The Gambling Commission has self-adopted the role of author of the next (2019-2022) National Responsible Gambling Strategy and has published a conversation document that can be found here;
There is much criticism laid at the door of everyone involved for the limited progress made with the current strategy and the Responsible Gambling Strategy Board (RGSB) specifically site “..an insufficient connection between the strategy and the statutory powers of the Commission” as one of the reasons. Whilst there is no evidence produced to support this tenuous link (perhaps excuse), there are two more fundamental issues with the current strategy that both the RGSB and the Gambling Commission fail to recognise;
- Is the lack of transparent accountability for the deliverables in the strategy and;
- Has been the inability to effectively define ‘gambling related harm’ on which all of the key elements of the strategy were built around.
The failure to effectively define Gambling Related Harm has been critical, a failure that has undermined the principle of the current strategy. Because it isn’t defined it can’t be measured. Because it can’t be measured no one knows whether ‘harm’ has been reduced or whether the strategy has been successful.
Have we learned from this?
Well as the new authors of the next version of the National Responsible Gambling Strategy have decided to entitle it ‘National Strategy to Reduce Gambling Harms’ the easy and resounding answer is ‘no’.
In fairness to the Gambling Commission, there is a description of harms on page 6 of the discussion document lifted from the RGSB’s own framework on this subject, however it is at best a ‘work in progress’. What it isn’t, is a definition that can be put into a measurable format that would enable effective oversight of a strategy that specifically aims to reduce it.
With the exception of physical harm, all other harms related to gambling whether emotional, financial, time related, relationship or welfare harms are all different for each individual. The aspiration to develop a bespoke set of tools or methods to meet the definition of harms for every individual is such a big ‘ask’ that success is unlikely, if not impossible. We need a strategy built on rock, not on sand.
So the error that is in danger of being repeated again is the lack of a proper understanding of the problem we should be trying to fix.
Collectively, we need to take a fresh look at ‘what the problem actually is’ from a different perspective and not accept the perceived wisdom.
‘Gambling related harm’ is actually a symptom (or consequence) of the problem, it is not the cause or the problem itself.
The problem we should be looking at is that not all gamblers have the ability to ‘stay in control’ of their gambling at all times. This is a far more tangible problem to define, measure and address, as we are already doing in some parts of the industry with particular forms of gambling activity. And the irony is that if we help more gamblers to stay in control more of the time, it will have a direct impact on reducing gambling related harm.
It’s not as sexy or ‘headline grabbing’ for the anti-gambling brigade or for the Commission to spout from the lectern.
And if we are seen to be dealing with this effectively it’s not going to persuade Westminster to adopt problem gambling as a NHS or Public Health issue. But is that really a bad outcome?
However it is time to stop and think. If we genuinely want to help and protect the vulnerable individual who needs our support then we should be focusing on helping them to stay in control, not on humiliating them even further by highlighting how much harm and damage they are causing to society.