Tackling gambling related harm: A whole council approach

Tackling gambling related harm - a whole council approach
Harmful gambling is increasingly cited as a public health issue which requires a broad response; that is to say, traditional approaches that focus on single interventions do not tend to work at a population level.

Foreword

There is increasing awareness about the harms that can be caused by gambling and its impact on families and local communities, as well as the individuals directly affected by it. The prevalence of high street gambling premises; the significant increase in gambling advertising since the introduction of the Gambling Act in 2005; and the rise in online gambling have all contributed to societal concern about gambling in the UK and the harm that can be associated with it.  

Gambling related harms are now widely recognised as a public health issue which require a broad response. Harmful gambling is a complex problem with many different but often interlinked factors - no single measure is likely to be effective on its own in addressing it. 

Consequently, many organisations have a part to play in addressing the harms caused by gambling, not least the gambling industry itself. There are several ways in which councils can try to prevent and support those individuals and families who are experiencing harm from gambling and reduce population exposure to gambling. This is in addition to their statutory licensing responsibility to try to prevent local gambling premises causing harm through their products or practices. There are, however, often limited resources available for gambling harm prevention interventions at a local level, however relatively low-cost interventions can have a significant impact.  

For example, councils will be coming into contact with people negatively impacted by gambling through a range of services, including housing and homelessness, financial inclusion, children’s services and addiction services. Yet few councils have data on where harmful gambling has been a contributory or additional factor in these cases. This leads to a lack of understanding about the needs of our communities, and we are therefore less able to prevent and address gambling related harms, or to take full advantage of the support that is available to those affected by harmful gambling through the third sector and NHS led treatment system. 

Having the support of elected members and the chief executive in changing our understanding of harmful gambling and its impacts is vital.  It sends a clear signal that addressing harmful gambling is a priority, not just for public health and licensing but across  the whole council and its wider stakeholders, thereby facilitating cooperation across departments and with local communities and partners. 

In 2018 the LGA and Public Health England developed this document to provide an overview of harmful gambling and how councils can try to help local residents who are impacted by it. This updated version reflects the advances that have been made in tackling gambling related harm and supporting those affected by it in the five years since. Despite this progress, we know from our work on two of the LGA’s policy boards that this issue remains of concern to councillor colleagues up and down the country, and that there is still more to do. We hope you find this guidance useful in understanding how councils can strengthen their work in this area. 

Cllr Heather Kidd
Chair, LGA Safer and Stronger Communities Board    

Cllr David Fothergill 
Chair, LGA Community Wellbeing Board 

Executive summary

'Harmful gambling’ is an umbrella term to describe any frequency of gambling that results in people experiencing harm. Gambling products can be very addictive, and widespread persuasive marketing and advertising can have negative impacts. Harmful gambling can impact on an individual’s physical and mental health, relationships, housing and finances, and affect a wide range of people, such as families, colleagues, employers and wider local communities.  

Gambling industry voices tend to frame gambling as being a harmless leisure activity that is a personal choice and something individuals should enjoy ‘responsibly.’ They do not focus on the addictive and harmful products and practices used by gambling operators to maximise profits. This can lead to narratives which suggest the individual experiencing harm is a ‘problem’, and this stigma often leads to gambling harms being hidden.  

Whilst anyone can be negatively affected by gambling related harms, harms are not distributed equally. Increased exposure can make certain people more vulnerable to the harms caused by gambling, for example: children and young people, people with mental health issues, homeless people, and those living in deprived areas. Often operators specifically target these groups, for example by locating premises in the most deprived areas. 

Research, education and treatment of harmful gambling is primarily commissioned and delivered by the Gambling Commission, GambleAware, and the NHS. Because of GambleAware’s role in distributing voluntary industry donations, some stakeholders have expressed concern about potential conflicts of interest due to the potential influence of the gambling industry, although GambleAware emphasise the steps they have taken to ensure their independence.   

Councils are not responsible for providing treatment for harmful gambling, but there are a range of ways in which different services can support people into the right treatment and support, including embedding knowledge and awareness of gambling within existing services, giving it parity of esteem with other issues- such as alcohol or substance misuse- and setting the tone of how gambling is discussed within a local area.  

District and unitary (licensing) authorities have a statutory role regulating local gambling premises and various tools to try to prevent gambling related harm occurring in premises: developing maps highlighting locally specific gambling risks; preparing local licensing policies setting out expectations of gambling businesses, and undertaking compliance visits to assess whether they are meeting these expectations. This activity is funded through the fees licensing authorities charge for licences. Planning teams can also play an important role in relation to local gambling premises through the council’s Local Plan.   

Gambling may also be driving demand for other council service areas, including children’s, family and adult social services, treatment and early intervention services, homelessness and wider housing services and financial inclusion and debt advice services.  

Councils should ensure that frontline staff are provided with training so they can have conversations about gambling harms, raise awareness and support people to access help such as the NHS gambling treatment clinics. Councils can also seek to work with local partners and build links with support organisations to help develop specific local referral pathways and ensure these can be accessed from across the full range of local services. As frontline awareness and identification of the harms that can be caused by gambling develops, councils should ensure they capture data about it, to help understand the extent of harmful gambling, impacts and costs associated with it.   

Public health teams can play a role in ensuring that this data, and related data on groups who may be at an elevated risk of gambling related harms, is collected and shared. They can also work with local partners in the community and voluntary sector, and through integrated care boards and integrated care partnerships, to develop a coherent approach to harmful gambling, including focused preventative work. Crucially, councils and public health leads can also have an important role in reframing how gambling harms are described and leading effective communications on this issue to challenge stigma and negative perceptions relating to gambling harm, as this stigma can prevent people from talking about their gambling or seeking help.   

The Gambling Act 2005  

The Gambling Act 2005 underpins the legislative approach to betting and gambling in the UK. The Act changed the underlying approach to gambling from permitting but not encouraging it, to increasing the opportunities for adults to gamble, and treating it as a leisure activity. This significantly liberalised the gambling regime, for example, by enabling gambling operators to advertise across all media platforms and creating an ‘aim to permit’ new gambling premises. These changes, coupled with technological advances, have led to significant increases in gambling participation and gambling related harms.  

In 2023, the Government published the Gambling Act Review White Paper which sets out the Government’s plans for reforming gambling legislation. The changes proposed by the White Paper are referred to throughout this guidance. 

Taking a public health approach to tackling gambling harms

Many councils are now taking a public health approach to tackling gambling harms, such as councils in Yorkshire and the Humber and Greater Manchester, and this is something the LGA fully supports. Councils may also be interested in the Australian City of Monash Council’s gambling policy, which explicitly takes a public health approach to tackling gambling harms and is well regarded amongst public health stakeholders. 

A public health approach looks at issues from a societal rather than an individual level. It is a way of thinking and acting collectively to address a problem that can damage health and wellbeing, rather than seeing something through a single or narrow lens (for example, looking at something simply as a financial issue).   

Public health approaches have successfully been applied to a range of other socially complex and long-standing problems, such as serious violence and alcohol related harm. They employ methods such as systems mapping and modelling using data, intelligence, research, evaluation and participatory methods to assess problems, inform interventions and increase opportunities for action to avoid or reduce health harm.   

Generally a public health approach is led by public health teams and adopts a multi-agency approach across partners with similar goals, with a particular focus on prevention. The core principles of the approach are: 
 

  • understanding the problem at a population level 
  • framing the problem as part of a complex and interdependent system 
  • collating data and evidence of what works 
  • being prevention focused 
  • protecting health and wellbeing 
  • encouraging multi-agency working
  • addressing inequalities, social justice and human rights.   

In relation to gambling, a public health approach can be defined as “one based on collective action to advance the public good by promoting health, equity, and social justice, and by adopting a broad and population-level perspective to gambling harms. Achieving this approach will, in part, require the public health community to engage fully with this issue, advancing counter-discourses to those that have become common, while recognising that policy and social change are complex and context-dependent.” The Faculty of Public Health  and Association of Directors of Public Health have produced some recommended actions which could be adopted to enable councils to take a public health approach to tackling gambling harms.  

As this document has highlighted, many council teams and services will come into contact with people experiencing gambling related harms. It is therefore crucial that councils are using all of the tools at their disposal to prevent gambling harms from occurring and ensuring that staff are trained and able to signpost people experiencing harms to support. Just as we have seen with tactics used by the tobacco industry, councils need to be cognisant of tactics that seek to undermine evidence and promote personal responsibility. 

The role of public health teams 

There is now widespread recognition that gambling related harms are public health issues and Public Health England’s (now the Office for Health Improvement and Disparities) evidence review will be a useful tool for councils seeking to evidence the need to develop a public health response to gambling harm. To deliver a public health approach, councils should ensure there is a partnership between public health and other council teams using national rules and regulations to their full advantage. However, the LGA is clear that a public health response does not equate to local public health funded services having a responsibility for providing treatment for gambling harms. Councils are not currently funded to provide support for individuals experiencing problems with gambling under the terms of the transfer of responsibility to local government in 2014 and are not a core part of the treatment framework outlined in an earlier section of this document.  

Nevertheless, both local government and health services can do more to ensure that gambling related harms are prevented through careful consideration of contextual factors which can influence gambling and the potential harms it might cause (for example, by ensuring a council’s licensing policy or local plan is robust on gambling related harms issues) and to ensure that people experiencing harms from gambling are identified - whether through primary or secondary care, or through council services – and are signposted to support and treatment.  

It is clear that public health teams can play a strategic role in relation to harmful gambling and should consider the overlaps between gambling harms and other local public health issues, given the high levels of comorbidity with mental health problems and the negative financial, health and relationship impacts of harmful gambling on the individual and those around them.   

A number of local authorities have undertaken local reviews to understand the extent of gambling harm in their local area. For example, in 2022 the Greater Manchester Combined Authority published a strategic needs assessment which brings together the best available local and national evidence to describe the extent and impact of gambling related harms in Greater Manchester. Other examples include Devon County Council’s  spotlight review to understand the extent of gambling harm in the county and Stockton’s Adult Social Care and Health Select Committee’s review which built a local evidence base on gambling harms. The Gambling Commission signposts to a list of resources which may help councils to build an evidence base on gambling harms in their area. However, when undertaking this work, councils should be mindful that any local review is likely to be an underestimate of levels of local gambling related harms because stigma and under-recognition of the risks and harms from gambling mean it is often under-reported and hidden.

Local public health teams can also engage with the issue by identifying and promoting local pathways of care and treatment provision, taking steps to tackle the stigma surrounding gambling related harms, and raising awareness of the issue. Public health teams can also help by promoting positive stories of recovery, which can be very effective, and councils should consider involving lived experience groups with this work. Taking such steps may support local residents to talk about any gambling related harms that they may be experiencing, which will help with tackling stigma. Councils may find the public health framework for gambling related harm reduction, produced by Directors of Public Health in Yorkshire and the Humber, particularly helpful.   

It is important to increase public health team’s awareness of gambling related harms so they can support services to recognise the signs of harmful gambling, assess and signpost to appropriate support. The Royal Society of Public Health has produced resources (funded by Gambleaware) to support those working with members of the public to understand and better respond to gambling related harms.  

The Gambling Commission has produced a briefing note on the issues where it believes public health can play a role, including supporting the licensing authorities with developing a statement of licensing policy (considered in the previous section) and working with local health professionals to increase awareness of the issue. Councils may also find research from 2022 on policies and interventions to reduce harmful gambling helpful. The research identified 40 universal and targeted measures to tackle harmful gambling, which they believe, if implemented, could substantially strengthen regulatory controls while providing new resources. 

Case study: Task and Finish Group on Gambling Harms in Barnsley 
 

It is becoming increasingly well recognised that harmful gambling is a public health issue associated with harms to individuals, their families, their friends, and wider society. However, due to the lack of local, regional and national data and the complexity of quantifying the metric of ‘gambling related harm’, it is often less understood in comparison to other public health issues such as smoking, obesity, or alcohol misuse. 

  

As such, Barnsley Council’s Overview and Scrutiny Committee established a Gambling Task and Finish Group (TFG) to investigate gambling related harm in Barnsley. This included considering the key challenges around gambling and gambling related harm; the support services available in the borough and beyond; and what the future plans are in terms of this agenda. 

  

The TFG met with Public Health, Licencing Officers, local agencies and organisations, the NHS, national charities, and service providers. As a result of their investigations, the TFG has developed 12 recommendations to support further improvement on this agenda.  These recommendations will be a catalyst for action in Barnsley, with a focus on improving our understanding of the prevalence and degree of gambling, problem gambling and gambling related harm, raising awareness more broadly, maintaining regulation, and improving access to services. 

What councils can do:  

  • Contribute data and insight to the development of local area profiles to support licensing statements of policy. 
  • Ensure public health teams are aware of gambling related harm and can support services to screen, assess and signpost to appropriate support. 
  • Identify local organisations providing treatment and support to assist with signposting. 
  • Identify appropriate referral pathways. 
  • Work through integrated care boards and integrated care partnerships to develop a coherent approach to harmful gambling, include focused prevention work with potential high-risk groups. 
  • Integrated care boards and integrated care partnerships should be encouraged to raise awareness of harmful gambling amongst primary care professionals and work with local authorities to signpost to local and national support services, as well as integrating externally commissioned treatment services into existing local services, for example, integration within Primary Care Networks. 
  • Mental Health Service Providers should consider how they can best identify harmful gambling and provide access to specialist support, particularly for young people presenting through child and adolescent mental health services (CAMHS).   

Other resources and research