Discussion Paper 1, 2015
A contribution to community consultation.
Self exclusion: A strategy to take back control.
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Preamble
Amity Community Services Inc. (Amity) is a non-‐government, non-‐denominational, not-‐for-‐profit agency that has been providing prevention and intervention services, in the form of counselling, information, education and training, to the Darwin and broader Northern Territory community in relation to behaviours of habit since 1976. Amity believes in helping people help themselves. Amity supports the view that health is more than the absence of disease, and sees health as a complete state of physical, mental, emotional and spiritual well-‐being. Amity accords with the World Health Organisation description of health as a resource for life and a product of lifestyles and living conditions. At Amity it is recognised that lifestyles contain different patterns of human behaviour encompassing both benefits and costs to the individual, family and the community. Amity aspires to be a leading community based organisation that values and actively promotes the adoption of healthy habits and lifestyles. Amity has been involved in the field of harm minimisation and community education and development for almost four decades. Amity is the primary deliverer of a range of prevention and intervention services in the area of gambling throughout the Northern Territory and has been working in the area of problem gambling for over twenty years. Amity espouses a Public Health view to gambling issues in the Northern Territory. Public health is the science and art of prevention and of promoting health through the organised efforts and informed choices of society, public and private organisations, communities and individuals. Amity’s view is that the existence of gambling and its related problems arise from a complex interaction between the: • Games people play -‐ such as diversity, type and speed of play; degree of skill vs. chance and cost
and accessibility. • Individuals -‐ factors within the person that increase or decrease individual desire to gamble. • Systemic and cultural factors – the factors and influences within our society and economic
system that encourage and discourage gambling.
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Executive Summary
This paper explores and makes recommendations about self-‐exclusion for Territory regulated land-‐based gambling environments. It may be worth further considering issues and relevance for the online environment based in the Territory.
Viewing gambling from a public health framework enables governments, industry, individuals and community to work collectively to reduce the incidence and prevalence of gambling-‐related harm.
Written into Codes of Practice for Responsible Gambling around the world there is a requirement to implement, manage and review harm minimisation strategies for the gambling product and the gambling environment. One harm minimisation practice is self-‐exclusion, a strategy that individuals can engage in to be prevented from participation in specific gambling products, services or areas of gambling.
Self-‐exclusion is a preventative measure.
Empirical evidence, nationally and internationally, on self-‐exclusion supports what Amity’s clients discuss as problematic: cooling off period, single venue implementation and a lack of information about the process for both the individual and staff in venues.
There is a need to acknowledge self-‐exclusion programs are undermined by the opportunity to gamble at different venues, with different operators, on different products, in different jurisdictions if single venue approach is in place (Parke & Rigbye, 2014). It has been found that while 46% of individuals engaging in self-‐exclusion reported a breach, 82% of all participants still found it ‘very’ or ‘totally effective’ (Tremblay et al., 2008).
Problem gamblers self-‐report that self-‐exclusion has significant benefits with people indicating less gambling, increased feelings of self-‐control and increased psychological wellbeing and overall functioning (Gainsbury, 2014).
There are many areas in which existing processes could be improved such as: a comprehensive, multi-‐site, multi-‐operator, geographical or by type, rather than isolated coverage; quick and simple procedure to implement and reinstate; minimising exposure, for the ‘self-‐excluder’ to gambling venues and products; increasing flexibility in the process (e.g. remotely accessed) and a program promoted throughout Territory gambling environments.
Recommendations • Strengthen self-‐exclusion to align with best practice models
o Multi-‐venue or geographic location, quick and simple, flexible, minimises exposure to gambling for the ‘self-‐excluder’ and is widely promoted.
• Have a centralised database managed by single entity. • Run a public health campaign throughout venues promoting of self-‐exclusion as a
strategy to take back/stay in control. • Evaluate the process.
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Public Health and Harm minimisation
Public health is a term applied to broad areas of health of diverse populations. Public Health is viewed as the science and art of protecting and improving the health of communities through the promotion of healthy habits and lifestyles. Korn (2002) acknowledges that gambling had been studied from many perspectives and suggests that the benefit of a public health viewpoint enables the examination of the broad impact of gambling rather than the narrow biomedical view that focuses on individual’s problems. Public health works to address all levels of prevention, intervention and protection with an integrated approach that emphasises multiple strategies for action (Korn, 2002). “Public health action reflects values of social justice and equity, and attention to vulnerable and disadvantaged people” (Korn, 2002, p.3).
Blaszczynski, Ladouceur and Shaffer (2004) and Fogarty and Young (2008) discussed how viewing gambling from a public health framework enables governments, industry, individuals and community to work collectively to reduce the incidence and prevalence of gambling-‐related harm. Public health does this by examining and advocating for the implementation of strategies in the areas of consumer behaviour, gambling environments, industry practices and government policies with the overarching aim of creating and maintaining safer gambling experiences (Blaszczynski, et. al., 2004; Fogarty & Young, 2008; Korn, 2002).
In 2008 the School for Social and Policy Research at Charles Darwin University released a discussion paper about gambling harm-‐minimisation measures post 1999 (Fogarty & Young, 2008). Fogarty and Young (2008) suggest “harm minimisation is a balancing act, one that weighs consumer protection against the recreational and financial benefits of gambling” (p. v). Harm minimisation measures and strategies are developed and implemented to modify and mitigate risks within an environment, for the individual and working to reduce the harm of problem gambling within the community.
Strategies usually fall into one of three broad domains: • Primary preventative initiatives -‐ measures aimed to reduce problem gambling targeted at
the broader community. The focus is on informed choice; • Secondary preventative initiatives -‐ measures aimed to reduce problem gambling behaviours
at gambling venues; and • Tertiary measures -‐ aimed at people who indicate they have a gambling problem.
Responsible Gambling
Australia’s gambling industry and its’ potential community and social impacts entered the spotlight with the release of the Productivity Commission’s reports into Gambling in 1999 and 2010. Research and studies published in this area continue to build a scientific body of evidence regarding the nature of gambling, human interactions with gambling and the harm of the gambling product. Blaszczynski and colleagues (2011) noted “there is considerable conceptual confusion surrounding the term ‘responsible gambling’”(p. 568) and that the concept of responsible gambling came about from gambling businesses’ reaction to community concern over the impacts of the gambling product on people, families and society. The requirement to implement, manage and review harm minimisation strategies throughout the gambling environment are written into Codes of Practice
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around the world with responsible gambling practices becoming a requirement of running a gambling business. In this paper responsible gambling refers to gambling environments and products that allows people to make informed decisions about their gambling behaviour. Responsible gambling can occur through actions and ownership of individuals, communities, the regulator and gambling industry to achieve socially acceptable outcomes. Responsible gambling can be the result of individual choice and of regulated environments where the potential for gambling related harms has been minimised.
Self-‐Exclusion
Self-‐exclusion is one harm minimisation practice that is part of all Codes of Practice for Responsible Gambling in Australia. Self-‐exclusion is a strategy that individuals can engage in to be prevented from participation in specific gambling products, services or areas of gambling (QLD Code of Practice). Research has discussed how engaging in self-‐exclusion is a form of help-‐seeking behaviour for people struggling with gambling problems. Thus suggesting that self-‐exclusion should be viewed as a tool that people, experiencing problems with their gambling, can engage in to acknowledge and take personal responsibility for their gambling problems (The National Centre for Responsible Gambling, 2010). Self-‐exclusion has been classified as a reactive rather than preventative harm minimisation measure. The Productivity Commission (2010 as quoted in Parke & Rigby, 2014) viewed the strategy as a reactive and inflexible approach harnessing abstinence as its goal while others have identified this option as an important component of harm minimisation within the public health framework (Gainsbury, 2013). Livingstone and colleagues (2014) discussed how self-‐exclusion is a form of pre-‐commitment, a preventative measure, where individuals are able to enter into an agreement with venues and other institutions to be excluded from gambling for a nominated period of time. The Productivity Commission reported in 2010 that there were 15,000 exclusion agreements in place in Australia. These represent between 9% and 17% of the problem gambling population (Productivity Commission, 2010). In a 2003 study of self-‐exclusion in Victoria and South Australia, O’Neil and colleagues found that the uptake of self-‐exclusion programs was about 2.5%-‐3.5% in the problem gambling population. Looking further around the world, in one study on self-‐exclusion programs in Canadian provinces it was found that 0.6-‐7% of people experiencing problems with gambling had engaged with this strategy (Williams et al., 2012).
Self-‐exclusion in the Northern Territory
Provision of self-‐exclusion is a requirement of the Northern Territory Responsible Gambling Code of Practice that became mandatory in 2006. Current NT practices revolve around patron responsibility for their own gambling activities. However, gambling providers are required, under the Code, to provide patrons with the option of excluding themselves from gambling (Northern Territory Code of Practice for Responsible Gambling).
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The onus is on the individual to initiate the process to each and every gambling venue they decide to self-‐exclude from. Patrons are encouraged to access counselling services and are not to be sent correspondence or promotional materials under the Code. In the Territory upon applying for self-‐exclusion, a three-‐day revocation period (i.e. cooling off period) is in place. The affect of this 3-‐day cooling off period on the process or individual is unclear. Feedback from Amity’s counselling clients indicates that the NT practice of self-‐exclusion is cumbersome and presents a range of challenges for people. In particular in relation to obtaining information about the process and requirements (e.g. passport photos, hard copies of forms for each venue), identifying the right person in the venue and approaching each and every venue to lodge self-‐exclusion forms.
Limitations to Self-‐Exclusion
Many identified limitations in the literature are beyond the control of stakeholders such as treatment agencies and venues. Subsequently, the scope of this discussion will provide a brief overview of the identified limitations that the NT can change to increase flexibility in the self-‐exclusion process.
Evidence, nationally and internationally, in the self-‐exclusion space supports what Amity’s clients discuss as problematic: cooling off period, single venue implementation and a lack of information about the process for both the individual and staff in venues.
Self-‐exclusion aims to prevent access to gambling rather than address factors contributing to impaired control (Blaszczynski, Ladouceur & Nower, 2007). Other jurisdictions in Australia assist individuals who wish to self-‐exclude through an independent process that does not require the person identifying as having problems with gambling to enter the gambling venues to self-‐exclude. Single venue Parke and Rigbye (2014) state there is a need to acknowledge self-‐exclusion programs are undermined by the opportunity to gamble at different venues, with different operators, on different products, in different jurisdictions if single venue approach is in place. Amity clients tell us that entering each venue to exclude can become increasingly difficult as many venues appear to be unclear of the process and this increases people’s feelings of anxiety, shame and stigma about having problems. For example, if an individual decides to engage in self-‐exclusion and lives in the Tiwi area they may decide to self-‐exclude from all venues within the vicinity – this could involve up to 8 venues. Some people tell us that by the time they have attempted the first couple they are so anxious they fold up the forms and find themselves gambling in the next venue to reduce their negative feelings. Unsupported staff O’Neil and colleagues (2003) state that venue staff may have a lack of experience and support in administration processes. Also that venue staff report feelings of being unsupported to fully engage in training and skill building to better manage self-‐exclusion with people (O’Neil et al., 2003).
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Enforcement Tremblay et al (2008) found that while 46% of individuals engaging in self-‐exclusion reported a breach, 82% of all participants still found it ‘very’ or ‘totally effective’ with significant reductions in money and time spent gambling and a reduction of negative consequences of gambling such as depression, anxiety and at-‐risk alcohol consumption (Gainsbury, 2014). Ongoing changes in the regulatory environment with a focus on the implementation and adherence to requirements under the Code can work to strengthen processes. Revocation Parke and Rigby (2014) found that through their qualitative study, a large majority of gambling operators supported the best practice of ‘requests to exclude should take immediate effect’. Low uptake Literature identifies that uptake of self-‐exclusion programs are low. Looking nationally and internationally, even with wide promotion of self-‐exclusion this is likely to remain the case. Time periods for self-‐exclusion may deter some people from registering with program (Gainsbury 2010). Shorter periods of self-‐exclusion may be necessary and used as a tool for ‘high risk times’. A study collecting qualitative data on focus groups of people who have self-‐excluded in Canada, had a group which suggested “time out” or “cool down” periods which they thought may be useful in conjunction with counselling (Responsible Gambling Council, 2008) as an alternative to longer self-‐exclusion periods. Cultural change There are suggestions that more support for people who choose to self-‐exclude could be provided which then may increase uptake of treatment options (The Responsible Gaming Council, 2008). Increasing promotion of self-‐exclusion as a strategy to ‘take back control’ could work to reduce the know barriers such as shame and stigma (Productivity Commission, 2010). Thus moving self-‐exclusion from an abstinence approach to a mechanism of self-‐control. Conclusions drawn in a recent broader review of operator-‐based approaches to harm minimisation (see Blaszczynski, Parke, Parke and Rigbye, 2014) suggests that the following will likely be important in facilitating effective self-‐exclusion:
• Guidelines for self-‐exclusion should be prescriptive wherever possible (e.g., specifications regarding what constitute a minimum acceptable level of ‘active promotion’).
• Appropriate responsible gambling intervention training, with clear specification of staff responsibilities, should be put in place.
• The at-‐risk player should be engaged, wherever possible, before significant harm is experienced.
• Self-‐exclusion strategies should be evaluated using robust research designs, adequately sized samples, adequate outcome variables and follow-‐up measures.
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Learning from the evidence. Implications for the Territory
While there isn’t comprehensive literature to easily evaluate best practice, preliminary findings indicate that self-‐exclusion has significant benefits for problem gamblers. Self-‐reporting has found that people indicate less gambling, increased feelings of self-‐control and increased psychological wellbeing and overall functioning (Gainsbury, 2014). Parke and Rigby (2014) in their study found that flexibility of a self-‐exclusion program may work to increase uptake to a wider audience and promote self-‐control rather than abstinence.
There are many areas in which existing processes could be improved such as: • A comprehensive (e.g. multi-‐site, multi-‐operator, geographical, by type) rather than
isolated coverage; • A procedure that is quick and simple to implement and reinstate; • Minimising exposure, for the ‘self-‐excluder’, to gambling venues and products (e.g.
people can access self exclusion from a treatment provider not only venues); • Increase flexibility in the process (e.g. remotely accessed, electronic completion of
the form) • A widely promoted public health campaign; and • Ongoing training for all gambling venues.
Flexibility may include a range of self-‐exclusion time periods, the option of choosing geographical regions to exclude from, single-‐venue or multi-‐venue exclusion, and options of multiple access points for registration or renewal (e.g. venues, treatment providers or remotely) (Parke & Rigby 2014). Flexibility in the program is useful when acknowledging that self-‐exclusion may be a tool in self-‐control rather than assuming all potential participants want to adopt life-‐long abstinence (Parke & Rigbye, 2014). Parke and Rigby’s (2014) review of the literature around self-‐exclusion found simplicity and convenience as the key guiding principles underpinning successful self-‐exclusion.
Self-‐exclusion programs need to be widely promoted throughout the Territory to be an effective tool in harm minimisation. One of the recommendations by a study from Irwin et al (2011) looking into perceptions and experiences of program participants was to enhance program awareness through greater program marketing. Program participants reported that had they discovered the program earlier, they would have enrolled prior to losing more money. Parke and Rigby (2014) also found active and strategic promotion is a requirement of effective self-‐exclusion. Research in health promotions has suggested that campaigns are more likely to be effective when they are: well-‐resourced and enduring; target a clearly defined audience; are based on advanced marketing strategies that effectively target, communicate with, and have relevance for, and credibility with the audience; and provide a credible message to which the audience is frequently exposed (see Attachment A for QLD examples).
Health Promotion is conducted by: displays in gaming venues; health promotion material in health and community services; health promotion material in key locations such as public libraries, bus
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interchanges, shopping centres and Centrelink Offices; and broadcasting of key messages and strategies through media.
Cultural Change
Other jurisdictions have identified key components to culture change in this area. For example Queensland identified that a culture change required collaboration from treatment agencies, government, industry, people whom gamble and the broader community. Changing views of self-‐exclusion could encompass in-‐venue education and a widely promoted public health campaign.
Recommendations for the Northern Territory
The Territory could benefit from increasing flexibility into the current process by implementing a multi-‐venue, geographical, or by type of self-‐exclusion process that has a centralised database and is managed by a single entity. Increase flexibility into the process by ensuring that self-‐exclusion is widely promoted as a strategy ‘to take back control’ and is simple to understand and engage in for people choosing the option. This would need to be supported through the provision of training to gaming employees throughout the Territory. Any changes to process and procedures would benefit from an independent evaluation to gauge uptake, effectiveness and simplicity in the process.
Evaluation
While self-‐exclusion programs are available and recognised in many jurisdictions, few evaluation studies on the effectiveness of these programs have been carried out (Ladouceur & Sylvain, 2007). Livingstone and colleagues (2014) in their research stated that a rigorous, mandatory evaluation and assessment of harm minimisation measures was required.
The evaluation proposed here is not in a research project but rather a review of perspectives, limitations, strengths of the process and outcomes. This evaluation would examine the development and implementation of change around self-‐exclusion to determine if the changes have increased awareness and flexibility of self-‐exclusion.
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References
Blaszczynski, A., Ladouceur, R., & Nower, L. (2007). Self-‐exclusion: A proposed Gateway to Treatment Model. International Gambling Studies, Vol 7, 59-‐71.
Blaszczynski, A., Ladouceur, R., & Shaffer, H. J. (2004). A science-‐based framework for responsible gambling: The Reno Model. Journal of Gambling Studies, Vol 20, 3, 301-‐317.
Cohen, I, McCormick, A, Corrado, R. (2011). BCLC’s Voluntary Self-‐Exclusion Program: Perceptions and Experiences of a Sample of Program Participants. BC Centre for Social Responsibility.
Fogarty, C., & Young, M. (2008). Gambling Harm-‐minimisation measures post 1999: An Australian overview with particular reference to the Northern Territory. Discussion paper prepared for the Community Benefit Committee and Department of Justice, Northern Territory Government.
Gainsbury, S. (2013). Review of self-‐exclusion grom gambling venues as an intervention for problem gambling. Journal of Gambling Studies, 1-‐23.
Korn, D. A. (2002). Examining gambling issues from a public health perspective. The Electronic Journal of Gambling Studies, Vol 4, 1-‐18.
Ladouceur, R., & Sylvain, C. (2007). Self-‐Exclusion Program: A Longitudinal Evaluation Study. Journal Gambling Studies, Vol 23, 85-‐94.
Livingstone, C., Rintoul, A., & Francis, L. (2014). What is the evidence for harm minimisation measures in gambling venues? Evidence Base, issue 2.
National Centre for Responsible Gaming. (2010). Increasing the odds. A series dedicated to
understanding gambling disorders. Volume 5: Evaluation self-‐exclusion as an intervention for disordered gambling. National Centre for Responsible Gaming, USA.
O’Neil, M., Whetton, S., Dolman, B., Herbert, M., Giannopoulos, V., O'Neil, D., & Wordley, J. (2003).
Evaluation of Self-‐exclusion Programs and Harm Minimisation Measures: Report A. South Australian Centre for Economic Studies, Adelaide.
Parke, J., & Rigbye, J. (2014). Self-‐Exclusion as a Gambling Harm Minimisation Measure in Great
Britain: An Overview of the Academic Evidence and Perspectives from Industry and Treatment Professionals. Responsible Gambling Trust.
Williams, R., West, B., & Simpson, R. (2012). Prevention of Problem Gambling: A Comprehensive
Review of the Evidence and Identified Best Practices, Ontario Problem Gambling Research Centre and the Ontario Ministry of Health and Long Term Care.
Winslow, C-‐E A. (1920). The untilled fields of public health. Science 51(1306), 23–33.
doi:10.1126/science.51.1306.23.
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Attachment A
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