Legal & RegulatoryIndustryFeature

Poppleston Allen: Explaining the new changes to LCCP reporting

Imogen Moss, Solicitor at Licensing law firm Poppleston Allen, speaks to Gambling Insider about what the industry – from small land-based operators to large online outfits – needs to know about the Gambling Commission's new LCCP suicide reporting. 

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While the new Gambling Commission (GC) code of practice around suicide reporting has certainly caused alarm for operators in the betting and gaming industry, the rule is both straightforward and, hopefully, rare in its occurrence.  

From 1st April a licensee must “…notify the Commission, as soon as reasonably practicable, if it knows or has reasonable cause to suspect, that a person who has gambled with it has died by suicide, whether or not such suicide is known or suspected to be associated with gambling.”  

That means it is therefore a specific reportable event under the Licence Conditions and Codes of Practice (LCCP). 

In reality, this circumstance is so specific as to be fairly rare. The requirement to report is triggered if an operator has reasonable cause to suspect that a customer has died by suicide – so it is dependent on what information is made available to a licensee’s staff or management.   

Two circumstances in which this might occur would be if staff members hear about the suicide of a customer though different avenues, such as through another customer or the local or national press – both of these situations would be enough to have ‘reasonable cause to suspect’, and therefore, should be reported. 

The information requested as part of a report is limited to the customer’s name, date of birth and summary of gambling activity if known – as such, it should not be too difficult for the operator to collate. 

What does this mean on a practical level for the industry, especially the small high street operators? 

The key point is to ensure that your staff is trained on the updated LCCP requirement and that there is a reporting process established in your organisation. 

Employees should also be trained and comfortable with the reporting process, for example, that they know: 

The circumstances under which they should report something to management. 

To whom they should report the knowledge. 

What HR and mental health support is available to them if they are impacted by the customer’s death. 

The key point is to ensure that your staff is trained on the updated LCCP requirement and that there is a reporting process established in your organisation

Your management staff will also want to be trained so they understand how to relay the information to the Gambling Commission and how to format the report, etc.  

What guidance, instruction and points of reference has the GC given to licence holders for finding this data? 

Guidance is currently limited, but the GC has been clear in its consultation response that gambling businesses would only be required to notify the Commission that a person who has gambled with them has died by suicide if they themselves are aware of it. Specifically, the Consultation response states, “We do not expect gambling businesses to actively investigate various sources of information but to be cognisant of developments it might become aware of and respond accordingly.” 

The GC recognises in its response that suicide is a sensitive and complex matter and as such it does not expect operators to determine if the suicide was connected to gambling activity – this is a matter for the coroner and/or police to determine. This is why the condition has been worded to include any customer who has died by suicide, whether or not it is know if gambling was a contributing factor. 

The Gambling Commission has stated that it is likely to publish further guidance in this area on their website. 

While the hope remains that the reporting requirement is a rare occurrence, if there are any doubts it may be better to notify the GC than not. 

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