In this article Andy Woods reports on what was described as “game changing” research into area vulnerability to gambling-related harm, as the research was released by Westminster and Manchester Councils on 9 February 2016 and will be adopted into their policies to coincide with the requirements for individual premises risk assessments for gambling premises on 6 April 2016.
On 9 February 2016 I attended the release and publication of “research exploring areas of vulnerability to gambling related harm”. This research was described at the launch by Westminster Council as a “game changer” for local authorities and has since been described by Westminster as a “major step forward in Westminster and Manchester City Councils’ aim to identify at risk groups , their location and density within our cities”. The research was undertaken by Geo Futures and the reports will be available on Manchester and Westminster’s website, as will all of the maps referred to. There will also be a link to a map tool and it is hoped that care providers “will be able to use the vulnerability index to consider targeted intervention and support for the more at risk areas of both cities”. Westminster and Manchester City Councils’ Statement of Licensing Principles for Gambling will be revised to include these results.
So what exactly does this all mean? I am sure that there will be two fairly distinct opinions as to what the practical impact of this research will be. There is no doubt that the research will play a significant part in any applications for gambling premises licences made in Westminster or Manchester and I have no doubt that other local authorities will soon follow a similar approach. Westminster City Council made it clear that it was felt by them that there was no flexibility under the Gambling Act 2005 and that this research will impact on how Westminster City Council interpret the legislation. The research was described as a “missing link” and that it would “make a difference to decisions”. Westminster City Council stressed of course that they are not per se anti-gambling.
Heather Wardle presented the bulk of the research and explained that it is in effect a harm risk index. The work has been undertaken so as to coincide with the requirement under the LCCP for each gambling premises to undertake its own local area risk assessment as from 6 April 2016, and Heather expressed the hope that gambling operators would be able to use the information obtained to undertake their profiles. It was explained that Geo Futures has created spatial tools and maps to map out where potentially people are at risk of harm and it was stressed by Heather Wardle that the work relates to potential risk and probability of events happening and the likely impact of events as opposed to actual harm to any specific group. Research was undertaken into demographics, socio economic groups, groups who were able to exercise proper judgement and other groups including problem gamblers. The groups were split up further to include specific groups such as the unemployed, abuse sufferers and the homeless and it was submitted that there was evidence these groups are at risk.
It was confirmed there was no local level data specific to any group stressing that a specific group in a specific area had been caused harm by any gambling issues and that the mapping which had been carried out was independent of the distribution of gambling premises around any areas.
Geo Futures looked in particular at unemployed deprived areas, location of schools and churches, location of homeless shelters, location of clinics and doctors’ surgeries which may deal with those exhibiting problem gambling and as a result of all of this research produced hotspots in Manchester and Westminster in which the risk would be deemed to be very high. It was stressed that it did not mean that in other areas which were not a hot spot or even a mild spot there was no risk, but that the colouring of the maps and the darkness of the colour reflected the areas of a greater risk.
This will undoubtedly impact on any applications for gambling premises licences made in Manchester or Westminster after April 2016. I agree with Heather that the information will help gambling operators in undertaking local risk assessments although there was, as far as I am concerned, one significant piece of the jigsaw which was not discussed as this research was released and that piece is that most gambling operators are fully aware of the location of all churches, schools, homeless shelters and doctors surgeries which are near gambling premises and indeed in most applications I have made in the last twelve months I have included a risk assessment which refers to localised potential issues.
There were not many members of the trade at the research launch and there may have been lots of challenges to the research which has been undertaken if there had been, but the research was presented as not highlighting that harm had taken place but that in certain areas there was a greater potential risk of harm. It will be interesting to see how Manchester and Westminster deal with applications in these areas. I think I made my last application for a betting office in China Town, which to nobody’s surprise was included as a hot spot in the area. My application included a fairly lengthy risk assessment and maps which indicated where all of the schools, churches etc. were located and then referred to our policies which would promote the licensing objectives and protect the vulnerable. If I was to make an application in China Town tomorrow I would do exactly the same thing and refer to the same documents. The burning question is whether Westminster or Manchester will say “you have identified all the risks and your policies deal with all of the risks and therefore under the Gambling Act 2005 and the aim to permit principle we are granting the application” or whether the decision will be “we know that you have identified the risks and have policies in place but this is a hotspot area of potential risk and therefore we do not think the application will be granted”.
Only time will tell but it will be interesting to see whether other local authorities follow suit and how Westminster and Manchester do actually approach future applications.