Gambling policy Part B

The Council acknowledges that CSE awareness doesn’t just apply to children on licensed premises, particularly as children are not permitted access to most gambling premises. Applicants should be equally aware of children in the proximity of the premises that may be waiting for, or seeking, older persons.

Applicants are encouraged to ensure that suitable management controls are in place to safeguard children against the risk of CSE. Measures may include, but are not limited to:

• awareness training for staff;
• regular patrols of the premises, including external areas and the immediate proximity, to identify any vulnerable children;
• close monitoring of patrons as they leave the premises;
• recording and reporting concerns to the police.

The Council expects applicants to be aware of ‘risk indicators’ of CSE which include, but are not limited to:

• developing relationships between a child and an older person
• children in the company of a group of older persons
• children regularly attending premises and meeting with a number of different older persons, particularly where older persons may be facilitating gambling for children
• children outside of licensed premises developing relationships with an older person, particularly an older person facilitating gambling for children
• children leaving the locality of the premises with older persons, particularly with a group of older persons 
• children looking uncomfortable in the company of, or leaving with, older persons particularly groups of older persons

Whilst the Council does not wish to create the impression that all contact between children and older persons is inappropriate, it is strongly of the view that licence holders should be aware of the risks of CSE and should proactively manage their premises to minimise the risks.

The Hertfordshire Safeguarding Children Board (HSCB) have dual role in respect of preventing CSE within licensed premises. The HSCB is a responsible authority under the Act having been nominated by the Council to undertake this function. The HSCB also monitor compliance with the statutory requirements under section 11 of the Children Act 2004 to safeguard and promote the welfare of children. Applicants are encouraged to visit the HSCB website for advice www.hertssafeguarding.org.uk

The Council expects applicants to demonstrate the measures they will take to safeguard against CSE in the operating schedule.