We made representations to Lambeth Council in response to the recent proposed refresh of its Gambling Policy. The Council is required to review and adopt this policy every three years, and the next will run until January 2029.

We do not believe the degree of gambling vulnerability in our local community is brought out sufficiently in the draft policy.

A reading of the general advice on harms from gambling set in the policy does provide helpful context for our grave concerns on the impact for our local community in and around the West Norwood and Tulse Hill town centres, and we asked that this advice is incorporated within the policy rather than set out in an Appendix. The UK has one of the world’s largest gambling markets, London has a much higher risk of gambling harm than the UK average, and Lambeth and our parliamentary constituency a higher risk again. Harm from gambling is a serious and worsening public health issue.  

Gambling Aware measure gambling harm by the Problem Gambling Severity Index, which uses the following scale:

• 0 = no identified problems
• 1-2 = low risk of problems
• 3-7 = moderate risk of problems
• 8+ = experiencing problem gambling

Their published data shows levels of gambling risk in both Lambeth and our parliamentary constituency: Dulwich & West Norwood (D&WN) which is well in excess of the UK average:

	%	%	%
Level of risk	UK	Lambeth	D&WN
Low level	7.2	9.6	9.6
Moderate level	4.1	8.0	6.8
Problem gambling	3.4	8.7	8.3

We asked for the above statistics and those for the other parliamentary constituencies, be added to the policy in order to provide more context on the severity of existing gambling harm on our local community.

For the purposes of this draft policy, ‘vulnerable persons’ includes but is not limited to young adults, those with a history of gambling-related harm, shift workers gambling before or after work, individuals with mental health issues, people on low incomes, those experiencing homelessness, and individuals affected by drugs or alcohol. We suggested that children be added to this definition.  

Unfortunately, the ward profile data used to underpin the draft policy was published in Autumn 2021 and includes even older statistics, and so is some five years old for a policy due to commence in 2026. Also most of the above categories are not included in the provided statistics. From the draft policy it was difficult to clearly understand the local impact of gambling on vulnerable local people at a ward level, but we drew attention to the local high percentages of children under 15 (Knight’s Hill 1^st, Gipsy Hill 2^nd , and West Dulwich 3^rd in the borough) and older people over 60 as a % of population (Gipsy Hill 4^th, Knight’s Hill 6^th and West Dulwich 12^th). We provided further detailed comments on the included maps, and concluded the vulnerability area on the provided map should be much larger - covering all town centre wards except possibly West Dulwich. We asked that accurate ward based data on all the above categories is collected and included in the next Gambling Policy to give fuller guidance to gambling operators and strengthen the policy.

We are concerned that the proposed policy includes a proposal to remove the definition of West Norwood and Tulse Hill as a gambling cluster. This seemed to us to fly in face of the arrival in our town centre of an adult gaming centre: Reels. We made detailed comments too on the identified gambling establishments in the town centre and others that should be added.

If the gambling cluster definition was removed, this would mean the attention of current and future gambling operators would not be drawn to the fact that our area already has three or more licensed gambling premises and the links of such concentration to higher rates of problem gambling. There is an expectation that operators will show in their applications how they will take particular positive action to avoid negatively impacting on those most vulnerable to gambling harms, as well as the local area. We fear the degree of enforcement by the Council would reduce.

We also queried why the Crystal Palace triangle is not a designated gambling cluster, and raised the degree of vulnerability to gambling harm of the population of Gipsy Hill Ward.

Like many respondents to the consultation, we objected to the proposal to end the existing ban on Casinos in the borough. Officers explained to us that there is a national maximum number of casinos allowed, which has already been met. We felt the removal of the resolution could always result in a casino application should operators close existing premises and wish to relocate to London.

Lastly, we made suggestions on improved consultation on the next Gambling Policy and Licensing Policy (the next versions of both are due to commence in 2029).

We await a response from the Council, including clarification of when the draft policy will be considered along with an analysis of all the representations made. We will update this page when we have heard more.