made in the response of The Methodist Church.
3. General Comments
The Salvation Army accepts that for
most people gambling is an enjoyable leisure activity, although
it notes with interest that even the Secretary of State only goes
so far as to call it 'predominantly harmless'. For a minority
of people, however, gambling is anything but harmless. Its effects
can ruin lives, destroy relationships and tear apart families.
The Salvation Army recognises that the Government has a difficult
and precarious balance to strike but it is concerned that in some
instances liberalisation is outpacing research into the consequences.
In anticipation of the draft Bill The
Salvation Army commissioned public opinion research from NOP into
the public's attitude towards some of the issues found in the
Bill. The research, which will be referred to in more detail throughout
the submission, showed that:
- 93% of the population thinks there
are enough opportunities to gamble in Britain at the moment;
- 82% of the population believes
that children under the age of 18 should not be allowed to play
fruit machines;
- 94% of the population thought that
allowing people to gamble using credit cards would put people
at greater risk of incurring gambling debts;
- 82% of the population thought that
people were more likely to lose money if they drank alcohol while
gambling;
- 56% of the population, and 64%
of women, would not be happy for a casino to open near to where
they live.[9]
The Government has admitted that the
new gambling regime will see a substantial increase in gambling
opportunities but the research conducted for The Salvation Army
shows that there is virtually no public demand for this. The Salvation
Army would question, therefore, the need for the expansion of
an industry which the population thinks is large enough already.
In a speech to Gamcare's 2003 annual
conference Richard Caborn MP said that the Government would be
disappointed if the number of people addicted to gambling rose
after liberalisation. The Salvation Army inquired then, and is
still yet to ascertain, how the Government intends to reduce the
percentage of gamblers who have a problem, for if the percentage
remains static, but the number of people gambling goes up, then
the number of problem gamblers will also rise. As far as The Salvation
Army is aware the Government has not stated publicly that a rise
in gambling opportunities, particularly of the more addictive
types such as casinos, will almost definitely lead to a rise in
the number of problem gamblers.
The Salvation Army believes that in
every instance where the Government plans to relax current restrictions
extensive research should be carried out as to the likely effects.
The Government should fund research as the process moves forward
and commit in the strongest terms to reversing any decisions which
are having negative social consequences. It is a concern that
'vulnerable people' are not defined in the draft Bill.
The Salvation Army welcomes the proposal
that the gambling industry should contribute towards the cost
of treatment for problem gamblers. However, it is concerned that
a figure of £3m is woefully inadequate given the likely upsurge
in the number of gambling opportunities and the almost inevitable
accompanying increase in problem gambling.
4. Children and young people
The Salvation Army wholeheartedly supports
the Government in its stance that 'gambling is for adults only'.
It believes that gambling safely requires life experiences and
maturity which can only be guaranteed, and then only imperfectly,
by excluding children and young people. The best available evidence
strongly suggests a correlation between starting to gamble at
a young age and problem gambling in later life. Dr Sue Fisher
has found a noticeable association between problem gambling and
starting gambling at 14 or younger. She found that 64% of severe
problem gamblers and 50% of problem gamblers had started gambling
at age 14 or below whereas only 16% of social gamblers had started
gambling by the age of 14.[10]
The Salvation Army welcomes the new offences that will be created
by the Bill in relation to 16- and 17-year-olds seeking to gamble
and, even more importantly, for adults who enable or permit anyone
under the age of 18 to gamble.
The Salvation Army is very disappointed,
however, that having outlined its commitment to maintaining gambling
as an 'adults only' activity the Government plans to allow children
to have free access to 'Category D' gaming machines. For children
of any age a £5 prize is not an insignificant attraction.
However, it is the wider principle that is more important. The
only difference between a Category A machine and a Category D
machine is the size of the stake and prize; the process involved
is exactly the same. By allowing children and young people under
the age of 18 to play Category D machines the Government is diluting
its main message about protecting children by implying that gambling
is, in fact, acceptable for children as long as the amount of
money involved is low. That is a very different position to stating
that gambling is only for adults.
The Government is also out of step
with public opinion on the issue of allowing children to play
fruit machines. In the survey carried out by NOP for The Salvation
Army 82% of respondents did not think that children under 18 should
be allowed to play fruit machines. It was pointed out to respondents
that children would be allowed to play only 'some types of fruit
machine' but the response was overwhelmingly negative.
The fact that Category D machines will
be readily available to children in non-gambling outlets means
that they will be virtually unregulated. There will be no mechanism
to monitor the playing habits of young children in many of these
venues. Again, The Salvation Army believes this runs contrary
to the Government's stated intention of protecting vulnerable
young people.
The same could be said of the anomaly
which allows children to play the National Lottery and football
pools. Here the inference is that it is acceptable for children
to gamble as long as the activity is 'relatively low risk'.[11]
The Government may be right about the relatively low risk, although
the Gambling Prevalence Survey 2000 showed that something as supposedly
innocuous as the National Lottery has the possibility of being
addictive in its own right, but in its statement of policy the
Government does not qualify its view that gambling is only for
adults. It does not distinguish between 'high' and 'low' risk
gambling. In practice, however, the Government's policy is qualified
to an unacceptable degree.
5. Casinos
The Salvation Army is very concerned
about the increase in casinos that will be brought about by the
proposals in the draft Bill. Research has shown that the types
of gambling offered by casinos are among the most addictive and
any increase in casino-based gambling is likely to cause a disproportionately
higher increase in problem gambling than an increase in other
forms of gambling.
The Government is aware of the level
of disquiet in communities mooted as potential locations for new
casinos. Indeed, the research commissioned by The Salvation Army
from NOP shows that 56% of the population as a whole, and 64%
of women, would not be happy for a casino to open near to where
they live. Communities must be given the opportunity to express
their concerns and fears in the planning process - and these concerns
and fears must be listened to. Moreover, the planning regime should
enable social factors to be taken into account when decisions
are made. The Salvation Army is concerned that the draft Bill
seems to enable only those who live very near to a proposed casino
to object. This is completely unacceptable when one is considering
introducing gambling facilities on a scale never seen before in
Britain. The Salvation Army proposes that anyone within the 'catchment
area' of a proposed casino should be able to object.
The Salvation Army is very concerned
about the mixing of gambling and alcohol. The Government rightly
points out that gambling is an adult activity that requires mature
brain functionality and developed cognitive reasoning. Alcohol,
in virtually any quantity, reduces cognitive functionality substantially
and increases the likelihood of making rash choices. Indeed, in
the NOP research carried out for The Salvation Army 82% of the
population said that they thought people were more likely to lose
money if they drank alcohol while gambling. The Salvation Army
is concerned that the recent decision to allow alcohol onto the
gaming floor of casinos was made with little consultation or,
to the best of its knowledge, research into the potential effects.
It is this kind of decision that makes The Salvation Army nervous
about the amount of 'flexibility' in the draft Bill. The Salvation
Army believes that there should be a clear demarcation in mixed
entertainment complexes between areas where alcohol is served
and areas where gambling is allowed.
The Salvation Army also thinks that
there is a very strong case for keeping the membership requirement
for casinos, even if membership is available immediately upon
production of identity documents. This adds another check to the
system and requires people to pause before playing.
6. Credit
The Salvation Army is very concerned
about the possibility of extending the availability of gambling
with credit. This view seems to be shared by the population as
a whole, 94% of whom think that making gambling with credit cards
more widespread puts people at greater risk of incurring gambling
debts. Given the current fears about the level of consumer debt
it seems the wrong moment to be legislating for gambling with
credit. The Salvation Army is aware that some gambling can already
be undertaken using credit cards but it believes the Government
could use this opportunity to tighten up that area. There are
many other ways of paying for gambling products that offer less
of a risk to the financially vulnerable. Gambling debts on credit
offer a double penalty - the gambler has to pay back the loss
and the interest.
7. Internet gambling
The Government is absolutely right
to address the area of internet gambling which is an ever-growing
concern. Initial research seems to show that gambling on the internet
may be more addictive than many other forms of gambling although
far more work needs to be carried out in this area. The Salvation
Army believes that the dangers inherent in internet gambling may
warrant its exclusion from the forms of gambling permitted in
Britain, particularly as countries that have lived with internet
gambling for a short time, such as the USA, are reassessing their
position following the negative social impact.
However, it has to be recognised that
internet gambling is already available to British citizens through
websites registered abroad which are subject to minimal or no
regulation. Therefore, with great caution The Salvation Army supports
the Government's proposals to licence internet gambling in Britain
as long as the most rigorous social responsibility codes are enacted
to protect children and vulnerable adults.
As an extra precaution, given the higher
addictive possibilities of internet gambling, The Salvation Army
thinks that credit cards should not be used as a method of payment.
It is recognised that many sites may wish to use credit cards
as a way of authenticating a person's age but it would be completely
unacceptable for knowledge of a valid credit card number alone
to be taken as proof of age. The current National Lottery website
runs successfully only using debit cards and also adheres to age
verification guidelines using iAC (interactiveAgeCheck). The site
also gives users the opportunity to self-exclude and includes
regular 'reality checks'. The Salvation Army believes that this
site exhibits many elements of good practice and, although not
perfect, shows that credit cards are not necessary to verify age.
8. Conclusion
In many ways problem gambling is an
unseen addiction but where it exists it can cause havoc in people's
lives and tear families apart. The theme running through the NOP
research conducted on behalf of The Salvation Army is that the
Government is out of step with the public on many issues raised
in the draft Gambling Bill. There seems little or no demand for
an increase in gambling opportunities. Despite talk of regeneration,
with 'resort casinos' for example, it seems the people who will
truly benefit from the proposed legislation are the gambling industry,
which stands to make substantial profits, and the Government through
increased tax revenue.
The Salvation Army supports the Government
in its aim to protect children and the vulnerable but fears that
the legislation as it stands paves the way for a substantial increase
in problem gambling with all the associated social costs.
9 NOP poll
was conducted by telephone between 28-30th November
2003 amongst a nationally representative sample of 973 adults
aged 18 and over. Back
10 Fisher, S,
'Gambling and problem gambling in British adolescents', a report
to a consortium of the British casino industry, University of
Plymouth quoted in Orford, J, Sproston, K, Erens, B, White, C,
& Mitchell, L, Gambling and Problem Gambling in Britain
(London, Brunner-Routledge) 2003. Back
11 Draft Gambling
Bill: The Policy p. 49 Back
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