Gambling Commission Continues Rolling Programme of Test-Purchasing

late August bank holiday weekend already seems a distant memory, but the
Gambling Commission used it to announce its latest round of underage test
purchasing, which continues.

Commission said that tests of smaller adult gaming centre and independent
betting shop premises earlier in the summer had revealed some weaknesses in
operators’ systems for identifying and challenging youngsters who enter the
premises hoping to play gaming machines. Those tests were conducted in
collaboration with local authorities and the police, and focussed upon access
to gaming machines by young people who did not seek interaction with staff
first, in order to assess operators’ ability to identify and prevent underage

the past, the Commission has carried out test purchasing whereby the youngsters
did interact with staff by, for example, visiting the cash desk for change.
This gave staff the chance to identify and challenge them. In the tests earlier
this summer, the Commission found that, in over half the cases, young persons
were able to access premises and play the machines, reflecting, it said, its
concerns that certain sections of the industry do not have sufficient
safeguards in place.

Commission further said that it was expecting to see an improvement in results
as the programme, which was due to last “for the next few months”, continued.
No doubt it will make known its findings in due course.

from the programme have been those operators who have persuaded the Commission
that they are effectively monitoring their policies, either by using third
party testing companies and sharing the results with the Commission, or who are
members of trade associations that make test purchasing schemes available to

approach of the Commission under this latest initiative is consistent with its
May 2011 Guidance Note on Test Purchasing. It will not generally prioritise the
practice in sectors and on themes where operators have their own arrangements
for monitoring compliance. It will inform the sector potentially affected of
its intentions, in general terms, before the exercise starts and it will
re-test premises that fail a short time later. Additionally, the Commission
will aim to inform operators at the earliest possible opportunity once the
testing of all of their premises is complete, to enable them to conduct any
investigation or re-training that might be necessary.

is the operator’s responsibility to inform its staff of the outcome of test
purchasing, to manage that outcome and to secure future compliance. Dependent
on the results of the exercise, operators may be required to supply details of
an improvement programme.

I mentioned, the responsibilities of the Commission and of licensing
authorities overlap when it comes to enforcing the law on underage gambling.
Generally, the licensing authority is responsible for securing compliance
within its geographical boundary, whereas the Commission focusses more on
issues which might be of wider significance and have the potential to have an
impact at a regional or national level. The fact that the Commission is working
in partnership with licensing authorities on this project is an indication of
its concerns that certain sectors of the gambling industry appear to be
demonstrating weaknesses across the board.

who have yet to be tested should certainly refresh their minds in relation to
their policies and procedures for identifying and excluding those who are
underage, ensure that all relevant staff are clear about their obligations in
this regard and know how best to meet them, and check to see that all
supporting documentation, including training records, for example, is complete
and up-to-date.