7 Self-Exclusion
7.1 | Introduction |
7.2 | LCCP Self-Exclusion Code Provisions |
7.3 | The Bingo Industry Self-Exclusion Scheme (BISES) General Overview |
7.4 | Process Overview |
7.5 | Withdrawal of the hard copy Self-Exclusion and Reinstatement Forms |
7.6 | Bingo Industry Self-Exclusion Scheme (BISES) Database |
7.7 | Reinstatement |
7.8 | Self-Exclusion Audit Trail/Reporting |
7.9 | Breaches |
7.10 | User Guides |
7.11 | Website Links |
Appendix A – Self-Exclusion Interviews Retail Bingo Summary | |
Appendix B – Self-Exclusion Interviews High Street Bingo Summary | |
Appendix C – The Bingo Industry Self-Exclusion Scheme Information Leaflet | |
Appendix D – Taking a Self-Exclusion Customer Photograph |
Licensing Objective: Protecting children and other vulnerable persons, from being harmed or exploited by gambling
7.1 Introduction
7.1.1
Section 6 of the Operators’ Handbook (Customer Interaction) covered the requirements for operators on how to deal with customers whose behaviour may indicate that they are experiencing difficulties in controlling their gambling. It states that the Duty Manager (of the premises) should discuss the possibility of self-exclusion with any customer who admits to having lost control of their gambling or who are exhibiting symptoms of distress. All operators should ensure that there are leaflets available in club to inform customers of self-exclusion, what it entails and how they can request this, including an option to self-exclude without revisiting the premises.
7.1.2
Self-exclusion has limitations if only administered locally and the Responsible Gambling Trust’s “Operator-Based Approaches to Harm Minimisation in Gambling” report identified the ease with which someone who has self-excluded at one location or with one operator could continue to gamble at others. Consequently, there was a need to explore and develop ‘Multi-Operator Self-Exclusion Schemes’ to permit data and resource sharing, so that gamblers can have the choice of a more comprehensive reach when they take the decision to self-exclude. The Gambling Commission supported this approach and following the subsequent LCCP changes, The Bingo Association developed a national multi-operator self-exclusion scheme for licensed bingo operators which allows an individual to make a single request to self-exclude from bingo. The scheme known as the Bingo Industry Self-Exclusion Scheme (BISES) has been designed to facilitate compliance with the LCCP and thereby protect the customer’s welfare, by providing a scheme that covers all types of licensed bingo operation, whether traditional retail clubs, high street, or holiday parks.
7.1.3
In this section of the Operators’ Handbook, self-exclusion is considered in terms of the regulations set out in the LCCP and the practical steps to be followed when a customer requests self-exclusion. The process ends by placing a record of the customer’s details on to the national self-exclusion database and the customer’s self-exclusion becomes active across all premises operated by members of The Bingo Association.
Customer data and photographs
7.1.4
The protection of customer data and the prohibition on its use commercially, or without The Bingo Association’s permission is detailed in a separate sub-licence agreement between the Bingo Association and members that use BISES. It is important that all Bingo Association members are aware that they must not store or print images of individuals and that they must put procedures in place to ensure that once a digital image is uploaded to the database, that any images stored locally (on cameras or on cloud storage) must be deleted. The Bingo Association is registered with the ICO as a data controller to allow the retention of personal data and images that are on the self-exclusion database.
7.1.5
The style, face size and photo quality must be suitable for recognition by other self-exclusion scheme users. The guidelines in appendix D are based on a passport photo and should be adhered to, in order to prevent the self-exclusion application being refused by The Bingo Association, due to a poor quality image. Please read, photocopy and ensure that all senior staff follow the instructions in appendix D, so that a quality photograph is taken of your self-excluding customer.
7.1.6
Passwords
a) Your compliance department will advise you on how often you should change your passwords for access to the BISES system.
b) A process must be put in place to remove passwords that were issued to members of staff when they cease employment with the company.
7.2 LCCP Self-Exclusion Code Provisions
The social responsibility code provision 3.5.1 for self-exclusion is specific in that it requires operators to ensure the following:
Social responsibility code provision 3.5.1
Self-exclusion non-remote SR code
- Licensees must have and put into effect procedures for self-exclusion and take all reasonable steps to refuse service or to otherwise prevent an individual who has entered a self-exclusion agreement from participating in gambling.
- Licensees must, as soon as practicable, take all reasonable steps to prevent any marketing material being sent to a self-excluded customer.
- Licensees must take steps to remove the name and details of a self-excluded individual from any marketing databases used by the company or group (or otherwise flag that person as an individual to whom marketing material must not be sent), within two days of receiving the completed self-exclusion notification.
- This covers any marketing material relating to gambling, or other activities that take place on the premises where gambling may take place. However, it would not extend to blanket marketing which is targeted at a particular geographical area and where the excluded individual would not knowingly be included.
- Licensees must close any customer accounts of an individual who has entered a self-exclusion agreement and return any funds held in the customer account. It is not sufficient merely to prevent an individual from withdrawing funds from their customer account whilst still accepting wagers from them. Where the giving of credit is permitted, the licensee may retain details of the amount owed to them by the individual, although the account must not be active.
- Licensees must put into effect procedures designed to ensure that an individual who has self-excluded cannot gain access to gambling. These procedures must include:
a) a register of those excluded with appropriate records (name, address, other details, and any membership or account details that may be held by the operator)
b) photo identification (except where the Licensee can reasonably satisfy themselves that in the circumstances in which they provide facilities for gambling an alternative means of identification is at least as effective) and a signature;
c) staff training to ensure that staff are able to enforce the systems
d) the removal of those persons found in the gambling area or attempting to gamble from the premises. - Licensees must ensure that their procedures for preventing access to gambling by self-excluded individuals take account of the structure and layout of the gambling premises.
- Licensees must, when administering the self-exclusion agreement, signpost the individual to counselling and support services.
Additional requirements for operators are set out in the ordinary code provision 3.5.2
Ordinary code provision 3.5.2
Self-exclusion non remote ordinary code
- Self-exclusion procedures should require individuals to take positive action in order to self-exclude. This can be a signature on a self-exclusion form.
- Individuals should be able to self-exclude without having to enter gambling premises.
- Before an individual self-excludes, licensees should provide or make available sufficient information about what the consequences of self-exclusion are.
- Licensees should take all reasonable steps to extend the self-exclusion to premises of the same type owned by the operator in the customer’s local area. In setting the bounds of that area licensees may take into account the customer’s address (if known to them), anything else known to them about the distance the customer ordinarily travels to gamble and any specific request the customer may make.
- Licensees should encourage the customer to consider extending their self-exclusion to other licensees’ gambling premises in the customer’s local area.
- Customers should be given the opportunity to discuss self-exclusion in private, where possible.
- Licensees should take steps to ensure that:
a) the minimum self-exclusion period offered is of a duration of not less than 6 nor more than 12 months;
b) any self-exclusion may, on request, be extended for one or more further periods of at least 6 months each;
c) a customer who has decided to enter a self exclusion agreement is given the opportunity to do so immediately without any cooling-off period. However, if the customer wishes to consider the self-exclusion further (for example to discuss with problem gambling groups), the customer may return at a later date to enter into self-exclusion;
d) at the end of the period chosen by the customer, the self-exclusion remains in place for a further 6 months, unless the customer takes positive action in order to gamble again;
e) where a customer chooses not to renew the self-exclusion, and makes a positive request to begin gambling again during the 6-month period following the end of their initial self-exclusion, the customer is given one day to cool off before being allowed access to gambling facilities. The contact must be made via phone or in person; and
f) not withstanding the expiry of the period of self-exclusion chosen by a customer, no marketing material should be sent to them unless and until they have asked for or agreed to accept such material. - The licensee should retain the records relating to a self-exclusion agreement at least for the length of the self-exclusion agreement plus a further 6 months.
- (Please note that the Commission does not require the licensee to carry out any particular assessment or make any judgement as to whether the previously self- excluded individual should again be permitted access to gambling. The requirement to take positive action in person or over the phone is purely to
a) check that the customer has considered the decision to access gambling again and allow them to consider the implications; and
b) implement the one day cooling-off period and explain why this has been put in place.) - Licensees should have, and put into effect, policies and procedures which recognise, seek to guard against and otherwise address, the fact that some individuals who have self-excluded might attempt to breach their exclusion without entering a gambling premises, for example, by getting another to gamble on their behalf.
- Licensees should have effective systems in place to inform all venue staff of self-excluded individuals who have recently attempted to breach a self-exclusion in that venue, and the licensees neighbouring venues.
- In providing training to staff on their responsibilities for self-exclusion, licensees should have, as a minimum, policies for induction training and refresher training.
An additional Social Responsibility Code Provision (3.5.6).
Social Responsibility Code Provision 3.5.6
Self-exclusion non remote
- Licensees must offer customers with whom they enter into a self-exclusion agreement in respect of facilities for any kind of gambling offered by them the ability to self-exclude from facilities for the same kind of gambling offered in their locality by any other holder of an operating licence to whom this provision applies, by participating in one or more available multi-operator self-exclusion schemes.
Ordinary code provision (3.5.7)
Ordinary Code Provision 3.5.7 (effective 8th May 2015)
Self-exclusion non remote
- Licensees should contribute to and participate in the development and effective implementation of multi-operator self-exclusions schemes with the aim of making available to customers the ability to self-exclude from facilities for gambling provided by other licensed operators within their local area(s).
7.3 The Bingo Industry Self-Exclusion (BISES) Scheme General Overview
Retail Clubs, Holiday Parks and High Street Bingo licensed premises)
7.3.1
The Bingo Association, working with leading bingo operators, ISD Group (ISD) and IHL Tech Ltd (IHL) to provide a digital self-exclusion solution to all members. When a customer requests self-exclusion; and the interview process has been concluded, the exclusion is carried out using
SmartEXCLUSION app – a tablet-based solution provided by The Bingo Association. During the process, the tablet assists in collecting the personal details, an image and signature, including exclusion preferences and then automatically uploaded on to the Bingo Industry Self-Exclusion Scheme (BISES) database.
[NOTE: If the SmartEXCLUSION tablet is not available due to downtime, software maintenance, hardware/software fault or connectivity issues, then temporary access will be given to an online portal to process the Self- Exclusion. For any queries, please contact The Bingo Association on 01582 860921 or by email: info@bingo-association.co.uk.]
7.3.2
Exclusions from any licensed bingo venue are included on BISES which is applicable to Retail Clubs, Holiday Parks and then to any High Street Bingo venue with the same post code prefix.
7.3.3
Exclusions from a High Street Bingo venue are added to BISES for retail clubs but are only applicable to other High Street Bingo venues inside the chosen radius.
7.3.4
The information is uploaded to the BISES database. A gallery of excluders appears on the tablet in each venue.
a) For traditional Retail Bingo venues, the gallery shows all excluders, in a newest to oldest order by exclusion date. This can be filtered by nearest first. The gallery is searchable by name.
b) For High Street Bingo and Holiday Park venues, the gallery shows all applicable exclusions with the same filters available.
7.3.5
The BISES database can be accessed automatically from your membership system through an API which allows you to perform lookups for new member details or current members who exclude between visits.
a) Where a club has membership card readers connected through their membership system to BISES, any self-excluded customer attempting entry by swiping a membership card that has not been confiscated, will prompt a warning message on the membership monitors, indicating that there is a problem with the membership card and that the member should report to reception. At the same time, reception will get a warning message that there has been an attempted breach.
b) When a new member applies for membership, the details entered on to the membership system are automatically checked against the BISES database and flagged if there is a match. Where a match is detected, the membership application is refused.
7.3.6
Authorised staff from all the BA member clubs have secure access to the excluder information. The gallery contains only Full Name, image and exclusion start and end date, plus the excluding venue.
7.3.7
Retail clubs who use a membership solution without current API access will be provided with the relevant API call details and be responsible for ensuring these are written to correctly.
Holiday Parks
7.3.8
Given the seasonal nature of Holiday Parks’ business and the difficulty of identifying individuals who are spending a short period of time on a Holiday Park, The Bingo Association has agreed with the Gambling Commission that a customer who has self-excluded through BISES must inform the Holiday Park operator if they intended to visit a holiday park and must also inform reception staff on their arrival at the park. This is covered in the self-exclusion terms and conditions (point 1) which states: ‘To activate your self-exclusion at any Holiday Park that you plan to visit, it is your responsibility to inform the Holiday Park before your arrival that you have self-excluded from playing bingo. A list of such member operators is available on The Bingo Association website: www.bingo-association.co.uk
7.3.9
On arrival at the Holiday Park, the customer must alert reception that they are self-excluded from playing bingo and gaming machines. A member of management with licence responsibility should discreetly remind the customer of their agreement and responsibilities and inform the relevant bingo staff and security that the customer is self-excluded from playing bingo and gaming machines. The operator will ensure that their entertainment staff and other relevant members of staff have seen a photograph of any self-excluded guest. If a customer indicates that they wish to self-exclude within the bingo licensed area during a visit to a Holiday Park, arrangements must be in place for the compliance or Duty Manager to be informed and the self-exclusion process must be undertaken using the SmartEXCLUSION tablet provided.
Leaflets and customer information
7.3.10
Leaflets and customer information must be made available in club, explaining about self-exclusion and also informing the customer of their option to self-exclude without attending the premises.
Training and Customer Interview
7.3.11
Self-exclusion training must be given to all members of management and senior staff that are likely to be on a Duty Manager rota. The process to be followed must be clear to all relevant members of staff. If a customer requests self-exclusion, a trained member of staff must conduct an interview with the customer to ensure that they understand what self-exclusion entails. The relevant self-exclusion interview script (Appendix A) should be used to ensure that a customer receives a consistent and comprehensive briefing on what the self-exclusion process involves and what their obligations are, once the agreement is signed. This script can also be used during an interview carried out by telephone, if a customer requests to self-exclude off-site. Procedures must be put in place to facilitate this, by providing a club telephone number or e-mail address where a customer may request self-exclusion without visiting the premises. An interview must take place and the details entered into the SmartEXCLUSION tablet, together with a digital image of the customer. Once submitted, the customer will be e-mailed a copy of the completed self-exclusion together with the terms and conditions of their self-exclusion. It is important that the identity of the customer is verified before processing the self-exclusion. This can be done by checking their details against your membership records or by requesting an image of the customers’ driving licence or another form of photographic ID.
7.3.12
Staff training for self-exclusion should include an understanding of the Code provisions relating to customer interaction (see section 14.6.1 of the Operators Handbook) as well as the Self-Exclusion terms and conditions.
7.4 Process Overview
7.4.1
Following an interview to discuss self-exclusion at the end of which the customer decides to proceed with self-exclusion, the self-exclusion must be completed using the SmartEXCLUSION tablet and a digital image of the customer acquired. The completed self-exclusion, along with the terms and conditions, must be given to the customer as a record of their self-exclusion agreement and its duration by any reasonable means necessary. The completed self-exclusion records all of the details required for a customer’s self-exclusion. The information on the digital form, the customer’s photograph, the terms and conditions, and the customer’s digital acceptance form a comprehensive agreement for self-exclusion between the customer and the operator.
Images
7.4.2
A digital image is essential. If the customer refuses to have their photograph taken, the self-exclusion cannot proceed. It is advised that in these circumstances, where the customer will not fully commit to their own self-exclusion, barring the customer from all your premises is the appropriate course of action. This approach is supported by the Gambling Commission. Furthermore; you must not use images from CCTV or from Facebook or other Social Media. If an image has been obtained, save the image to the local drive on your PC or tablet for upload into your Membership system, or directly on to BISES (See Resources Centre). The image must be deleted locally when it is successfully uploaded.
7.4.3
Personal cameras must not be used as images are often automatically copied to commercial cloud storage and this will result in a clear breach of data protection regulations. Local images must be deleted after they are uploaded to the BISES database.
7.4.4
When the self-exclusion is digitally signed and a photograph obtained, the details must be uploaded to the BISES database via the SmartEXCLUSION tablet as soon as possible, but within 24 hours. A copy of the agreement is automatically emailed to the customer. These actions will exclude a customer from gambling in all retail bingo premises and the high street bingo licensed premises that the customer has chosen to self-exclude from and that are members of The Bingo Association. The exclusion will be with immediate effect for most premises and within 7 days for some operators.
Funds on electronic device
7.4.5
The SmartEXCLUSION form has a tick box where a customer indicates if they have any funds held on an electronic device. Ascertain and verify the amount of customer funds held on any electronic bingo account and return the balance of funds to the customer. Print a copy of the customer funds report from the electronic bingo system confirming the total amount of credit due to the customer together with a supporting ‘withdrawal of credit’ receipt where available. Ensure both the receipt and printout confirming total amount of funds are signed by the customer to confirm the amount of funds returned to them as part of the self-exclusion process. Retain signed copies and attach to the self-exclusion for audit purposes. Finally delist the customer from their electronic bingo account to prevent further use.
Online Bingo
7.4.6
If the customer has asked to be self-excluded from any online bingo account that is operated by your company, follow the relevant internal procedures and pass the details on to the relevant internal contacts or departments. This box must only be ticked if your company operates online bingo. Ticking this box will not exclude customers from other online websites.
Period of Self-Exclusion
7.4.7
A customer can only be excluded for a minimum period of 6 months and a maximum period of 12 months. At the end of the period this can be extended for one or more further periods of at least 6 months each.
Membership Cards
7.4.8
Recover the membership card(s) from the customer and shred so that the customer cannot attempt entry by using their membership card. Ask the customer to destroy any duplicate cards that they may have at home. The Maxim membership system will work with the self-exclusion system to identify current and duplicate cards that may subsequently be used by the customer, to obtain entry after they have requested self-exclusion. On real-time systems, when a customer is attempting to use a duplicate card at the membership card reader, the system will provide a message that the card is not valid and that the customer should report to the membership desk. A warning message will also appear at the membership desk to alert the staff. Where a self-excluded customer is identified whilst breaching or attempting to breach their self-exclusion, the customer should be challenged, their details checked and if confirmed, the customer should be asked to leave. The breach or attempted breach must be logged on the BISES system using the SmartEXCLUSION tablet.
Other gambling sectors
7.4.9
During the interview, a customer may ask to be excluded from gambling in other sectors. The bingo industry scheme does not link with other sector self-exclusion schemes. There are 3 options available:
- Direct the Customer to the self-exclusion page on the GamCare website
- Direct the customer to GAMSTOP for gambling websites and apps run by companies licensed in Great Britain.
- Direct the customer to the relevant trade association so that they can make direct contact. The trade associations’ telephone numbers are as follows:
a) Betting and Gaming Council (BGC) for betting shops, online gaming businesses and casinos, phone 0207 434 2111
b) British Amusement Catering Trade Association (BACTA) for machine arcades, phone 0207 730 6444
7.4.10
The Website addresses for GamCare, GAMSTOP and the Trade Associations can be found in the Resources Centre.
Signposting to Counselling and Support Services
7.4.11
During the self-exclusion interview and application process, the Manager or responsible person must ensure that the customer is directed to counselling and support services such as BeGambleAware and GamCare and provide the appropriate GamCare literature. This literature can be obtained direct from GamCare website (See Resources Centre) or by calling 020 7801 7000. It is suggested that a number of the GamCare leaflets available from this source are kept onsite to ensure that they are on hand.
7.4.12
Customers must also be given the relevant contact phone numbers below for key problem gambling help organisations. Help sheets for these organisations are in section 8 of this operators’ handbook and website links are available the end of this section.
a) GamCare and BeGambleAware Phone: 0808 802 0133 (National Gambling Helpline)
b) Gordon Moody Association Phone: 01384 241292
c) Gamblers Anonymous Phone: 08700 508880
d) The National Problem Gambling Clinic Phone: 020 7381 7722
e) National Debtline Phone: 0808 808 4000
7.5 Withdrawal of the hard copy Self-Exclusion and Reinstatement Forms
7.5.1
As of 31st March 2020, The Bingo Association will no longer be providing any hard copies of the self-exclusion application forms or reinstatement request forms to members. Instead, members must use the SmartEXCLUSION tablet, which has been provided to every member premises, for all Self-Exclusions and Reinstatements. For any queries, please contact The Bingo Association by phoning 01582 860921 or by email using the following contact address: info@bingo-association.co.uk.
7.6 Bingo Industry Self-Exclusion Scheme Database & website
The Bingo Association has produced the following guide ‘Access to the Bingo Industry Self-Exclusion Database and Website’, which is available on request by emailing info@bingo-association.co.uk and explains how to access the self-exclusion database, specifically for the local system that you have.
7.7 Reinstatement
7.7.1
A self-excluded person can decide that they wish to reinstate and request to be allowed to gamble again. The key things about this process are:
a) A reinstatement request cannot be made within the period of self-exclusion.
b) The details of any such a request must be entered on to BISES via the SmartEXCLUSION tablet and digitally signed by the customer.
c) The request may either be made in person or by phone.
d) Customers should be asked if they have considered the implications of gambling again.
e) A 24 hour cooling-off period must elapse between the customer’s application for reinstatement and being allowed to enter the premises for gambling.
f) Licensees are not required to carry out any assessment or make a judgment as to whether the previously self-excluded individual should be permitted to access gambling again.
7.7.2
Some operators will require that customer reinstatement following self-exclusion, can only be made at the request of that customer, either by telephone (by e-mail where this facility is available) or in person. If the request is made by phone, the customer should be asked to make an appointment with the Duty Manager in order to visit the premises to discuss reinstatement. The customer must be notified that there is a 24 hour cooling off period before they are permitted to gamble again. The details must then be uploaded to the BISES database as soon as possible.
7.7.3
The reinstatement request form can be completed on the SmartEXCLUSION tablet. The customer status will then be automatically updated on BISES.
7.7.4
The customer must actively opt-in to receive marketing materials; otherwise the operator must ensure that their name remains off the marketing database.
7.7.5
Where a membership system is used that connects directly to the BISES database (such as Maxim), the customer’s details will be updated automatically and the restrictions will be removed from the membership record. Management and relevant staff must be informed of the changes.
7.7.6 Removal of the Auto reinstatement process
Ordinary Code provision 3.5.2 7(d) states: ‘at the end of the period chosen by the customer, the self-exclusion remains in place for a further 6 months, unless the customer takes positive action in order to gamble again’. Although the self-exclusion period ends 6 months after the customers elected self-exclusion period of between 6-12 months, The Bingo Association and its members have agreed that the current retail bingo self-exclusion process should remain, i.e., there is no auto-reinstatement: all self-exclusions remain active unless reinstated, and must remain searchable on BISES via the tablet, with the marketing permission maintained at ‘no mailings’.
7.8 Self-Exclusion Audit Trail/Reporting
The number of customers who have self-excluded from your company’s licensed bingo premises should be recorded and made available in 2 ways:
a) to allow for inspection by the Local Licensing Authority or Gambling Commission.
b) to be recorded on the company’s Annual Regulatory Return
This information will be available on the self-exclusion reports for the company/premises designated within your login credentials. The Bingo Association has access to the national database and a report of all self-exclusions that have been entered on to the database.
7.9 Breaches
7.9.1
If a customer is prevented from entering a premises before they have participated in any gambling, an attempted breach will need to be recorded on the BISES system. If a member has entered the premises and participated in gambling either on machines or bingo of any kind, a breach will need to be recorded. For some operators, the attempted breach will be automatically generated on the BISES database. For others, a retrospective manual entry will be required.
7.9.2
If a customer enters the premises, (whether they take part in gambling or not), while their self-exclusion is active, they should be discreetly asked to leave immediately by the Duty Manager. If they have gambled/tried to gamble, all stake monies should be refunded and any winnings may be distributed to other players or given to charity at the discretion of the operator.
7.9.3
The incident should be recorded on the BISES database as an ‘attempted breach’ or ‘breach’ as appropriate and also on any company incident form that is required.
7.9.4
If necessary a letter should be sent to the member reminding them of their personal undertaking in their self-exclusion agreement and the earliest date that they can return to the bingo premises. Please consult your compliance department for the letter format.
7.9.5
Actual breaches may be notified by your Compliance Manager (where applicable) on a case by case basis to the Gambling Commission though must be included in the Annual Regulatory Return. The Bingo Association will also make periodic industry-wide reports to the Gambling Commission.
7.9.6
Staff training – You must be able to produce training records that demonstrate that customer interaction and self-exclusion training is actively taking place within your premises and incident reports are made, detailing actions taken in response to self-excluded customers being found on the premises.
7.10 User Guides
7.10.1
An interview script is provided in Appendix A (retail bingo premises) and Appendix B (High Street Bingo premises), to assist with your customer self-exclusion interview.
7.10.2
An information leaflet by the Bingo Association is provided in Appendix C to assist the customer’s understanding of self-exclusion and the implications before they reach the application stage.
7.10.3
There is a User Guide to assist you with using the BISES system which is available on request by emailing: info@bingo-association.co.uk
7.10.4
[NOTE: The guide may not be relevant to Mecca bingo club managers, as direct access to the website by clubs is not currently required, due to the central function that manages the system on their behalf.]
7.10.5
Two guidance sheets for the self-exclusion interview follow in Appendix A and B, Appendix C is a customer information leaflet and Appendix D explains the process of taking a self-exclusion customer photo. Item 5 is available on the Bingo Association website in the members’ area.
- Appendix A – Self-exclusion interviews – Retail Bingo
- Appendix B – Self-exclusion interviews – High Street Bingo
- Appendix C – The Bingo Industry Self-Exclusion Scheme – Information Leaflet
- Appendix D – Taking a self-exclusion customer Photograph
- Self-Exclusion Guide
7.11 Website Links
(Please see the Resources Centre).
Appendix A
Self-Exclusion Interviews Retail Bingo Summary
10 Steps to a successful Self-exclusion
- Conduct a one to one interview in a discreet location.
- Explain what self-exclusion is.
- Explain the consequences of self-exclusion.
- Ensure the customer understands that a photo is mandatory.
- Ensure the customer understands that self-exclusion is for a minimum period of 6 months and a maximum of 12 months.
- Ensure the customer knows that exclusion from traditional clubs is national and from high street premises is on a local basis.
- Reassure the customer that their personal data is held on a secure private database and is confidential.
- Ask the customer if they wish to self-exclude now.
- If yes, complete the self-exclusion on the SmartEXCLUSION tablet.
- Advise the customer that a copy of their self-exclusion will be emailed to them, along with the Terms & Conditions and give them a copy of the relevant GamCare/help leaflets.
The Self-Exclusion Guidance Notes – Retail Bingo
Under the terms of the Licensing Conditions and Codes of Practice (LCCP) a customer who asks to self-exclude should be interviewed in order that they understand what self-exclusion entails; the operator must provide, or make available, sufficient information about what the consequences of self-exclusion are.
Self-exclusion is a sensitive matter and should be dealt with by the club manager or someone else who is designated and suitably trained to undertake the self-exclusion interview. When a customer asks about self-excluding, they should be taken somewhere where this can be discussed in private.
If a customer prefers to self-exclude without entering the club, they can do so over the telephone or online. Customers can obtain guidance from their club or from the Bingo Association website at www.bingo-association.co.uk where they will find a self-exclusion tab which has all the necessary contact information.
The script below will ensure that a customer understands what self-exclusion means so that they can make an informed decision about self-exclusion. Every self-exclusion request must be accompanied with an image of the customer. Make sure that the customer understands that this is essential in order to process their request.
Suggested interview script:
“Before you make the decision to self-exclude, I must explain to you what self-exclusion means and what the consequences of your self-exclusion are. Everything that I explain to you is contained in the self-exclusion request form that you will be asked to sign digitally should you choose to self-exclude. Please listen carefully. When I have finished I will ask if you are sure that you want self-exclusion.
Asking for self-exclusion means that you have decided that you need help with a gambling problem and that you are asking bingo operators to help you stop gambling;
It is your decision not to enter a licensed bingo premises and we agree to help you. We expect complete commitment to the agreement from you and you MUST provide a photograph in order to be self-excluded. If you refuse, unfortunately you cannot enter the self-exclusion scheme. We strongly advise you to take steps to get help; I can give you details of some agencies.
This bingo operator is a member of the national Bingo Industry Self-Exclusion Scheme (BISES) and your self-exclusion will be supported throughout Great Britain in all traditional retail bingo premises. Your personal details will be shared on the BISES database in order for all members of the Association to be able to help you. Your details will also be shared with local high street gambling premises that hold a bingo licence and which share the same two letter prefix as the postcode of this club. Your personal details will NOT be shared with any third party. Non-personal data may be used for statistical analysis of problem gambling and may be shared with the Gambling Commission.
Your photograph will be shared on the BISES database to assist with your identification and self-exclusion. Please note, this will remain confidential along with all your data provided.
This means that if you ask for self-exclusion you will not be able to play bingo at any of these premises [give examples, for instance: you won’t be able to play at Mecca, Buzz, Castle, relevant Cashino premises for the period of your self-exclusion].
You may request to be self-excluded for a minimum of six months or for a maximum period of 12 months; you may extend your self-exclusion period by one or more periods of at least 6 months each when this period(s) reaches its end. You may also choose to reinstate at the end of your self-exclusion; you must request reinstatement and complete the relevant request. There is a 24 hour “cooling off” period before you will be able to gamble again.
The self-exclusion agreement means that you will sign an undertaking not to enter any licensed bingo premises for the requested period of self-exclusion and that you agree that you will not attempt to circumvent your self-exclusion. We offer our assistance to help you, but we cannot be held responsible if you succeed in circumventing your self-exclusion. Members of the Bingo industry self-exclusion scheme will take all reasonable steps to prevent you from entering a bingo licensed premises and gambling. If you are found to have gained access to a bingo licensed premises, you will be asked to leave. If you do breach your self-exclusion, any winnings that may arise from playing while self-excluded may be forfeited.
If you book to spend some time at a holiday park that offers bingo, you must inform the reception/management of the park when you arrive that you have self-excluded from bingo.
You will be given contact information so that you can contact counselling and support services
Do you understand what self-exclusion means? Do you want to proceed now? Do you want to consider this and contact us later if you want to proceed?
I have an online form using a SmartEXCLUSION tablet for you to complete which represents our agreement. Please read the details carefully before you sign it. Please ask me if you have any questions. Once the online form is complete and I have taken a photograph, your details will be uploaded on to the BISES database; it may take up to 7 days for all operators to update their systems. If you are a member of an online bingo site operated by this company, you can also request self-exclusion from that site. If you wish to do this, please tick the box on the online self-exclusion form.
Your details will be removed from the marketing database of the club that you self-excluded once your details have been submitted. Please be advised that it may take up to 7 days for other operators within the scheme to action this. Following the expiry of your self-exclusion period, you can only be added back to the marketing database if you specifically request it.
I will take away any membership cards that you have with you. If you have additional cards at home, please return them by post. If you have any credit held on a terminal, I will arrange for this money to be returned to you now. I have got some leaflets for you from GamCare with their contact details so that you can contact them for further help or counselling.
Do you have any further questions?
Appendix B
Self-Exclusion Interviews High Street Bingo Summary
10 Steps to a successful Self-exclusion
- Conduct a one to one interview in a discreet location.
- Explain what self-exclusion is.
- Explain the consequences of self-exclusion.
- Ensure the customer understands that capturing a photo is mandatory.
- Ensure the customer understands that self-exclusion is for a minimum period of 6 months and a maximum of 12 months.
- Ensure the customer knows that exclusion from high street premises is on a local basis and traditional retail bingo clubs is national.
- Reassure the customer that their personal data is held on a secure private database and is confidential.
- Ask the customer if they wish to self-exclude now.
- If yes, complete the self-exclusion on the SmartEXCLUSION tablet, take the photo and upload it to the self-exclusion site.
- Advise the customer that a copy of their self-exclusion will be emailed to them, along with the Terms & Conditions and give them a copy of the relevant GamCare/help leaflets.
The Self-Exclusion Guidance Notes – High Street Bingo
Under the terms of the Licensing Conditions and Codes of Practice (LCCP) a customer who asks to self-exclude should be interviewed in order that they understand what self-exclusion entails; the operator must provide, or make available, sufficient information about what the consequences of self-exclusion are.
Self-exclusion is a sensitive matter and should be dealt with by the duty manager or someone else who is designated and suitably trained to undertake the self-exclusion interview. When a customer asks about self-excluding, they should be taken somewhere where this can be discussed in private.
If a customer prefers to self-exclude without entering the venue, they can do so over the telephone or online. Customers can obtain guidance from their venue or from the Bingo Association website at www.bingo-association.co.uk where they will find a self-exclusion tab which has all the necessary contact information.
The script below will ensure that a customer understands what self-exclusion means so that they can make an informed decision about self-exclusion. Every self-exclusion request must be accompanied with an image of the customer. Make sure that the customer understands that this is essential in order to process their request.
Suggested interview script:
“Before you make the decision to self-exclude, I must explain to you what self-exclusion means and what the consequences of your self-exclusion are. Everything that I explain to you is contained in the self-exclusion request form that you will be asked to sign should you choose to self-exclude. Please listen carefully. When I have finished I will ask if you are sure that you want self-exclusion.
Asking for self-exclusion means that you have decided that you need help with a gambling problem and that you are asking bingo operators to help you stop gambling;
It is your decision not to enter a licensed bingo premises and we agree to help you. We expect complete commitment to the agreement from you and you MUST provide a photograph in order to be self-excluded. If you refuse, unfortunately you cannot enter the self-exclusion scheme. We strongly advise you to take steps to get help; I can give you details of some agencies.
This bingo operator is a member of the national Bingo Industry Self-Exclusion Scheme (BISES) and your self-exclusion will be supported throughout Great Britain in all traditional bingo premises and relevant local high street venues. Your personal details will be shared on the BISES database in order for all members of the Association to be able to help you. Your details will also be shared with local high street gambling premises that hold a bingo licence and which share the same two letter prefix as the postcode of this club. Your personal details will NOT be shared with any third party. Non-personal data may be used for statistical analysis of problem gambling and may be shared with the Gambling Commission.
Your photograph will be shared on the self-exclusion database to assist with your identification and self-exclusion. Please note, this will remain confidential along with all your data provided.
This means that if you ask for self-exclusion you will not be able to play bingo at any of these premises [give examples, for instance: you won’t be able to play at Mecca, Buzz, Castle, relevant Cashino premises] for the period of your self-exclusion.
You may request to be self-excluded for six months or for a maximum period of 12 months; you may extend your self-exclusion period by one or more periods of 6 months each when this period(s) reaches its end. You may also choose to reinstate at the end of your self-exclusion; you must request reinstatement and complete the relevant request. There is a 24 hour “cooling off” period before you will be able to gamble again.
The self-exclusion agreement means that you will sign an undertaking not to enter any bingo licensed premises for the requested period of self-exclusion and that you agree that you will not attempt to circumvent your self-exclusion. We offer our assistance to help you, but we cannot be held responsible if you succeed in circumventing your self-exclusion. Members of the bingo industry self-exclusion scheme will take all reasonable steps to prevent you from entering a bingo licensed premises and gambling. If you are found to have gained access to a bingo licensed premises, you will be asked to leave. If you do breach your self-exclusion, any winnings that may arise from playing while self-excluded may be forfeited.
If you book to spend some time at a holiday park that offers bingo, you must inform the reception/management of the park when you arrive that you have self-excluded for bingo.
You will be given contact information so that you can contact counselling and support services.
Do you understand what self-exclusion means? Do you want to proceed now? Do you want to consider this and contact us later if you want to proceed?
I have an online form using a SmartEXCLUSION tablet for you to complete which represents our agreement. Please ensure you have given the correct information and understand the terms and conditions before you sign it.
Please ask me if you have any questions. During the process I will take a photograph and your details will be uploaded on to the BISES database; it may take up to 7 days for all operators to update their systems.
Your details will be removed from the marketing database of the club that you self-excluded once your details have been submitted. Please be advised that it may take up to 7 days for other operators within the scheme to action this. Following the expiry of your self-exclusion period, you can only be added back to the marketing database if you specifically request it.
If you have any credit held on a terminal, I will arrange for this money to be returned to you now.
I have got some leaflets for you from GamCare with their contact details so that you can contact them for further help or counselling.
Do you have any further questions?
Appendix C
The Bingo Industry Self-Exclusion Scheme Information Leaflet
What is self-exclusion?
Self-exclusion is one of the ways that you can address any problems that you may be experiencing with your gambling. You can choose to exclude yourself from bingo and ask your bingo club operator to help you. Your club operator is a member of the national bingo industry self-exclusion scheme (BISES) which means that all members of this scheme will use their best endeavours to prevent you from entering their premises and gambling.
How long will I be excluded for?
You can choose to self-exclude for a minimum of six months and a maximum of twelve months.
Who is responsible for keeping me out of bingo clubs?
You are responsible for your actions and for your decision to request exclusion. By signing the self-exclusion request form, you undertake not to circumvent your agreement and try to enter a bingo club during your agreed self-exclusion period. However, bingo club operators will also do what they reasonably can to help you.
The National Bingo Industry Self-Exclusion scheme (BISES)
The Bingo Association has established a scheme to permit its members to record the details of all individuals who have self-excluded on a secure private database. Having these details means that clubs can check swiped membership cards and new member applications against the records of those people who have self-excluded. Your personal data is protected and will not be shared beyond the bingo club operators.
Can I just self-exclude from my local club?
No. Self-exclusion means that you are effectively excluded from all licensed bingo clubs in Great Britain and from certain other licensed bingo premises in the neighbourhood of your regular club.
How can I apply?
You can ask the club duty manager about the scheme, who will interview you in a discreet location and give you a full explanation of what self-exclusion is, help you to complete the request form and take a digital image should you decide to ask to self-exclude. Your details will be uploaded to the self-exclusion database. You can also apply by telephone to your club, if you prefer. The telephone number of your club is available online, or you can request this information from The Bingo Association by submitting a form via the webpage on www.bingo-association.co.uk
What other help can I get?
You should consider excluding from all other forms of gambling in Great Britain. A list of other self-exclusion schemes is set out on The Bingo Association’s website. There are also links to national agencies who can give you counselling and other personal support.
Appendix D
Taking a Self-Exclusion Customer Photograph
DO
Choose a well-lit area to take the photo with no backlight.
- Ask the customer to:
a. Remove any glasses or head coverings and push back any hair that obscures their face.
b. Face forward, eyes open, mouth closed and look at the camera, no smile is needed. - Take a close-up of the customers face, head and shoulders (passport style).
Check that the photograph:
- Is in focus.
- Has no shadows.
- Is bright enough to see the customer’s facial features clearly.
- Has no ‘red-eye’.
DO NOT use:
- CCTV images.
- Facebook or any other Social Media images.
Please note:
- A poor quality image may be rejected by the BA.
- The image should be deleted locally, after it has been transferred on to the BA self-exclusion system.
- To upload a photograph within Maxim, the photograph size needs to be less than 3MB.
Any self-exclusions processed without a suitable passport-style photo will be removed from BISES.