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Guidance on Lotteries and Raffles
This is a reminder to Lions Clubs regarding Easter Egg Raffles – The Gambling Act, The Charities Act, and GDPR Requirements.
As many Lions Clubs are running online Easter Egg Raffles, online Duck Races, and other seasonal fundraising activities of various kinds over the next few weeks, (and are also contemplating other gambling type activities at events over the coming months as hopefully, lockdown provisions ease in each of the devolved Government areas), the very brief and non-exhaustive summary below provides a reminder to Lions Clubs of their obligations under the Gambling Act regarding the need to register for “small lottery “licenses, the display of the Club’s Charity number and details of the “promoter” for lotteries and raffles, and of GDPR considerations.
(A fuller and more detailed document relating to this subject has been prepared for Lions Clubs by the MD Compliance Team and is available below. Lions Clubs are recommended to read it if they are running an event to which that advice may apply. It is recognised that Lions Clubs are autonomous and are free to make their own decisions as to how they use the advice offered.)
- Lions Clubs are reminded that Raffles, Duck Races, Tombolas, and other similar activities, including Easter Egg and Treasure Island “square board” number sales, are regarded by the Gambling Commission as being lotteries requiring “small lotteries” registration and may require the purchase of a license from their local authority, with the completion of a return to the local authority of the outturn; unless the activity takes place on one day as a self-contained event – (such as at a summer fete or during dinner).
- A “small lottery” is considered by the Gambling Commission to be an activity raising less than £20,000 in a year, where entry is offered for payment of the same set cost per entry for an equal and random chance to win an offered prize unless, as mentioned above, the “lottery” takes place at a “self-contained single-day event”. This will mean that selling entries over a period for prizes will need to be registered as a small lottery with local authority licensing departments, and an annual license also covering this and similar events may need to be purchased.
- VERY IMPORTANT – The Gambling Commission also reminds us that we should take care not to sell entry in the “lottery” to under 16’s and other vulnerable persons.
- Materials relating to Raffles, tombolas, and other “small lotteries “ are required to clearly display the Lions Club Charity’s number and the details of the designated promoter.
- Money handling – Debit Card only payments rather than Credit Card payments are required for online raffles to comply with the Gambling Act, and if Lions Clubs are using ‘GoFundMe’ Clubs should be aware that Gift Aid is unlikely to be available.
- From a GDPR position, it is considered that by choosing to participate in the activity, by purchasing an entry ticket and/or board square or a virtual duck or similar, and supplying their contact details for the raffle or lottery, etc participants are freely giving GDPR consent regarding that personal information. It is suggested that all materials should include the notice: “All information provided herein will be processed in accordance with UK Data Protection legislation. All feasible security measures are in place”. However, there is an obligation to take reasonable actions to safeguard the privacy of participants and in publishing the details of the winners of the lottery.
PCC Lion Heather Jeavons
MD 105 Compliance Officer
Date: March 2021