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TRANSCRIPT
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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.