Hotels Queensland responsible gambling Resource manual - SectionA V3.2 2020 - Developed by Queensland Hotels Association and the Department of ...
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Department of Justice and Attorney-General
Queensland responsible gambling
Resource manual
Section A • V3.2 • 2020
Hotels
Developed by Queensland Hotels Association and the Department of Justice and Attorney-General
Contents
Practice 1 Provision of information............................. 3 Practice 4 Physical environment............................... 26
1.1 Potential risks...................................................... 3 4.1 Minors prohibited and
1.2 Available on request............................................ 3 4.2 Minors excluded................................................ 26
Example 1.2A Responsible gambling (house) policy....4 4.3 Hospitality services .......................................... 26
Example 1.2B Player information guide................... 5 4.4 Unduly intoxicated customers............................ 26
1.3 Odds of winning major prizes............................... 7 4.5 Child care and play areas................................... 27
1.4 Predominant cultural groups................................ 7 4.6 Gratuities.......................................................... 27
Examples of acceptable/unacceptable actions............ 7 4.7 Passage of time................................................. 27
4.8 Breaks in play .................................................. 27
Practice 2 Interaction with customers and community....8
4.9 New gambling products and services................. 28
2.1 Community liaison .............................................. 8
Example 4.9A New gambling service/product
2.2 Customer liaison role.......................................... 8 guideline—responsible gambling........................... 28
2.3 Customer complaints........................................... 9 Examples of acceptable/unacceptable actions.......... 28
Example 2.3A Complaint handling procedures........ 9
Practice 5 Financial transactions.............................. 29
Example 2.3B Gambling-related incident report.....10
5.1 ATM facilities..................................................... 29
2.4 Training and skills development.......................... 11
5.2 Cashing of cheques and payment of winnings ... 29
Example 2.4A Possible problem gambling risk
indicators .............................................................. 11 Example 5.2A Financial transactions policy........... 30
Example 2.4B Register of training..........................12 5.3 Credit betting (lending of money) ...................... 30
Examples of acceptable/unacceptable actions...........12 Examples of acceptable/unacceptable actions.......... 30
Practice 3 Exclusion provisions.................................13 Practice 6 Advertising and promotions......................31
3.1 Exclusion procedures .........................................13 6.1 Code of Ethics.....................................................31
Self-exclusion checklist (document exchange)......... 15 6.2 False, misleading or deceptive .......................... 32
Venue-initiated exclusion checklist 6.3 Misrepresentation of probabilities..................... 32
(document exchange).............................................16 6.4 Reasonable strategy (financial betterment)........ 33
Example 3.1A Self-exclusion flowchart...................18 6.5 Misleading statements...................................... 33
Example 3.1B Venue-initiated exclusion flowchart.... 19 6.6 Community standards....................................... 34
Example 3.1C Revocation process flowchart.......... 20 6.7 Other activities to promote................................ 34
Example 3.1D Conditions of re-entry 6.8 Minors or vulnerable or disadvantaged groups.... 34
(participation in gambling activities)......................21 6.9 External signs................................................... 35
Example 3.1E Consent to monitor my gambling 6.10 Irresponsible trading practices......................... 35
activities............................................................... 22
6.11 Consumption of alcohol.................................... 36
3.2 Contact information for support services........... 23
6.12 Consent of the person ..................................... 36
3.3 Exclusion from other gambling providers........... 23
6.13 Responsible gambling messages...................... 37
3.4 Correspondence to excluded customers ............ 23
Examples of acceptable/unacceptable actions.......... 23 Gambling help information...................................... 38
Glossary of terms..................................................... 24 Examples of risk indicators.................................... 39
Glossary of exclusion forms..................................... 25
Queensland responsible gambling resource manual | Section A | Hotels 2
Practice 1
Provision of information
Introduction
Hotels have a responsibility to offer their customers accurate and meaningful information so that they are able to
make informed decisions about their gambling. This information will be readily available to all customers and will
be placed in high traffic areas in and around designated gambling areas.
1.1 Potential risks 1.2 Available on request
Information about the potential risks associated with Information is displayed in a prominent location to
gambling and where to get help for problem gambling alert customers that the following information is
is prominently displayed in all gambling areas and available on request:
near cash out facilities which service gambling areas. • the gambling provider’s Responsible gambling
policy document including policies for addressing
Actions of the gambling provider
problem gambling issues relevant to the local
The hotel will prominently display current responsible community
gambling signage and information on where to get
• the nature of games, game rules, odds or returns to
help in designated gambling areas and near ATM and
players
EFTPOS/cash out facilities servicing gambling areas.
Current in-venue signage includes: • exclusion provisions
• gambling-related complaint handling procedures
• key elements of the gambling provider’s financial
transaction practices.
Actions of the gambling provider
Hotels will alert customers (this could be in the
form of a board, sign or poster), that additional
information is available on request, which includes:
• the Responsible gambling (house) policy (Example
1.2A) including policies for addressing problem
gambling issues relevant to the local community
• Player information guide (Example 1.2B) detailing
information on the nature of games, game rules,
odds or returns to players
For additional information about where the signage
• exclusion provisions
can be used, or to download copies please visit
www.business.qld.gov.au/liquor-gaming • gambling-related compliant handling procedures
• key elements of the gambling provider’s financial
Ongoing maintenance of signage and information will
transaction practices.
be the responsibility of the gambling provider.
Best practice Best practice
Local gambling help services may have brochures Gambling providers may choose to display their full
that advertise their services and these can be used or summarised Responsible gambling (house) policy
in locations around the gambling area and/or venue and Player information guide in prominent location/s.
at the manager’s discretion—for example, on the Any customer becoming a member of a loyalty
back of toilet doors. In addition, gambling providers program would automatically be provided with
could display responsible gambling signage and this information at some stage in their application
information in other areas of the venue, for example process (upon initial application or on issue of a
near the cashier’s booth and/or stand-alone change loyalty card or similar).
dispensing devices.
Queensland responsible gambling resource manual | Section A | Hotels 3
Members of the Queensland Hotels Association Example 1.2A Responsible
(QHA) will also have access to the fortnightly
newsletter and monthly magazine that will provide
gambling (house) policy
them with informative articles, industry and Goal
Queensland responsible gambling Code of Practice
This house policy broadly defines the range
(Code of Practice) updates particularly in relation to
of responsible gambling initiatives and harm
best practice initiatives and general gambling-related
minimisation strategies within the venue. If you
pieces. In addition to this, the QHA will provide a
require further clarification on any of the information
responsible gambling section in the Members Only
contained within this policy please ask one of
area of their website.
our friendly staff to assist you. Enjoy responsible
Hotels could consider providing information in a gambling.
range of languages other than English. Demographic
information for each hotel’s local community and General
languages spoken can be found at the Australian Management and staff of this hotel support the
Bureau of Statistics website (www.abs.gov.au) and responsible provision of gambling products at the
hotels could contact the relevant local community venue for our customers’ enjoyment.
organisation for assistance with translation. This hotel has a senior staff member who can assist
Additionally hotels could also post information on you with all gambling-related enquiries.
their own websites.
Gambling products are offered at this venue in
accordance with the relevant legislation related to
that product.
Practices
1. Provision of information
The hotel has available a range of information,
upon request, to assist customers with their
decision to gamble, which includes:
• Player information guide
• signage on the potential harm of gambling
• Gambling Help services to assist those affected
by gambling.
2. Interaction with customers and community
The venue has available a senior staff member to
assist with:
• customers’ enquiries on gambling-related issues
• facilitating exclusion programs for customers
• liaison with community network groups
• resolving customer complaints.
The venue has a commitment to the ongoing
training and development of staff and management
in the responsible provision of gambling and
gambling products.
The venue has in place detailed complaint handling
procedures for the amicable and timely resolving of
complaints.
3. Exclusion provisions
The hotel will offer exclusion provisions as one of
a range of proactive measures to assist those with
gambling problems.
Please ask a staff member for the [insert position here],
for example, customer liaison officer or manager.
Queensland responsible gambling resource manual | Section A | Hotels 4
4. Physical environment Example 1.2B Player information
Minors are not permitted to gamble nor be in a
designated gambling area, and the only acceptable
guide
forms of identification to ascertain age are: Introduction
• current driver licence/learner permit This guide is offered to ensure that customers of this
• current passport (from any country) hotel are provided with relevant information on a
• Adult Proof of Age card (18+ Card) range of gambling products provided by the venue.
• Keypass identity card Gambling is a past time enjoyed by many Australians
• Foreign driver licences with a photo and date of and has long been a part of Australian society. For
birth of the licence holder. some however, gambling may become a problem.
Where a foreign driver licence is not written in This venue is committed to providing any gambling
English, an international driver permit issued in product in such a way as to maximise the benefit
the foreign country of origin (and including a photo most people gain from this ancillary form of
of the licence holder and translation) must be entertainment, whilst minimising any potential
presented with the foreign driver licence. harm that some people may experience when their
gambling becomes a problem. Sometimes, this
Customers who are unduly intoxicated will be
behaviour may affect the customer themselves,
refused service of alcohol, will not be permitted to
and/or their family and friends, and which may
gamble and may be asked to leave the premises.
extend to the wider community.
The hotel will provide a safe and clean gambling
Whilst offering players a general guide to gambling at
area at all times.
the venue, this booklet also offers some helpful hints
Customers’ privacy and confidentiality will be a top to assist customers control their use of gambling to
priority all of the time. ensure it is enjoyed for what it is—entertainment.
Gaming machines will be maintained in premium What are your chances of winning?
condition all of the time and any machine unable to
Customers should be aware of their odds or chances
be played will be clearly marked.
of winning on a range of commonly used gambling
The ‘chocking’ or continual depressing of buttons services at the venue. These services include
by insertion of a coaster, plastic peg or similar is electronic gaming machines (known as EGMs or
not allowed at this hotel. pokies) and Keno.
5. Financial transactions
Electronic Gaming Machines
Credit betting is illegal.
All EGMs undergo stringent testing before they are
No credit is available to anyone, at any time, under installed in venues to ensure they comply with strict
any circumstance. government regulations. By law, each EGM must also
The ATMs within this venue have access only to be approved in Queensland. This is noted by the
debit accounts. presence of an official machine plate found on the
Please refer to the hotel’s Financial transactions side of the machine. These measures are taken for
policy for more information. your protection.
6. Advertising and promotions By law, all EGMs in Queensland are programmed
For more information on acceptable and to return to player (RTP) between 85–92 per cent
unacceptable advertising and promotions, of takings. This means that for every $1 invested,
including player loyalty/rewards programs, please the machine is programmed an RTP of between 85
refer to the Advertising and promotions section cents and 92 cents on average, over a long period of
of the Queensland responsible gambling resource time. As stated, the RTP is a long term average and
manual (Hotels). it means that, in the long run, the machine always
‘The [insert hotel name]—promoting responsible comes out ahead.
enjoyment’. The stopping position of each reel is completely
random and is done separately and independently
of each reel. The outcome of each spin is completely
random and whether you win or lose is totally a
matter of luck.
Queensland responsible gambling resource manual | Section A | Hotels 5
Gaming machines are not pre-programmed to pay at Do you have a problem with gambling?
a specific time or after any particular cycle. In other Sometimes, a person’s gambling behaviour may
words, a customer’s chances of winning or losing are cause harm to themselves or their families or friends.
exactly the same for every play, regardless of any Quite often, a person may not realise they have a
previous play. problem with gambling.
So, it does not make a difference whether: Ask yourself—do you:
• you play a pokie straight after someone else has • think a lot about your previous or next gambling
had a large payout adventure?
• you play a machine that has not had a large payout • get irritable if you cannot gamble?
for sometime
• find yourself increasing the amount you gamble?
• you play at certain times and/or certain days
• gamble to win back losses?
• you press the button in certain ways.
• try to hide how much time and money you spend
Odds on gambling?
The chances of the same five symbols appearing • have problems in work or relationships as a result
in the highest winning combination depend on the of gambling?
game design and are generally very small (this can • borrow money or sell goods to assist in paying
be as little as 1 in 7 million). This means that for up to household bills?
every 7 million times the reels are spun, five symbols • commit unlawful acts to finance gambling?
appearing in the highest winning combination may
• have difficulty controlling your gambling?
occur only once on average. Of course, there is an
increased chance of winning a smaller prize which • gamble to avoid thinking about or dealing with
requires fewer matching symbols or lower paying difficult issues?
symbols. An example may be as follows: If you answered ‘yes’ to one or more of these
5 of the same lower paying symbols–1 chance in questions, you may have problems with gambling.
4,784 spins If you would like more information or want to talk to
4 of the same symbols–1 chance in 490 spins someone about your gambling, call the Gambling
3 of the same symbols–1 chance in 45 spins Helpline on 1800 858 858 or contact one of the
friendly staff at this hotel. Confidentiality and privacy
2 of the same symbols–1 chance in 9 spins.
are ensured.
Remember, the chances of specific combinations
occurring are totally random.
Numbers games (Keno)
Keno is found in hotels, clubs and casinos around
the State. Games are drawn every three minutes. Like
Lotto or Powerball, the numbers are drawn using a
device that is basically a random number generator.
In Keno there are 80 numbers—1 to 80. Under strict
supervision 20 numbers are drawn, as mentioned,
at random. Players can choose from 1 to 10 numbers,
then 15, 20, and 40.
Odds
If you choose 7, 8, 9 or 10 numbers, a proportion of
your bet, or wager, will be allocated to the jackpot for
7, 8, 9 or 10 number games. Your chance of winning
the jackpot on the 10 number game is 1 in 8,911,711.
This basically means that on average, if you play over
8 million games, you may win the jackpot once.
Queensland responsible gambling resource manual | Section A | Hotels 6
1.3 Odds of winning major prizes 1.4 Predominant cultural groups
Meaningful and accurate information on the odds of Gambling providers are to provide information and
winning major prizes is prominently displayed in all materials suitable for predominant cultural groups in
gambling areas and in proximity to relevant games. their local community.
Actions of the gambling provider Actions of the gambling provider
Information on the odds of winning major prizes on The hotel will:
various forms of gambling will be displayed in all • provide an information sheet in a language, other
gambling areas and in proximity to relevant games. than English, if required by the demographic
makeup of the membership or patronage
Best practice
• ensure that the responsible gambling messages
To do this the hotel could:
contained in the information sheet are culturally-
• display odds of winning major prizes by displaying appropriate
the chances of winning
• include a note in the English language version of
• ensure gambling staff are informed about the odds the information sheet that similar information is
of major prizes of gambling products offered at the also available in other languages.
venue
• prominently display the Player information guide Where suitable information and materials are
(Example 1.2B) in accessible areas around the not available, gambling providers should provide
venue including in designated gambling areas non-English speaking customers with the contact
and near ATMs, EFTPOS facilities and the cashier details for a translating service e.g. Translating and
booth, for customers’ use Interpreting Service (TIS) National on 131 450 or
www.tisnational.gov.au
• ensure adequate supply of these guides
• alert customers to its availability and promote its Best practice
use. The hotel may further develop or source a range of
responsible gambling materials in languages other
Hotels could promote the availability of these guides
than English, which are stored electronically and
via:
printed upon request.
• machine ‘talkers’ attached to the side of gaming
machines
• DL display stands in between gaming machines
• display stands near ATMs, EFTPOS/cash out Examples of acceptable/
facilities and cashier booths. unacceptable actions
The Player information guide will contain information Acceptable
beneficial to the player, and may include: Make customers aware that information is available
• the odds or chances of winning prizes on gambling on request that includes the venue’s Responsible
products and services—for example, gaming gambling (house) policy (Example 1.2A), information
machines and Keno on odds and returns to players, exclusion provisions,
• the potential harm that may result from gambling complaint handling procedures and key elements of
• some common indicators that may alert customers their financial transaction practices.
that their (or their family member’s or friend’s) Ensure sufficient stock of where to get help signs and
gambling behaviour is becoming a problem takeaway cards are maintained.
• the availability of counselling and other support
services
Unacceptable
Placing responsible gambling information in hard-to-
• general information to assist customers make
reach, inaccessible or hard-to-view locations in the
informed decisions about their gambling
venue.
expenditure and usage.
Informing customers that responsible gambling
information is unavailable.
Queensland responsible gambling resource manual | Section A | Hotels 7
Practice 2
Interaction with customers and community
Introduction
Hotels must ensure adequate liaison with customers and the relevant local community groups on an as required
basis to effectively resolve problem gambling issues and to receive feedback and facilitate cooperation.
Cooperation between the hotel and the relevant local community groups, or nearest available groups, has
important advantages such as:
• community networking makes good business sense and offers hotels the opportunity to understand local
community issues
• promoting the hotel as an active and responsible community partner.
2.1 Community liaison 2.2 Customer liaison role
To support early intervention and prevention strategies Gambling providers are to nominate a person/s to
where opportunities arise, gambling providers are to perform the customer liaison role and who is to:
establish effective mechanisms to link with: • be available during approved opening gaming
• local gambling-related support services hours
• community networks where responsible gambling- • provide appropriate information to assist customers
related issues could be raised. with gambling-related problems
Actions of the gambling provider • support staff in providing assistance to those
customers
The hotel will ensure a senior/responsible staff
member performs the role of customer liaison officer • provide assistance to staff with gambling-related
(CLO) to establish and continue open communication problems
channels with local gambling-related support • develop linkages with local community groups
services and relevant local community networks. where opportunities arise.
This appointment is at the manager’s discretion
Actions of the gambling provider
and in some instances this may be the manager.
The tasks associated with this role do not warrant The hotel will nominate a senior/responsible gaming
the development of a new position, but rather staff member (e.g. a gaming supervisor/manager or
incorporate a current role. assistant/duty manager or indeed the hotel manager)
as the CLO who will be responsible for all customer
Establish links between hotels and local relevant liaison matters concerning, in the primary instance,
community networks and support services. The CLO gambling-related issues. This staff member will:
could make contact with the local (nearest) Gambling
• ensure information is displayed as required by
Help service provider to open up communication and
Practice 1.1
establish a relationship that will assist the gambling
provider to deal with any problem gambling issues • provide relevant information to hotel customers
that may arise in the future. and staff who make it known to the staff member
they have gambling-related problems, which
The CLO could contact the local Gambling Help includes at a minimum, information about the
service and invite them to conduct a training session nearest support service
for the hotel staff. The training session could
• support staff in providing assistance to customers
focus on equipping gaming staff with information
with gambling-related problems
and strategies to help customers with gambling
problems, together with conflict resolution, physical • offer venue staff and management regular updates
and mental signs of stress and stress management. on gambling-related issues and enquiries and
appropriate action, whilst maintaining customers’
The hotel will provide ongoing training for staff in and/or staff’s privacy and confidentiality at all
responsible gambling services and products. The times
hotel will establish customer complaint handling
• attend relevant meetings as and when required.
procedures.
Queensland responsible gambling resource manual | Section A | Hotels 8Best practice Example 2.3A Complaint
Hotel staff meetings could have an update from the handling procedures
CLO on concerns/developments/actions taken on
gambling-related issues. The [insert hotel name here] aims to provide great
service and quality facilities for all our customers to
The CLO would be responsible for internally and enjoy all of the time.
externally provided training in the responsible service
of gambling, customer care and management of We recognise that sometimes this may not happen.
self-exclusions, venue-initiated exclusions, Appreciating the value of our customers and the
revocations and the handling of contraventions. importance of return business, please raise any
query with the customer liaison officer (CLO) or the
manager (venues please delete as required) and
2.3 Customer complaints follow these steps to resolve the issue satisfactorily:
Complaint handling procedures that can deal with 1. All comments and complaints are to be referred to
gambling issues are established and promoted by the CLO. In their absence, please refer any issue to
gambling providers. the manager.
Actions of the gambling provider 2. If a gambling-related complaint, ensure the
Gambling-related incident report (Example 2.3B) is
The hotel will establish and implement formal
completed.
Complaint handling procedures (Example 2.3A), if
one does not already exist, to effectively resolve to 3. The CLO will contact the customer to:
each party’s satisfaction, any complaints arising from • ensure the exact nature of the comment or
gambling-related issues. Example 2.3A is offered complaint is known
as an example only and hotels are encouraged to • advise the customer of action to be taken.
develop their own complaint handling procedures. 4. A decision will be made as to whether the comment
The CLO will handle/record all complaints/incidents or complaint can be resolved immediately by
of a gambling nature using a Gambling-related the CLO or whether it needs referral to a higher
incident report (Example 2.3B). In their absence, level, e.g. management or the Office of Liquor and
a suitable alternative staff member should be Gaming Regulation (OLGR).
nominated. Details of any incidents or complaints 5. If referral to a higher level is required, the customer
will be entered into the register of gambling-related must be notified within 48 hours of the complaint
complaints. Only designated people (e.g. the being made as to the timeframe for response.
manager, the CLO or their nominated replacement) 6. An initial written notice in relation to payout
can complete the register in full. refusals is required (pursuant to s. 245 of the
The hotel and relevant staff should note that payout Gaming Machine Act 1991) to be made as soon as
refusals may include the involvement of the Licensed practicable after the decision is made.
Monitoring Operator and/or the Office of Liquor 7. Any solution arrived at should be supported by the
and Gaming Regulation (OLGR). All matters should appropriate hotel policy or procedural statement
be well documented with supporting evidence and/or legislative conditions. This should be
and information. Pursuant to s. 245 of the Gaming advised in writing.
Machine Act 1991, a written notice in the case of a 8. Should the customer not be satisfied with the
payout refusal must be provided. result, they will be advised of the relevant appeals
Best practice mechanisms, such as OLGR.
In addition to the complaint handling procedures
and the register, hotels could implement additional
initiatives that may include:
• follow up complaint within 48 hours as a maximum
• advising customers of the relevant appeals
processes (e.g. Licensed Monitoring Operators and
OLGR) for payout refusals
• customer comment/feedback cards/forms in
appropriate areas
• ‘handling customer complaints’ training at
induction or further on-going training.
Queensland responsible gambling resource manual | Section A | Hotels 9Example 2.3B Gambling-related incident report Site name ________________________________________________________________________________________________ Incident date________________________________________ Incident time_________________________________________ Who reported the incident? (record as many details as possible) Name ______________________________________________ Phone_______________________________________________ Address__________________________________________________________________________________________________ City____________________________________________________ State/Territory____________ Postcode ________________ Email ___________________________________________________________________________________________________ Incident details (attach additional pages if required) ________________________________________________________________________________________________________ ________________________________________________________________________________________________________ ________________________________________________________________________________________________________ ________________________________________________________________________________________________________ ________________________________________________________________________________________________________ ________________________________________________________________________________________________________ ________________________________________________________________________________________________________ Immediate action taken (attach additional pages if required) ________________________________________________________________________________________________________ ________________________________________________________________________________________________________ ________________________________________________________________________________________________________ ________________________________________________________________________________________________________ ________________________________________________________________________________________________________ Follow-up action/other matters to note (attach additional pages if required) ________________________________________________________________________________________________________ ________________________________________________________________________________________________________ ________________________________________________________________________________________________________ ________________________________________________________________________________________________________ ________________________________________________________________________________________________________ Staff member details Staff member name________________________________________________________________________________________ Staff member position (customer liaison officer/manager/other)______________________________________________________ Signature ________________________________________________________________________ Date____________________ Queensland responsible gambling resource manual | Section A | Hotels 10
2.4 Training and skills Example 2.4A Possible problem
development gambling risk indicators
Mechanisms are established to ensure that Observed or reported signs
appropriate and ongoing responsible gambling
Emotional responses
training is provided to staff who provide gambling
products to customers. • Suffering from depression and/or have thoughts of
suicide due to gambling behaviour.
In addition, the relevant owners, boards and
• Kicking or violently striking machines.
managers receive appropriate information to guide
decision making in relation to responsible gambling. • Vocally displaying anger (swearing to themselves,
grunts) and/or threatening or causing physical
Actions of the gambling provider harm to others or self.
Management of the hotel and staff involved in • Looking sad or depressed after gambling.
gambling-related duties will undertake training in the • Crying after losing a lot of money.
responsible provision of gambling products including Faulty cognition
Possible problem gambling risk indicators (Example
• Having an unrealistic perception about the chance/
2.4A) for staff. All such training will be regularly
odds of winning.
updated in the hotel’s Register of training (Example
2.4B) and the relevant staff file, in collaboration with Frequency, duration and intensity
the staff member performing the customer liaison • Gambling every day of the week.
role. Training will be ongoing for staff and gambling • Gambling continuously without taking a break for
providers which can take one or a combination of extended periods of time.
forms. Impaired control/loss of control
For example, mandatory responsible service • Trying obsessively to win on a particular machine.
of gambling training from a registered training • Spending too much time and/or money gambling.
organisation (e.g. QHA) can be completed either:
Irrational attributions/behaviours
• in-house (e.g. QHA)
• Blaming the venue, staff or gaming machines
• by staff attending a ‘public’ course offered by a because they lost.
reputable training provider.
Raising funds/chasing behaviour
Best practice • Getting cash out from an ATM at the venue on
Staff and management are encouraged to investigate multiple occasions.
additional sources of gambling-related information • Trying to borrow, ‘scam’ money or sell valuables to
pertaining to training and skills development—for others for gambling.
example:
• Putting large win amounts back into the machine
• professional development short courses and and keeps playing.
workshops Social behaviours
• attendance at trade shows featuring gambling • Friends or relatives call or arrive to ask if the
products/services person is still at the venue.
• subscription to regulatory bodies’ publications, You may encounter customers displaying one or
newsletters, fact sheets, e.g. OLGR’s Responsible several of these indicators. Displaying one risk
service newsletter indicator may not mean the customer is a problem
• subscription to industry associations’ newsletters gambler (unless they display that particular risk
and magazines, e.g. QHA’s monthly Review and indicator to an unreasonable degree). Some of the
fortnightly update indicators can be quite subtle whilst others may be
• research on the internet—for example, more obvious. We are looking for clusters of three or
www.qha.org.au and more indicators. And remember, you are not a trained
www.business.qld.gov.au/liquor-gaming counsellor; your job is to respond with respect and
refer accordingly.
Adapted from Delfabbro, P.H., Osborn, A., Nevile, M., Skelt,
L. & McMillen, J. (2007). Identifying Problem Gamblers in
Gambling Venues, Gambling Research Australia, Melbourne
and Responsible Gambling Advisory Committee Exclusions
Focus Group (2002) Pathways and Protocols for Exclusion–An
Intervention/Rehabilitation Strategy.
Queensland responsible gambling resource manual | Section A | Hotels 11Example 2.4B Register of training
This register may be used to record relevant training undertaken by gambling-related customer service staff such
as the customer liaison officer.
Training undertaken
Staff member’s name Payroll number/ID number
(including completion date)
Examples of acceptable/unacceptable actions
Acceptable Unacceptable
Promptly referring customers who have a gambling- Breaching a customer’s or staff member’s
related problem or complaint to the customer liaison confidentiality by discussing issues or facts with
officer or staff member performing this role. other customers or staff members.
Offering customers with complaints the venue’s Not offering assistance to customers or staff
complaint handling procedures. members who indicate they have a complaint related
to gambling.
Queensland responsible gambling resource manual | Section A | Hotels 12Practice 3
Exclusion provisions
Self-exclusions and venue-initiated exclusions for problem gambling
Introduction
In the following sections the term gambling provider It is the responsibility of all gambling providers under
is used, which refers to a hotel with one or more legislation to actively enforce exclusion procedures
gambling products (pokies, TAB, Keno). The term with customers. Gambling providers are obliged to
licensee may also be used. This refers to the person provide assistance to customers who present for
or legal entity (company/incorporated body) in whose self-exclusion and to follow through with the
name the liquor and gaming licenses are issued. The exclusion process.
responsibilities attributed to the licensee may be
At all times the customer who is seeking an exclusion
carried out by their nominated representative which
will be required to make contact with the CLO or
may include the gaming nominee, manager or CLO.
nominated person of the hotel in the first instance
The exclusion provisions are aimed at supporting and apply for the exclusion in person.
customers who are, or who are at risk of, engaging in
Legislative references:
problem gambling behaviours. Exclusions may also
be referred to as banning. An exclusion can be either • Gaming Machine Act 1991
requested by a customer (self-exclusion) or directed • Keno Act 1996
by a gambling provider (venue-initiated exclusion). • Wagering Act 1998.
Exclusions offer the option of banning a customer
from specific gambling providers, gambling products 3.1 Exclusion procedures
or services. This can be from either the whole of a Gambling providers to provide exclusion procedures
venue or part of a venue, e.g. gaming machine area/ and supporting documentation.
Keno/TAB/all of these areas.
Actions of the gambling provider
The areas from which the customer is to be excluded
Management/senior gaming/gambling staff and the
can be determined either by:
CLO will familiarise themselves with the following:
• mutual agreement between the customer and the
• Self-exclusion flowchart (Example 3.1A)
venue in the case of self-exclusion
• Venue-initiated exclusion flowchart (Example 3.1B)
• the gambling provider’s discretion in the case of
venue-initiated exclusion. • Revocation process flowchart (Example 3.1C)
Specific actions of both the customer and gambling • Conditions of re-entry (participation in gambling
provider are prescribed in the legislation relating activities) (Example 3.1D).
to exclusions. Options are available to gambling
The hotel will develop and implement the following
providers and customers to limit contact with
minimum procedures for exclusions.
gambling activities. The advice of a concerned third
Note: approved exclusion Forms 3A–3I referred to in this section
party may be taken into consideration by a gambling are available for download from
provider in any action taken. Penalties (including www.business.qld.gov.au/liquor-gaming
financial) may apply to both the customer and the
Self-exclusion
licensee (and/or staff) where the exclusion is not
correctly followed, or breached by either party. An Upon being approached by a customer seeking
example of a breach may be where an excluded assistance, hotel staff will listen intently to
customer tries to re-enter a venue from which he/she customer’s request in a confidential manner and
has been banned. explain the need to refer the matter to the CLO.
If the customer refuses this, staff should emphasise
that they cannot provide the most effective
assistance and should suggest a meeting with the
manager (if different to CLO).
Queensland responsible gambling resource manual | Section A | Hotels 13The CLO should discuss with the customer the option of five years, after which time it will automatically
of self-exclusion. The CLO should ensure that the expire. In addition the CLO/venue:
customer is provided with sufficient information • should ensure that the privacy statement of the
about the self-exclusion process to make an informed hotel is attached to the documentation being
decision when accepting or declining self-exclusion. provided to the customer
Specifically the CLO should discuss:
• must provide the customer with details of
• the self-exclusion process at least one community support service for
• the timeframe of self-exclusions advice, assistance and/or counselling relating to
• options for exclusion from whole or part venue/ problem gambling.
some or all gaming products 7. The CLO should encourage the customer to
• contact with community support services consider self-exclusion from all venues operated
by the licensee, where applicable, or other venues
• the forms required
that the customer may access within the local area
• legal implications (refer to Practice 3.3 p. 23 for more information).
• the right to seek independent legal advice 8. It is the responsibility of the licensee to complete
• penalties that apply for breach of an exclusion. an entry in the Register of excluded persons
(Form 3G) for each customer who is issued a
The patron then makes a decision whether to proceed
Self-exclusion order.
with the self exclusion. If the customer does not
agree to proceed with a self-exclusion, the CLO A 24 hour cooling-off period is applicable to self-
should complete the Gambling-related incident report exclusion orders only. Within 24 hours of being
(Example 2.3B). served (receiving) a Self-exclusion order, a customer
Implementing a self-exclusion may request to revoke the Order. In this instance, the
1. Once the CLO has informed the customer about the venue must supply the customer with a Revocation
self-exclusion process and if the customer wishes notice: self-exclusion order (Form 3C) to complete and
to proceed, the CLO must provide the customer submit to the venue within the 24 hour time limit.
with a Self-exclusion notice (Form 3A). If the Revocation notice: self-exclusion order is
2. The exclusion may only apply to some sections of submitted by the customer to the venue within the
the venue, taking into consideration the need for the 24 hour time limit, then the Self-exclusion order is
customer to access some community services within considered void and the customer may freely re-enter
the venue (such as ATM, dining/bistro). Where the premises and gaming area/s as though the Order
possible, the CLO should discuss with the customer had never been in place.
the area or types of gaming they wish to be excluded
If the Revocation notice: self-exclusion order is
from, e.g. TAB only/pokies area only/whole venue.
submitted after the 24 hour limit has lapsed, then
In completing the Self-exclusion notice, the customer
the customer must wait a further 12 months/one year
will need to indicate their choice of exclusion from
before making an application for revocation starting
the whole venue, or the area or gambling activity
from the first anniversary of the issue of the Order.
they wish to be excluded from.
Refer to the revocations section (p. 16) for more
3. The CLO may request that the customer provide details.
a photo to assist staff to enforce the exclusion.
The customer must provide a photo if requested Once the Self-exclusion order is in place, a licensee
by the hotel. or an employee of the licensee has an obligation to
take reasonable steps to prevent the customer, who
4. The customer completes and returns the Self-
is known to be excluded, from entering or remaining
exclusion notice to the CLO. The Self-exclusion
in the licensed premises or gaming machine area. If
notice will need to be witnessed by an adult over 18
a licensee or an employee of a licensee prevents an
years of age. This may be another member of staff.
excluded customer from entering or remaining on the
5. Once the customer has given the CLO the Self- licensed premises, they must as soon as practicable,
exclusion notice, the CLO must as soon as provide a Notice of contravention of self-exclusion
practicable complete the Self-exclusion order order/exclusion direction (Form 3H) to the Executive
(Form 3B). This can usually be done on the spot. Director of OLGR.
6. Once signed by the authorised person within the
The excluded customer should be removed from any
hotel, the Self-exclusion order must be served
promotional or mailing database lists.
upon (given to) the customer and is effective from
when it is given to the customer for a maximum
Queensland responsible gambling resource manual | Section A | Hotels 14Self-exclusion checklist 5. Where possible, the CLO is recommended to
provide the customer with details of at least one
(document exchange) community support service for advice, assistance
The customer will provide the hotel with: and/or counselling, such as the local Gambling
• a completed Self-exclusion notice Help service provider (or equivalent local welfare
• a recent, clear photo (if asked). service).
6. The licensee must accompany the Exclusion
The hotel will provide the customer with: direction with an Information notice—exclusion
• a Self-exclusion order direction (Form 3I) detailing the reasons for
• details of at least one counselling service dealing exclusion and the customer’s further avenues
with problem gambling of action, e.g. appeal. A hotel may also wish to
provide a copy of their Conditions of re-entry
• a Conditions of re-entry (participation in gambling
(participation in gambling activities) (Example
activities) document (Example 3.1D) (optional).
3.1D) with the Information notice—exclusion
The hotel will provide OLGR with: direction.
• a copy of the Register of excluded persons (when The Exclusion direction is effective from the time it is
requested by OLGR) given to the customer and has a maximum time frame
• a Notice of contravention of self-exclusion order/ of five years, unless revoked earlier. After five years
exclusion direction, where applicable. the Direction will automatically expire.
Once an Exclusion direction is in place, a licensee
or an employee of the licensee has an obligation to
Venue-initiated exclusion (Exclusion direction) take reasonable steps to prevent the customer, who
is known to be excluded, from entering or remaining
Implementation
in the licensed premises or gaming machine area.
If reasonable grounds exist to believe that a customer
The excluded customer should be removed from any
is a problem gambler, an exclusion may be put in
promotional or mailing database lists and ensure that
place by the gambling provider. This option should
any loyalty or smart cards held by the customer are
only be pursued after reasonable steps have
cancelled or disabled so as to prevent the customer
been taken by the CLO to approach the customer
from using them to gamble.
where possible and discuss self-exclusion with the
customer. It is the responsibility of the CLO to complete the
details of each excluded customer in the Register of
1. If the customer refuses self-exclusion and/or CLO
excluded persons (Form 3G) which should be kept
believes on reasonable grounds the customer
in a secure place at the venue at all times. The CLO
is a problem gambler, the hotel may issue an
will ensure that the venue submits statistical data
Exclusion direction (Form 3D) to customer. The
regarding exclusion activity (when requested by
Exclusion direction may apply to the whole venue
OLGR) by completing the Report on excluded persons
or alternatively only apply to some sections of
(Form 3R).
the venue, taking into consideration the need for
the customer to access some community services To enable the effective enforcement of the exclusion
within the venue (such as ATM, dining/bistro). throughout the venue, the CLO must advise all
Where possible, the CLO should discuss this with relevant staff of the customer’s exclusion in a
the customer. discreet and confidential manner.
2. The Exclusion direction and a copy of the hotel’s If a licensee or an employee of a licensee prevents an
privacy statement must be served upon the excluded customer from entering or remaining on the
customer. licensed premises, they must as soon as practicable,
3. Ensure that the Statement of service section of the provide a Notice of contravention of self-exclusion
hotel’s copy of the Exclusion direction is completed. order/exclusion direction (Form 3H) to the Executive
4. A recent photo of the customer may be requested Director of OLGR.
by the licensee to be kept by the licensee to assist Customers may apply to revoke or cancel the
staff to enforce the exclusion. Exclusion direction once every 12 months, starting
from the first anniversary of the issue of the
Direction.
Note: an Exclusion direction may relate to one or more premises
operated by the licensee.
Queensland responsible gambling resource manual | Section A | Hotels 15Venue-initiated exclusion process for a self-exclusion and venue-initiated
exclusion is different. Please note the separate
checklist (document exchange) processes carefully. A hotel is obliged to assist a
The customer may provide the hotel with: customer seeking a revocation of their exclusion.
• a recent, clear photo (if asked). Revoking a self-exclusion
To revoke a Self-exclusion order (Form 3B) a customer
The hotel will provide customer with:
must submit a completed Revocation notice: self-
• an Exclusion Direction exclusion order (Form 3C) to the licensee either:
• an Information notice—exclusion direction • within the 24 hour cooling-off period after receipt
• details of at least one counselling service dealing of Self-exclusion order from customer
with problem gambling • at least one year after the customer received the
• a Conditions of re-entry (participation in gambling Self-exclusion order.
activities) (Example 3.1D) optional.
Within the 24 hour cooling-off period: If a Revocation
The hotel will provide OLGR with: notice: self-exclusion order is submitted by the
• a copy of the Register of excluded persons (when customer to the hotel within the 24 hour cooling-off
requested by OLGR) period, then the Self-exclusion order ceases from the
• a Notice of contravention of exclusion order/ time the Revocation notice: self-exclusion order is
direction, where applicable. given to the CLO of the hotel (i.e. immediately) unless
the licensee seeks to implement a venue-initiated
exclusion.
At least one year after the self-exclusion has been
Approach by a third party
issued: If the hotel supports the customer’s request
If a staff member is approached by a third party (e.g. to revoke an exclusion there is no obligation for
husband, wife, partner, or someone with a significant the hotel to respond to the Revocation notice: self-
relationship with the customer) requesting exclusion exclusion order. The Order will automatically cease
for another person, the staff member will refer the after the 28 days, and the customer will be free to
third party to the staff member performing the role of resume playing at the hotel.
CLO. The CLO is to explain to the third party that:
If the hotel believes, on reasonable grounds, that
• an exclusion may only be put in place either by the
the customer is a problem gambler, and should
individual concerned (self-exclusion) or initiated by
remain excluded, the licensee can issue an Exclusion
the hotel (exclusion direction)
direction. This can be done at any time, however in
• the third party cannot sign, or enter into, an order to ensure that the customer continues to be
exclusion on another person’s behalf excluded, gambling providers wishing to extend
• the third party may provide support to the an exclusion should implement a venue-initiated
customer by either suggesting self-exclusion exclusion (Exclusion direction) within the 28 day
or encouraging them to see the Gambling Help period after they have received the Revocation
service. notice: self-exclusion order. The licensee may choose
to provide the customer with a copy of the hotel’s
The third party may wish to discuss the self-exclusion
Conditions of re-entry (participation in gambling
option with the customer believed to have a problem
activities) (Example 3.1D) if applicable.
with gambling and/or encourage them to make
contact with a counselling service or the hotel’s CLO In all instances, the licensee must update the
directly. Register of excluded persons (Form 3G) as required.
The CLO is to check with the third party if they wish to Revoking a venue-initiated exclusion (Exclusion direction)
be identified to the customer in any discussions with A customer who has been issued an Exclusion
the CLO. The CLO is to record the third party approach direction may, after one year from its issue submit an
and any actions/outcomes in the Gambling-related Application to revoke exclusion direction (Form 3E).
incident report (Example 2.3B). The licensee has 28 days in which to respond.
Revoking/cancelling exclusions If the hotel supports the customer’s request to revoke
exclusion and the licensee agrees that the Exclusion
A revocation is where an excluded customer
direction can be lifted, the customer is to be issued
advises the hotel in writing that they wish to end
with a Revocation notice—exclusion direction (Form
the exclusion and re-enter the hotel and resume
3F) within the 28 day period. The licensee must also
participation in gaming activities. The revocation
update the Register of excluded persons (Form 3G).
Queensland responsible gambling resource manual | Section A | Hotels 16The licensee may choose to provide the customer Active monitoring program framework
with a copy of the hotel’s Conditions of re-entry The following is a framework for managing the active
(participation in gambling activities) (Example 3.1D) if monitoring program after it has been implemented at
applicable. the venue.
If the hotel has reasonable grounds to believe It is essential that the customer gives consent to have
that the customer should not resume gambling, their gambling activities monitored under the active
the licensee does not issue a Revocation notice— monitoring program. Consent is gained using a form
exclusion direction within the 28 days and the such as the Consent to monitor my gambling activities
Exclusion direction automatically remains in place. (Example 3.1E).
However, the licensee must, as soon as practicable, Subsequent to the relevant consent being obtained
provide the customer with an Information notice— using the Consent to monitor my gambling activities
refusal to revoke an exclusion direction (Form 3J) form, it is suggested that the following will assist in
detailing why the revocation application was rejected managing the active monitoring program:
and an explanation of their appeal rights. A customer
• The CLO should ensure that all relevant staff have
may only submit one revocation application per year,
been advised that the customer is on the active
starting at the first year anniversary of the issue of
monitoring program.
the exclusion.
• The signed Consent to monitor my gambling
Appeal: Where a licensee refuses an application to activities form will be kept on the premises with a
revoke an Exclusion direction, or issues an Exclusion photograph of the customer.
direction, the customer may appeal this decision
• To enable an accurate review of activities over a
through the Queensland Civil and Administrative
period of time, daily gaming activities should be
Tribunal.
recorded in a register/log.
Details regarding rights of appeal must be provided • Procedures should be implemented to ensure
to the customer with their Information notice— the CLO is alerted when the customer is on the
exclusion direction (Form 3I) and Information notice— premises. This could be a request for the customer
refusal to revoke an exclusion direction (Form 3J) at to advise the CLO at the venue when they arrive
the time of issue. and depart the premises.
Active monitoring • Where practicable, the CLO should record and
Active monitoring is where hotel staff take special assess the visitation time/rate spent at a gambling
note of the activities and behaviour of a customer activity.
who may be at risk of problem gambling. Collecting • Depending on the gaming activity, a customer may
and writing down information and data about an be required to be reviewed as to their suitability
individual can only be done with the individual’s to remain gambling. This review may highlight a
consent. This consent may be gained either through: need for a reassessment of the exclusion provision
• approaching a customer and discussing their options with the customer.
gambling behaviour with them and requesting their • To assist in determining your decision making, refer
consent for the hotel to actively monitor them to the Possible problem gambling risk indicators in
• as a condition of re-entry following a revocation Practice 2 of this Resource manual (p. 11).
of a Self-exclusion order or an Exclusion direction
This framework is suggested to complement the
where the customer is informed that the hotel will
processes that are currently in place.
be actively monitoring them as part of the process
of approving the customer’s re‑entry to the hotel. Assessment and review
To ensure the effectiveness of exclusion practices,
An active monitoring program should be
the hotel will:
implemented by the CLO. Active monitoring should
involve, where possible, the cooperation of gambling • provide regular staff information and training on
support services, the customer and support networks exclusions
of the customer, to assist them to limit any gambling • have clear reporting procedures (staff to
behaviours which may put themselves or others at management) of incidents (observations,
risk. The Possible problem gambling risk indicators enquiries, frequency) and actions taken by the
(Example 2.4A) may assist the CLO to make a hotel with regard to customers seeking exclusion
decision based on reasonable grounds. • review procedures for exclusions on a regular basis
for currency and effectiveness purposes.
Queensland responsible gambling resource manual | Section A | Hotels 17You can also read
