13 Complaints and Disputes      

13.1Code Provision
13.2Gambling Complaints and Disputes Overview
13.3Gambling Commission
13.4ADR Reportable Events
13.5Dispute Procedures
13.6Current Club Procedures and Terms and Conditions

13.1 Code Provision  

Social Responsibility code provision 6.1.1 within the LCCP details the licensee’s responsibilities concerning complaints and disputes. 

13.2 Gambling Complaints and Disputes Overview   


Formulating and implementing policies and training on how to deal with complaints and disputes helps operators achieve the Licensing Objective of “Ensuring that gambling is conducted in a fair and open way”. 


A complaint from a customer is normally made due to dissatisfaction with service, conduct, facilities or gambling issues. This section deals specifically with complaints relating to the outcome of a complainant’s gambling transaction. Operators must have a process in place for handling such complaints whether they have been communicated in person, e-mailed, by phone, or in writing.  


Schedule 1 to the Data Protection AWhat differentiates a Complaint from a Dispute is that complaints are handled, resolution sought and a conclusion is reached internally, when they are initially made. If no resolution can be reached at this first stage (usually involving senior staff or the Duty Manager), the complaint becomes a dispute and there must be an internal company procedure of one or more stages, involving senior management and/or compliance officers. When the internal process is exhausted and resolution has not been reached, the dispute is escalated further and must be referred to an external arbitrator or Alternative Dispute Resolution (ADR) entity.  


In the code above, the definition is as follows: 

In this code a complaint means a complaint about any aspect of the licensee’s conduct of the licensed activities, and a dispute is any complaint which: 

a) relates to the outcome of the complainant’s gambling transaction; and 

b) is not resolved at the first stage of the licensee’s complaints procedure. 


Typical complaints in a bingo premises range from trivial (when no formal action is required) such as coins not registering, to more serious matters such as late or missed claims, prize money queries and gaming machine malfunctions.  


A suitable form should be available to record the type of complaint, detailing when it was made, the circumstances of the complaint and who was involved. Any evidence if required (such as photographs, print-outs and CCTV footage) should be kept for reference during a dispute process and the outcome or any decision made should be recorded. 

13.3 Gambling Commission     


Complaints or Disputes that are reported to the Gambling Commission are restricted to gambling activities and not commercial activities relating to the Bar, catering or décor as they are areas generally outside the Licensing Objectives and the Gambling Commission remit. 


Complaints that are resolved internally do not need to be reported to the Gambling Commission (unless it is a reportable event); it is only when complaints are not resolved at the initial club stage of the procedure and the complaint becomes a dispute, that records must be kept for the Gambling Commission. These records must then be reported through the Annual Regulatory Return, irrespective of the outcome. Your company policy and procedures will define which records are to be kept at each stage and for how long. 

13.4 ADR Reportable Events      

Licence Condition 15.2.2 (Other reportable events) sets out the responsibility of the licensee to inform the Gambling Commission in regard to the outcome of any dispute that is referred to an ADR entity.

1. ‘Licensees must also notify the Commission in such form or manner as the Commission may from time to time specify, or ensure that the Commission is so notified, as soon as reasonably practicable, of the occurrence of the following events: 

a) the conclusion of a dispute referred to an ADR entity and in such case providing the Commission with a copy of the decision or note of the outcome’ 

In respect of the referral of disputes to an ADR entity, the licensee’s attention is drawn to social responsibility code provision 6 (this relates to code provision 6.1.1 which is shown at the beginning of this section). 

13.5 Dispute Procedures      

The Bingo Association’s Alternative Dispute Resolution procedure is undertaken by IBAS. 

13.6 Current Club Procedures and Terms and Conditions       


A copy of the Club/Company complaints procedure should be on the staff notice board and available as a leaflet to customers. The policy should illustrate the various stages of the customer complaint process, time-scales, confidentiality and contact details. 


Management and staff should be trained in company policies and procedures about how to deal with a complaint. 


Customers making a complaint should be advised of the confidential nature of the dispute investigation process. 


It is best practice to let the customer know what recordings and data will be retained in order to aid any investigation of a dispute and also the sharing with the customer, all information used by the operator in coming to a decision.