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MAY 2019

The London Borough of Lambeth

LOCAL AREA PROFILE GAMBLING ACT 2005

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Contents

Introduction 3 – 4

Lambeth’s Approach 5 – 7

Data 8

Vulnerability Maps 9 – 22

Gambling Vulnerability Zones 23 – 27

Gambling Premises Clusters 28 – 38

Licensing Guidelines 39

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Introduction 1.1 Great Britain has one of the most accessible gambling markets worldwide . Opportunities to

gamble exist on most high streets and, with the increase in online gambling, in virtually every

home. The majority of British people have gambled at some point and most of those who

gamble have no issues with keeping their gambling within sensible and affordable limits.

1.2 However, for some, gambling can be problematic, affecting their ability to live and work.

People with gambling problems often experience a range of negative effects, including health

issues, relationship breakdown, and difficulties with debt. In more severe cases gambling

problems can lead to crime, thoughts of suicide or suicide itself.1

1.3 When the Gambling Act 2005 (the Act) came into force in late 2007, it brought in a new,

comprehensive system for gambling regulation in Great Britain. The Act established a

dedicated regulator, at a national level, in the form of the Gambling Commission and

recognised the potential local impact and importance of gambling. So it created many local

regulators in line with local circumstances. Those regulators are the 380 licensing authorities

of England, Wales and Scotland. Lambeth Council, as such, is one of these regulators.

1.4 The regulatory environment in Great Britain is changing, becoming more focused on risk.

Licensing authorities are expected to take the lead on local regulation of gambling. As such,

policy is becoming more focused on understanding and mitigating gambling-related harm,

rather than focusing on problem gambling alone.

1.5 The Gambling Commission recommend, that as part of any policy refresh, which licensing

authorities are required to do every three years, that authorities also produce a Local Area

Profile. The Commission explain that this will have a number benefits for policy making in the

future, including:

Enabling licensing authorities to better serve their local community, by

improving Lambeth’s understanding of the community and the local risk profile;

1 https://www.gamblingcommission.gov.uk/PDF/survey-data/Gambling-behaviour-in-Great-Britain-2015.pdf

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Improved clarity for operators as to the relevant factors in licensing authority

decision making. This will lead to improved premises license applications, with

the potential operator already incorporating controls and measures to mitigate

risk in their application;

Enabling licensing authorities to make robust but fair decisions, based on a

clear, published set of factors and risks, which are therefore less susceptible to

challenge; and

Encouraging a proactive approach to risk that is likely to result in reduced

compliance and enforcement action.

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Lambeth’s Approach

2.1 The purpose of the Lambeth Local Area Profile is to identify the areas’ most vulnerable to

gambling related harm. Therefore, the question that this profile attempts to better

understand is – who is vulnerable to, or at risk of, gambling-related harm and where are such

vulnerabilities likely to manifest in Lambeth?

2.2 Gambling related harm was recently defined by the Gambling Commission in their ‘Measuring

Gambling Related Harms – A Framework for Action’ report, published in July 20182:

2.3 The Gambling Commission in 2012, whilst stating that it would not explicitly define who

exactly is vulnerable in relation to gambling, could identify types of people that it is likely to

impact more than others. This focuses on people who gamble more than they would want to,

some examples include:

Young people and students

Those with Mental Health problems

Those afflicted with substance use/misuse issues

Those with learning disabilities / difficulties

Homeless people

Those living in constrained economic circumstances

Those living in deprived areas

Those with personality / cognitive impairments

2 https://www.gamblingcommission.gov.uk/PDF/Measuring-gambling-related-harms.pdf

“Gambling-related harms are the adverse impacts from gambling on

the health and wellbeing of individuals, families, communities and

society”

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2.4 A report by the Gambling Commission in 2015 defined problem gambling as:

2.5 In accordance with the Gambling Commissions recent gambling harms framework and

previous publications, the types of harms that have been considered as part of this local area

profile are as follows:

Gambling associated crime (acquisitive and those at a gambling premises)

Relationship breakdown/problems (reported domestic incidents)

Unemployment, financial stress and income deprivation

Health issues

Homelessness

Children being exposed to gambling (accidental or otherwise)

2.6 Lambeth, as the licensing authority, has modelled where such risks might be more acute in

certain areas versus others. This has included an assessment of the key characteristics of the

borough to identify areas of higher risk of vulnerability to gambling-related harm.

2.7 The Lambeth approach is based on the possible risk to gambling-related harm and does not

mean that just because an area is seen as being at higher risk, that all people in that area will

suffer harm or be at risk of suffering harm.

2.8 Lambeth will take specific note of whether an application relates to a premise that is:

Close to an educational establishment, including colleges and universities;

Close to a center dealing with addictions;

Close to general practitioners and supported housing that focuses on mental

health;

Situated in an area of high, gambling associated crime;

Situated in an area of deprivation;

Close to locations that are regularly visited by those who are unemployed such

as job centers and food banks; or

Close to the location of businesses providing instant access to cash such as

payday loans, pawn shops

“To a degree that compromises, disrupts or damages family, personal

or recreational pursuits”

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2.9 Lambeth expects applicants for a new license to submit the completed assessment with their

application. It must identify the risks and state what control mechanisms are to be employed

at the premises to ensure that the licensing objectives are being met having regard to the

local area profiles produced by this Authority. The assessment must consider at a minimum:

The local area, including but not restricted to the types of premises and

operation in the area surrounding the gambling premises; educational facilities;

centers for vulnerable people; high crime area; high unemployment area; pawn

broker/pay day loan businesses in the vicinity; other gambling premises in the

vicinity

The gambling operation, including but not restricted to what gambling

products it provides in the premises; the staffing levels within the premises; the

level and requirement for staff training; whether loyalty or account cards are

used or not; the security and crime preventions arrangements it has in place;

how it advertises locally and on the premises; the marketing material within the

premises; the display and provision of information

The design and layout of the premises, including but not restricted to whether

the staff have obstructed views of gaming machines or entrances; whether the

design is such that children can see gambling taking place;

The control mechanisms to be put in place to mitigate the risks, for example;

the use of CCTV cameras, the provision of magnetic door locks, employment of

door supervisors, employing a challenge 25 scheme, increased number of

trained staff

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Data 3

3.1 Below is the data table which highlights the data that has gone into the model to assess

vulnerability across Lambeth.

Dataset Source Linked Harm

All crime - venue recorded as occurring at a Lambeth betting shop – 2016, 2017 and 2018

MPS Crime

Domestic incidents in Lambeth in 2017 and 2018

MPS Relationship problems/

breakdown

Acquisitive crime in 2017 and 2018 MPS Crime

Money lenders, pawnbrokers and food banks

Open Source Unemployment Financial Stress

Income Deprivation

Mental health services and mental health care facilities

Corporate GIS Lambeth CCG

Health Issues

Drug and alcohol treatment and recovery centres

Public Health Health Issues

Supervised Pharmacies Public Health Health Issues

Education institutions with students of 13-24 years

Corporate GIS Child Exposure

Hostels, supported housing, registered care & temporary accommodation

Corporate GIS Health Issues Homelessness

Economically active unemployed residents 2011 Census Unemployment Financial Stress

Income Deprivation

Location of Job Centres Corporate GIS Unemployment Financial Stress

Income Deprivation

Location of Youth Centres Corporate GIS Child Exposure

Income Deprivation Indices of Multiple Deprivation Unemployment Financial Stress

Income Deprivation

Employment Deprivation Indices of Multiple Deprivation Unemployment Financial Stress

Income Deprivation

Location of Gambling Premises Licenses Licensing All

Population by Lower Super Output Area ONS 2017 All

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Vulnerability Maps 4

4.1 Below is the data table which should be used to navigate between the various maps made

available through this local area profile.3

Map no. Map Title

Section 4 – Vulnerability Maps

1 Locations of Gambling Premises Licences in Lambeth

2 Density Analysis of Gambling Premises Licenses

3 Network Analysis of Gambling Premises Based on 5 Minute Walking Time

4 LSOA's Graded by IMD Income Scores and Showing Ward Boundaries

5 LSOA's Graded by IMD Employment Scores and Showing Ward Boundaries

6 Routing Map Showing Proximity of Secondary Schools and Youth Clubs to Betting Shops

7 Locations Linked to Vulnerable Adults

8 Density Analysis of Locations Linked to Vulnerable Adults

9 Routing Map Showing Proximity of Locations Linked to Vulnerable Adults to Betting Shops

10 Hot Spot Analysis of Crimes Associated with Gambling Premises Licenses

11 Hot Spot Analysis of Domestic Violence Offences in Lambeth

12 Hot Spot Analysis of Acquisitive Crimes in Lambeth

13 LSOA Overall Gambling Vulnerability Analysis

Section 5 – Gambling Vulnerability Zones

14 London Borough of Lambeth: Gambling Vulnerability Zones

15 North Lambeth Gambling Vulnerability Zones

16 Central Lambeth Gambling Vulnerability Zones

17 South Lambeth Gambling Vulnerability Zones

Section 6 – Gambling Premises Clusters

18 London Borough of Lambeth: Gambling Premises Clusters

19 South Bank and Waterloo Gambling Cluster

20 Kennington Gambling Cluster

21 Clapham Gambling Cluster

22 Central Brixton Gambling Cluster

23 West Norwood Gambling Cluster

24 Streatham Hill Gambling Cluster

25 St. Leonards Gambling Cluster

26 London Borough of Lambeth: Gambling Clusters and Vulnerability Zones

3 Use the links in the table to view higher resolution images and interactive views of the clusters and vulnerability maps

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MAP 1: Locations of Gambling Premises Licenses in Lambeth

4.2 Map 1 shows the locations of the premises with a Gambling Premises license in Lambeth. The

map shows concentrations in the high footfall areas, namely; Brixton Town Centre, Clapham

High Road, Streatham High Road and the South Bank.

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MAP 2: Density Analysis of Gambling Premises Licenses

4.3 Map 2 builds on Map 1 and shows a density analysis of gambling premises locations, evidence

assertions made in section 4.2 that highest concentration of premises are located in the

highest footfall areas.

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MAP 3: Network Analysis of Gambling Premises Based on 5 Minute Walking Time

4.4 Map 3 is a network analysis of Lambeth and the locations of it’s gambling premises. The map

illustrates the coverage a person could achieve if they were to walk for 5 minutes in any

direction from the premises. The map highlights that much of Brixton, Clapham High Street,

Streatham High Road, West Norwood and the north of the borough are within 5 minutes walk

of a gambling premises.

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MAP 4: LSOA's Graded by IMD Income Scores Showing Ward Boundaries

4.5 Map 4 is a visual representation of the most income deprived areas in Lambeth. Each lower

super output area (LSOA) is colour coded to represent the proportion of the population in that

locality who are dependent on means-tested benefits. It shows that for large areas in

Coldharbour, Vassall, Tulse Hill and Gipsy Hill wards it is common that over 25% of the

population are dependent on means-tested benefits, and in some instances up to 40%.

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MAP 5: LSOA's Graded by IMD Employment Scores Showing Ward Boundaries

4.6 Map 5 is a visual representation of the most employment deprived areas in Lambeth. Each

lower super output area (LSOA) is colour coded to represent the proportion of the population

in that locality who are involuntarily out of work. It shows that for large areas in Coldharbour,

Vassall, Knight’s Hill and Gipsy Hill wards it is common for between 15 - 25% of population to

be involuntarily out of work.

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MAP 6: Proximity of Secondary Schools and Youth Clubs to Gambling Premises

4.7 Map 6 plots the five nearest secondary schools, youth centers or colleges to each gambling

premises. In total, 276 routes were analysed. In Lambeth, on average, the nearest gambling

premises to each secondary school, youth club or college is 6 minutes walk away. This

highlights the close proximity with which Lambeth schools and gambling premises are already

situated.

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MAP 7: Locations Linked to Vulnerable Adults

4.8 Map 7 shows the locations that have been associated with vulnerable adults in Lambeth. They

include; addiction services, money lenders, pawnbrokers, food banks, talking therapies,

supervised pharmacies (for individuals who have been prescribed methadone or other similar

drugs), general practitioners who have a mental health specialist and hostels or supported

housing that focus on people who are/have; single or homeless with support needs, mental

health/disorder problems, drug or alcohol problems, young person at risk, or teenage parents.

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MAP 8: Density Analysis for Locations Linked to Vulnerable Adults

4.9 Map 8 shows a density analysis of locations that are associated with vulnerable adults. The

map highlights that the highest concentrations are found in central Lambeth, in particular

surrounding the Brixton Town Centre. There is a similarity between this map (Map 8) and Map

2. This highlights that the locations of higher densities of gambling premises and locations

where vulnerable adults with habitually frequent, are similar.

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MAP 9: Showing Proximity of Locations Linked to Vulnerable Adults to Betting Shops

4.10 Map 9 plots the ten nearest locations linked to vulnerable adults to each gambling premises.

In total, 550 routes were analysed and identified that on average across Lambeth, the nearest

gambling premises to each vulnerable location is approximately 3 minutes walk away. Further,

the average time taken to walk to ten vulnerable locations from each gambling premises in

Lambeth is 7 minutes. This highlights the close proximity with which vulnerable locations and

gambling premises are already situated.

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MAP 10: Hot Spot Analysis of Crimes Associated with Gambling Premises Licenses

4.11 Map 10 shows the result of the hot spot analysis for crimes where the address of one of

Lambeth’s licensed gambling premises was recorded as the venue of the crime. Each crime is

symbolised based on whether it is part of a statistically significant hot spot (red), a statistically

significant cold spot (blue). The red areas are hot spots, or areas where high numbers of

crimes at gambling premises are surrounded by other areas with high numbers of crimes at

gambling premises. In Lambeth, the two main hot spots are Streatham High Road and Brixton.

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MAP 11: Hot Spot Analysis of Domestic Violence Offences in Lambeth

4.12 Map 11 shows the result of the hot spot analysis for recorded crimes where the domestic

incident flag on the Metropolitan Police recording system was active. Each crime is symbolised

based on whether it is part of a statistically significant hot spot (red), and a statistically

significant cold spot (blue). The red areas are hot spots, or areas where high numbers of

domestic incidents are surrounded by other areas with high numbers of domestic incidents. In

Lambeth, hot spots are distributed throughout the borough with particularly high densities

near Streatham High Road, Tulse Hill Estate, St. Matthews Estate and Loughborough Junction.

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MAP 12: Hot Spot Analysis of Acquisitive Crimes in Lambeth

4.13 Map 12 shows the result of the hot spot analysis for recorded acquisitive crimes that are

linked to gambling related harm. The main crime classifications used were as follows; burglary,

theft from person, theft other, shoplifting and robbery. Each crime is symbolised based on

whether it is part of a statistically significant hot spot (red), and a statistically significant cold

spot (blue). The red areas are hot spots, or areas where high numbers of acquisitive crimes are

surrounded by other areas with high numbers of acquisitive crimes. In Lambeth, the most

prominent hot spots are in Brixton Town Centre, Clapham High Road and at the South Bank.

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MAP 13: LSOA Overall Gambling Vulnerability Analysis

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Gambling Vulnerability Zones 5

5.1 Map 13 represents a risk model created by combining all of the above factors per LSOA within

the vulnerability maps. Lambeth LSOA’s are then individually ranked by percentile. This allows

for the identification of the most vulnerable locations to gambling related harm in Lambeth,

divided into groups of 10%. Thus, we can assess how vulnerable a LSOA in Lambeth is, based

on our evaluation of the risks in that area, relative to other LSOA’s across the borough.

5.2 The variables that have been incorporated are, the number of; money lenders, addiction

centres, food banks, talking therapies, supervised pharmacies, youth centres, schools and

colleges, GPs with mental health therapists, hostels and supported housing, betting shops,

gambling premises crime, domestic incidents, acquisitive crime, population size, IMD income

score, IMD employment score, Census 2011 – young unemployed economically active people,

and Census 2011 – all unemployed economically active people.

5.3 The above described variables have been weighted in order to account for significantly

different volumes of independent measures, and prevent high volume variables being given

greater influence within the model. For example, the average number of acquisitive crimes

recorded per LSOA is 201, whereas the average number of addictions centres per LSOA is

0.017. If the totals were simply summed, then crime would dominate the model. In Lambeth’s

risk model, each LSOA is scored based on the proportion of the individual measure that is

located within it, represented as a decimal number. This ensures that each variable is more

evenly represented. Weighted measures have then been summed to give a total score for

gambling related vulnerability per LSOA. The higher the score, the higher the evaluated risk.

5.4 Map 13 is the overall combination of identified risks, weighted and ranked by LSOA’s in

Lambeth. However, if an LSOA is identified as being less vulnerable than the most vulnerable

LSOA’s, that does not mean that those areas do not carry their own specific risks. The above

compliment of maps should be used to identify the nature of the risks that are presented in

each area. Gambling premises operators are still expected to complete a local risk assessment,

irrespective of which percentile the LSOA they are based in is situated. As LSOA’s are small

geographic locations, neighbouring areas should also be considered.

5.5 Based on these risks, Gambling Vulnerability Zones have been created in the top 20% most

vulnerable LSOA’s. The purpose of the creation of these zones is to highlight, to current and

future premises operators, the areas in Lambeth where gambling vulnerability is most acute.

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MAP 14: Gambling Vulnerability Zones

5.6 Map 14 shows the Gambling Vulnerability Zones for the entire borough of Lambeth. These

zones represent the merging of bordering LSOA’s and in some instances single LSOA’s that are

identified as being in the 20% most vulnerable areas for gambling related harm in Lambeth.

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MAP 15: North Lambeth Gambling Vulnerability Zones

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MAP 16: Central Lambeth Gambling Vulnerability Zones

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MAP 17: South Lambeth Gambling Vulnerability Zones

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Gambling Premises Clusters 6

6.1 Westminster Council identified in their own Licensing Committee report of March 2018, that

there was sufficient evidence to indicate that higher problem gambling prevalence rates exist

where there are high concentrations of gambling premises in the same locality.

6.2 Problem gambling is defined as “to a degree that compromises, disrupts or damages family,

personal or recreational pursuits” (section 2.4) and there are many types of gambling activity

which can become ‘problem gambling’. The most common gambling activities that become

problematic are; spread betting, betting with a betting exchange, playing poker in pubs or

clubs, betting offline on events other than sports or horse or dog racing, and playing machines

in bookmakers.

6.3 This evidence was produced using research conducted by Natcen Social Research (Gambling

Behaviours in Great Britain 2015) and Geofutures in 2016 (now Gambleaware). The latter

defined higher concentrations to be locations where three or more betting shops are located

within 400 meters of one another.

6.4 On the basis of this evidence, routing analysis has been conducted on the Lambeth road and

pathway network, to establish where such clusters, three Gambling premises within 400

meters walking distance of each other, exist in Lambeth. In total, Lambeth has identified seven

clusters that would meet this criteria, these are as follows:

1. South Bank and Waterloo

2. Kennington

3. Clapham High Street

4. Central Brixton

5. West Norwood

6. Streatham Hill

7. St. Leonard’s

6.5 Lambeth clusters have been subsequently created by generating a 400 meter walking buffer

around each cluster of Gambling premises, using network analysis methodology. The following

series of maps (18 – 24) shows the geographical layout of these clusters in Lambeth and each

of them individually, highlighting the vulnerable locations nearby.

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6.6 The purpose of the creation of these clusters is to highlight, to current and future premises

operators, the areas in Lambeth where three or more gambling premises licences are based,

which the research identifies is linked to higher rates of problem gambling. This will enable

premises within these areas to have a useful reference tool with which to mitigate risks in the

local area, manage their gambling operation, design the layout of the premises and put in

place appropriate control measures.

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MAP 18: London Borough of Lambeth: Gambling Premises Clusters

6.7 Map 18, showing all Gambling Clusters where three or more Gambling clusters are within 400

meters walking distance in Lambeth. This follows the evidenced definition of concentrations

of premises that are correlated with higher problem gambling prevalence rates.

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MAP 19: South Bank and Waterloo Gambling Cluster

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MAP 20: Clapham High Street Gambling Cluster

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MAP 21: Clapham High Street Gambling Cluster

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MAP 22: Central Brixton Gambling Cluster

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MAP 23: West Norwood Gambling Cluster

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MAP 24: Streatham Hill Gambling Cluster

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MAP 25: Streatham Hill Gambling Cluster

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MAP 26: Gambling Clusters and Gambling Vulnerability Zones

6.8 Map 26 shows the Gambling premises clusters and the gambling vulnerability zones overlayed

on the same map of Lambeth.

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Lambeth Licensing Guidance 7

7.1 Lambeth considers that local risk assessments are a key component of the overall assessment

and management of the local risks. Each locality has its own challenges and applicants will be

expected to address the those local challenges in the undertaking of their own independent

gambling risk assessments, and when submitting an application to the Local Authority.

7.2 Gambling operators will be required to undertake a risk assessment for all of their existing

premises. Operators must also undertake a review of those assessments when certain triggers

are met. These are:

New premises applications;

Significant changes in local circumstances; and

Variations of the premises license

7.3 If a gambling premises operator does not put forward measures to overcome the local risks, or

the mitigate such risks, the council will consider what measures are needed. The Authority

expects that each premises will have a copy of its own independent local area risk assessment

onsite for authorised officers to view on request.

7.4 The risk based approach provides a better understanding of, and enables a proportionate

response, to risk. Risk is related to the probability of an event happening and the likely impact

of that event. In this case it is the risk of the impact on the licensing objectives. This guide will

assist gambling operators in undertaking and preparing their local (premises) risk assessments.

7.5 The policy is reflective of local issues, local data, local risk and the expectations a licensing

authority has of operators who either currently offer gambling facilities or wish to do so in the

future.

7.6 The existence of a clear and robust statement of policy provides greater scope for licensing

authorities to work in partnership with operators, other local businesses, communities, and

responsible authorities to identify and to proactively mitigate local risks to the licensing

objectives.