Q1. The Bingo Association’s policy is to avoid commenting on other sectors within the gambling industry. We seek to focus on promoting and developing the interests of all licensed bingo operators. This tends to be in contrast with both government and regulator who insist on using the gambling industry as a generic term in its narrative with the industry when in fact it is a loose coalition of operators in possession of different categories of gambling operating licence, with different conditions that they must comply with, operating in different environments with different types of consumer and with different levels of risk.
The licensed bingo industry can agree that the three primary aims of the Gambling Act 2005 are being upheld in Licensed Bingo but cannot comment on their application across other sectors.
Q2. The Bingo Association believes that the statutory instrument preventing the use of debit cards on gaming machines requires attention. Bingo clubs are increasingly the target for theft and armed robbery, this is because they are one of the few remaining locations where significant amounts of cash are kept on site. This creates a significant risk for the safety of our employees.
Consumer behaviour is also driving the cashless revolution and we believe bingo clubs should not be left behind through being unable to satisfy consumer demands. The concerns of bingo, as well as others in the business community, were articulated in responses to HM Treasury’s call for evidence on cash and digital payments, launched in March 2018. The Bingo Association recognises the reasons why the regulator and the government may hold reservations about allowing the use of debit cards from a safer gambling perspective and shares those concerns, but we believe that appropriate protocols could be implemented to regulate/limit spending on debit cards and these should be looked at and agreed as soon as possible.
Q3. The Bingo Association believes that licensed bingo operators are successfully regulated by the Gambling Commission and their local authorities. Bingo operators have chosen to retain membership as a requirement to play in their premises (in spite of the removal of this requirement by the Gambling Act 2005) which affords operators and their customers a significant degree of protection from potential harm.
Q4. For licensed bingo operators a duty of care to their customers is integral to the customer experience – so yes, in theory it should be a legal duty of care. The only caveat to this is agreeing an adequate definition of what scope a legal duty of care constitutes in practice and what the potential liabilities might be.
Q5. The Bingo Association finds this question very difficult to answer accurately. In July 2016, Ipsos MORI conducted an independent survey into problem gambling in bingo. It found levels of problem gambling to be relatively low in comparison to other forms of gambling (2.5 % of regular players). These figures have been underpinned by various prevalence and health surveys.
They also found that the average spend of a bingo player was £33 per visit. Undoubtedly for those few experiencing harm there will be some degree of impact and social cost. However, there is no metric available to evaluate this, if only because the amounts involved and numbers affected, are so small. The recently published Raising standards for consumers Enforcement report 2018/19 from the Gambling Commission contains a useful section on affordability benchmarks based on a YouGov survey. We believe this is not only a useful tool for managing interventions but that spending on Bingo is relatively affordable aspect of an individual’s disposable income.
Q6. There is considerably more information around the positive social and economic contribution that bingo clubs make to society. The Ipsos MORI research into problem gambling in bingo in 2016 devotes a chapter to this effect. The report concludes that a visit to a bingo club is a crucial lifeline to those whose ‘life circumstances limit their ability to participate in other leisure pursuits’. 92% of bingo customers attend their club with friends or family, and many make connections whilst at the bingo. It is therefore a social support system, where the key motivation for attending is to socialise and relieve isolation and boredom. Other benefits, as reported by the research, are that playing bingo improves mental agility, and offers a place in which to feel safe. The report concludes that length of time spent in a bingo club does not have a correlation with harm or spend; time spent gambling on a product is usually seen an indicator of harm by the DSM5 and PGSI tests.
Research by the University of Kent in 2016 on bingo and gambling regulation highlighted and endorsed the Mary Portas review of the high street. This states that bingo is a ‘brilliant way to bring people together’. The study concludes that there is a case that bingo’s distinctive social nature and player demographic should be deserving of a more bespoke approach to regulation.
In December 2013 Ernst & Young produced a study into the economic and social impacts of a bingo club closure on the UK economy. A bingo club in the Westcountry was taken as the club that was modelled. The study concluded that the economic loss after substitution was approximately £360,000 of Gross Value Added of £210,000 of tax contribution, eleven employees and eleven roles within the supply chain. Crucially, this was also without the social impact of the loss of a community-based leisure venue for a predominantly female (80%) middle aged (45+) and low income demographic.
Finally, a recent follow up study of the Whitehall 11 cohort study (August 12th, 2019) suggest a protective effect of social contact against dementia and that more frequent contact confers higher cognitive reserve. This finding was reported by The Sun newspaper and quotes one of the researchers Gill Livingston as saying amongst other things that ‘meeting in the pub, a bit of bingo, or out for dinner and a chat’ should be encouraged.
The Bingo Association recommends to members of the House of Lords select committee by way of an open invitation, a visit to a bingo club to witness how they are central to some communities and in particular to older people seeking fellowship and companionship in an age of well publicised loneliness.
Q7. The debate around the levy and whether it should be mandatory or not is one of the most frustrating debates in the gambling sector at present. The adequacy of the levy can only be determined once a comprehensive review is conducted to determine what is needed to address the problem. Otherwise it is just a guess, with the cart being positioned firmly before the horse.
Whilst efforts surrounding the collation of the voluntary levy and subsequently the amount raised from it has improved in recent years, there is still much that can be done to improve the reporting and administration of the funds raised. It is still very difficult to accurately report who is, and importantly who isn’t contributing the expected amount when contributions can still be made to organisations other than GambleAware and are therefore not reported publicly. There tends to be considerable misreporting of industry efforts as reports tend to be solely based on GambleAware reporting of its own receipts. In addition, companies representing businesses in different sectors tend not to split out their donation but give a lump sum, and there is still confusion about the definition of Gross Gaming Yield (GGY).
A mandatory levy, as the Labour Party is recommending, may improve the funds that can be dedicated towards research, education and treatment. However, The Bingo Association could never commit to such a method without first having an indication of the level at which it would be set. For example, total retail bingo GGY is £628m (2018/2019), which would mean that current contributions should be around £600,000. Or on current profitability, around 1.5% of annual profits.
If the levy was increased tenfold across the board to 1%, then this would require a contribution of £6m, or 15% of current Industry profitability. Such an impact on profitability would decimate an industry which is generally accepted to be at the lower end of the problem gambling risk profile. Therefore, The Bingo Association could only support a mandatory levy if the equivalent overall contribution remained the same as 0.1%.
Q8. The Bingo Association would welcome some clarity and leadership on the research debate. We, like many other gambling operators, have many questions that remain unanswered, these include, but aren’t limited to, the following:
This dilemma is hampering progress, which ultimately impacts on consumers, as academics continually dispute one another’s findings. We have even seen the refusal to acknowledge the legitimacy of each other’s findings. We also recognise the precarious position that GambleAware finds itself in, it is almost a “dammed if they do, dammed if they don’t” situation. This ‘cloud’ over the value and appropriateness of research efforts as a result of the source of funding is ultimately slowing progress and needs resolving.
Q9. The Bingo Association does not feel in a position to comment on this.
Q10. The Bingo Association does not feel in a position to comment on this.
Q11. The Bingo Association does not feel in a position to comment on this.
Q12. This area requires researching thoroughly as a matter of urgency. This is because it is such an emotive subject where the facts need to be established quickly one way or the other.
Q13. The Bingo Association and its members do not currently advertise on TV and do not feel in a position to comment. Some Bingo Association members do also have an online offering and do advertise Bingo. They may well wish to comment separately on this.
Q14. The Bingo Association is not in a position to comment on this.
Q15. The Bingo Association members operate a membership-only environment in the retail bingo space. Age verification testing also ensures that club procedures are in place to prevent children and young people from gaining access.
Q16. The Bingo Association’s view is that it makes sense for all significant gambling products to be age restricted to 18 years old. However, there are some benign and fun low stake, low prize products (found in seaside arcades) that should remain without a lower age limit. The introduction of a requirement of a minimum age of 18 years could disproportionately detract from a traditional British family holiday experience.
Q17. Yes, if they are found to be low stakes and low prizes and part of an ‘all the fun of the fair’ type of experience, particularly at the seaside, which many of us will have enjoyed as part of our childhood.
Q18 – The Bingo Association is not in a position to comment on this.
Q19 – The Bingo Association will be responding separately to the DCMS Consultation on the minimum age for playing National Lottery games.
Miles Baron
Chief Executive, The Bingo Association
2 September 2019