In fulfilment of its obligation under Article 180A(10)(f) of The Betting, Gaming, Lotteriesand Amusements (Northern Ireland) Order 1985 the Department for Communities is holding a consultation on an initial gambling Code of Practice.
The purpose of the code is to ensure gambling operations in NI are conducted in a fair and open way protect those under the legal age for gambling and other vulnerable persons from being harmed or exploited by gambling assist persons who are or may be affected by problems relating to gambling.
NI Sports Forum position
Scope: This Code of Practice will not be applicable to small lotteries or private lotteries run by voluntary led organisations but it is applicable to those running societies’ lotteries.
On review of the proposed Gambling Code of Practice, we welcome that some changes have taken place subsequent to the 2022 consultation and would highlight the following to try and clarify points:
- Clarification is needed regarding acceptance of credit or debit card payments for the likes of societies’ lotteries. These may be used as fundraising mechanisms and the nature of transactions (online and in person) is often through card transaction. Our concern is that this could adversely impact on clubs running society lotteries to raise funds for community benefit as individuals may often would use a credit card for purchasing online as a safer method of payment (e.g. fraud).
- The introduction to section 1.1 also needs to explicitly outline this is only in relation to gambling/ lottery activities.
- Through the Code, there is use of the term ‘premises’. 2.1 uses the term ‘locations’ and some clarity of the definition would aid readers.
- Section 5.1 – Clarification is needed “whether as fundraisers or as donors” – elements around donations appear to be covered in sections 1.1 and 2.4 already. 5.3 provides clear, tested guidance “Fundraising Involving Children” that should remain as the reference and be clear the section relates to fundraising.
- Section 5.2 risks confusing the rules for Societies Lotteries with those with streetcollections and house to collections. Collections are not a form of gambling andshould be removed from this Code of Practice on Gambling (see also NICVA position)
- Self Exclusion – Preamble or links to background information on what Customer Self Exclusion is would be helpful. For organisations (e.g. voluntary) looking to comply with this code and investigating the legislation, this would need signposted for full assessment.
NISF will be making a return on the basis of points above and welcomes further input from sports.