Weekly Lottery policies and procedures

Our policy

a) The NSPCC is committed to ensuring that all its lottery activity is operated in a secure, fair and socially responsible way and to endorsing responsible gambling amongst its supporters.

b) This guidance has been created to ensure that our lottery activity is in line with the regulatory framework set out by the Gambling Act 2005 by:

• Preventing gambling from being a source of crime and disorder, being associated with crime and disorder, or being used to support crime
• Ensuring that gambling is conducted in a fair and open way.
• Protecting children, problem gamblers and other vulnerable persons from being harmed or exploited by gambling.

External lottery manager procedures

a) The NSPCC conducts its lottery by means of contracting with Gambling Commission licensed External Lottery Managers (ELMs).

b) A record of all printed tickets sold and unsold is kept by the ELM responsible for paper tickets. A record of all online entries is kept by the ELM responsible for the online weekly lottery. The ELMs also retain contact details and any other information connected with monies sent in for tickets/ entries received. These records are kept for a minimum of three years in order to comply with Gambling Commission requirements.

c) All draws are conducted on the premises of the ELM responsible for draws in plain sight of two members of ELM staff.

d) The ELMs operate from secure premises, with fire safes in situ, and use contractors who work to approved security standards.

e) All entries and monies received for the lottery are processed by the ELMs. Monies are paid directly into NSPCC's own bank account. Weekly banking reports are provided by the ELMs.

Policy and procedure on fair and open draws

a) The terms and conditions of the lottery are fair.

b) Participants have access to the terms and conditions (including information on prizes) of the lottery prior to purchasing a chance to win.

c) Any promotional materials for the lottery are clear and not misleading, and all advertising for the lottery complies with the advertising code of practice applicable to the form and media the advert is in. The principles in these codes should also be applied to all forms and media not explicitly covered by the advertising codes as if they were.

d) Entry is open to all residents of the UK (including NSPCC volunteers) but excludes: NSPCC trustees or directors; or NSPCC employees or third parties each directly involved in the administration or management of the Weekly Lottery, or with the ability to influence the Weekly Lottery results. Entry costs £1 per play, payable in advance, by one of the methods permitted within the entry form.

e) Volunteers of the NSPCC or any third party may only participate in the lottery if they are not involved in the organisation, management or running of the activity.

f) Draws are conducted at random using either a random number generator or if this is not possible, using a blind draw.

g) A list of results is published on the NSPCC website. Winners' information is also available on request from the NSPCC.

h) All Weekly Lottery and Superdraw winners are notified within 14 days in writing, and in the case of the top prize winner of the Superdraw, by phone, if a telephone number is available.

i) Rules (Terms and Conditions) are published on NSPCC website, entry forms, at the point of sale and the reverse of raffle tickets.

j) Printed versions of rules are available on request from NSPCC.

k) The NSPCC has a complaints procedure in place for its lotteries, see below.

l) A record is kept of online and ticketed sales, and of tickets distributed and not returned.

Players queries, complaints and disputes procedure

A 'complaint' means a complaint about any aspect of the conduct of the licensed activities, and a 'dispute' is any complaint which:

a) is not resolved at the first stage of the complaints procedure; and
b) relates to the outcome of the complainant's gambling transaction.

Staff must ensure that:

• customers are told the name and status of the person to contact about their complaint
• customers are given a copy of the complaints procedure on request or on making a complaint
• all complaints are handled in accordance with the procedure.

Procedure

a) Either the NSPCC Supporter Care Team, or the ELM's contact team staff receive and deal with the initial complaint.

b) Complaints should if possible be investigated and resolved within 5 working days. If an investigation is likely to take longer the complainant will be notified with a proposed timescale, aiming to resolve the complaint within a maximum of 25 working days.

c) A log sheet is completed at the time of the call/ on receipt of the written complaint. The complainants contact information, details of the telephone adviser who took the call or member of staff who investigated the written complaint, the nature of the complaint and how the complaint was investigated and resolved are recorded on the log sheet.

d) The NSPCC and the ELM are each to notify the other immediately if an initial complaint cannot be resolved.

e) If the complainant is unhappy with the resolution of the complaint they should contact the Director of Fundraising of NSPCC who will reconsider the decision and who will contact the complainant within 10 working days.

f) If the complainant is still not satisfied, they should contact the Fundraising Standards Board (www.frsb.org.uk) within one month of the Director of Fundraising's decision. The Fundraising Standards Board will consider the complaint in the light of the Fundraising Promise, and the Institute of Fundraising's Code of Fundraising Practice. The Fundraising Standards Board's decision will be final.

g) A copy of each decision on, or a note of the outcome of, each dispute referred to the Fundraising Standards Board will be provided to the Gambling Commission quarterly by the NSPCC.

Protection of children and the vulnerable procedure

a) The NSPCC is committed to ensuring that its own staff and any sub-contractors understand their responsibilities for preventing underage gambling, returning stakes and not paying prizes to underage customers.

b) Persons under the age of 18 may not sell or buy NSPCC lottery tickets or online entries.

c) The NSPCC has the following procedures in place to prevent under age players from participating in any lotteries the NSPCC promotes:

On all cold data used by our ELM it is requested that all persons under 18 years of age are excluded from the list before being supplied for the use of our lotteries. Where possible the NSPCC checks its database to ensure persons are above the legal age limit before data is supplied for the use of a lottery. Details of the minimum age to play are listed on the reverse of tickets.
Any person who appears to be under the age of 18 (or any other age limit stated in the terms and conditions of a specific lottery) will be asked to produce proof of identity and age before they may purchase a lottery ticket.

d) Prizes may not be given to any person under the age of 18 or any other age limit stated in the terms and conditions of a specific lottery.

e) Any player who provides dishonest information regarding their age automatically forfeits the right to any prize.

f) Any player found to be under 18 years of age, or any other age limit stated in the terms and conditions of a specific lottery, will have any monies paid in relation to the lottery returned to them as soon as reasonably practicable.

g) In the event of a request from a vulnerable person's carer to cease mailing lottery packs, their details will be suppressed immediately within NSPCC's database. If the lottery pack has been received as a result of their details being supplied to NSPCC or the ELM through a cold list, NSPCC will also provide the individual with information on how to have the details suppressed within the list owner's mailing records.

Training policy

Training covering the NSPCC's lottery policies and guidelines is available for all employees.

All employees who work on the NSPCC lotteries must read, understand and act in accordance with the NSPCC lottery policy and procedures.

Information policy

The NSPCC will work with the Gambling Commission in an open and co-operative way and will inform the Commission as soon as reasonably practicable of any matters that the Commission would reasonably need to be aware of in exercising its regulatory functions. These are matters that will have a material impact on the NSPCC's business or on the NSPCC's ability to conduct its business. Such matters would include any major breach in information security which must by law also be reported to the Information Commissioner's Office.

Responsible gambling, and problem gambling procedure

a) The following procedures have been put in place by the NSPCC to encourage people to gamble responsibly and to seek help should gambling develop into a problem. Training is provided so that staff understand their responsibilities, and are aware of advice on socially responsible gambling and of where to get confidential advice should their gambling become hard to control.

b) GamCare is a UK based Charity that offers help and advice on gambling. Their helpline number is 0808 8020 133 and website is www.gamcare.org.uk. These details are included on all NSPCC tickets as well as the NSPCC website.

c) The NSPCC is a member of The Lotteries Council, and contributes via its membership to the Responsible Gambling Trust to research, education and treatment activities in relation to problem gambling.

d) The NSPCC must interact with a supporter where a concern arises that their behaviour may indicate problem gambling. If applicable the NSPCC will provide individuals with information on gambling support organisations. The appropriate level of management to initiate this type of customer interaction is the named Promoter of the lottery, or another Annex A operating licence holder. The type of behaviour that may trigger customer interaction could include the purchase of a very large number (for example 200) of tickets. In these circumstances there will be consideration of whether to refuse to sell lottery tickets to the supporter.

e) Restrictions are in place regarding the number of tickets that can be allocated to an individual. The maximum is 60 tickets per person. Additional tickets may only be sent to an individual once monies from the sale of the original tickets sent to that individual have been received.

f) Players can request the number of tickets they would like for an individual lottery and also the number of lotteries they would like to participate in on a yearly basis.

g) Players, or carers of a vulnerable person, can request self-exclusion from our database for further lottery mailings. The exclusion will be valid for a minimum of 6 months and cannot be reinstated during this time.

h) NSPCC shall take steps to remove the name and details of a self-excluded individual from any marketing databases relating to the lottery used by the charity (or otherwise flag that person as an individual to whom lottery marketing material must not be sent), within two days of receiving the completed self-exclusion notification. Staff shall be trained so that they are able to enforce these systems. NSPCC will require its ELMs to enforce equivalent exclusions.

i) If at the end of the period chosen by the customer (and at least six months later), the self-exclusion remains in place, unless the customer takes positive action in order to gamble again, no lottery marketing material should be sent to the individual unless the individual has taken positive action in order to gamble again, and has agreed to accept such material.

j) Where a customer chooses not to renew the self-exclusion, and makes a positive request to begin gambling again, the customer is given one day to cool off before being allowed access to gambling facilities. The contact must be made in writing.

Gambling responsibly and problem gamblers information

a) NSPCC is committed to contributing towards the identification and treatment of problem gamblers.

b) NSPCC is committed to contributing to public education on the risks of gambling and how to gamble safely. The majority of people do gamble responsibly.

c) The following information is in place to help you to gamble responsibly:

• You're buying fun, not investing your money.
• Set strict limits on how much time and money you're willing to spend.
• Quit while you're ahead.
• Only gamble with money you can afford to lose.
• Don't spend more money in the hope of winning back what you have lost.
• Keep up other interests and hobbies - don't let gambling take over your life.
• Don't gamble in order to escape from stress or boredom.
• Gambling in moderation is okay.

d) For some however gambling can become a problem. If you are concerned about the amount you are gambling, (or you are concerned for a friend or relative) then the following questions may help give you some guidance:

• Have you been criticised for your gambling?
• Have you lied to cover up the financial amount or the time you have spent gambling?
• Do arguments, stressful situations or disappointments make you want to gamble?
• Do you gamble alone for long periods?
• Do you stay away from work or college to gamble?
• Do you gamble to escape from a boring or unhappy life?
• Are you reluctant to spend 'gambling money' on anything else?
• Have you lost interest in your family, friends or pastimes due to gambling?
• If you lose, do you feel you must try to win back your losses as soon as possible?
• When you run out of money while gambling, do you feel lost and in despair, and feel the need to gamble again as soon as possible?
• Do you gamble until your last penny is gone?
• Have you lied, stolen or borrowed just to get money to gamble or to pay gambling debts?
• Does your gambling ever make you feel depressed or even suicidal?

e) If you feel you are answering 'yes' to the majority of the questions above, then it is likely a gambling problem exists. Sometimes just telling someone about your concerns can be a relief and the first step toward dealing with your problem.

f) For friendly and helpful advice from trained counsellors you can call GamCare's helpline on 0808 8020 133. The helpline is open 24 hours a day.

g) You can also visit GamCare's website www.gamcare.org.uk for more information and advice.