Raffle policy

Background

CAFOD is licensed by the Gambling Commission to run a Society Lottery. The Gambling Commission is the body set up to monitor all gambling activity in the UK. The legal framework under which CAFOD’s raffle operates is The Gambling Act 2005.

The Gambling Act 2005 has three main objectives:

Prevent gambling from being a source of crime or disorder, being associated with crime or disorder or being used to support crime.
Ensuring that gambling is being conducted in a fair and open way.
Protecting children and other vulnerable persons from being harmed or exploited by gambling.

While charity raffles present an extremely low risk they do however fall under the Gambling Act 2005 and CAFOD takes all reasonable steps to ensure compliance. Set out below is the policy to be followed by CAFOD and the External Lottery Manager (ELM) working on our behalf.

Law and disorder

CAFOD conducts its remote and non-remote raffles through Woods Valldata. – a registered ELM licensed by the Gambling Commission.
Woods Valldata operate an online platform which complies with all relevant codes and remote technical standards.
The ELM (Woods Valldata) keeps a record of all tickets that have been distributed.
The ELM (Woods Valldata) operates the online payment function and are responsible for the payment of income back to the charity. Ticket and chance distribution records are available for police checks.
Banking reports are issued by the ELM (Woods Valldata) to an agreed schedule. They will provide contact and payment details of monies received.
Data is stored by the ELM (Woods Valldata) in a ring-fenced account. This is transferred to CAFOD on an agreed regular basis. Data is transferred in a secure manner that requires two-factor authentication.
Non-remote raffle returns are processed by CAFOD operating in a secure premises and according to a secure procedure set out in the work package.
To minimise the risk of fraud, there is a restriction of 60 tickets per customer in place unless customer interaction occurs. Without customer interaction chances will not be entered into the draw. Interactions will be recorded and where the tickets are purchases beyond the limit, records will be kept for 3 years.

Fair and open draws

Draws are conducted in a fair and open way to ensure all remote and non-remote entries have an equal chance of winning.
Draws are conducted using a random number generator that has been approved by the Gambling Commission, or by blind draw on CAFOD premises in plain site of at least two staff members.
The winning ticket numbers are published on CAFOD’s website following the draw. This information is also available on request.
Winners are notified in writing within two weeks.
Rules are published on CAFOD’s website.
We have a complaints procedure in place (see below).

Queries and complaints

Telephone complaints

Any queries and complaints regarding the lottery should be made to CAFOD, or directly to the ELM (Woods Valldata).
Following standard procedure, a log sheet will be completed detailing the caller’s and advisor’s contact details, the nature of the complaint and steps taken to resolve the complaint.
The steps taken to resolve the complaint, and the outcome, are also recorded for future reference.
In the event that a telephone or online complaint cannot be resolved by the ELM (Woods Valldata) or representatives of CAFOD, Woods Valldata will provide free third party arbitration via IBAS.

Written complaints

Any queries and complaints regarding the lottery should be made to CAFOD, or directly to the ELM (Woods Valldata). CAFOD, as well as the ELM (Woods Valldata) will respond to complaints and queries within 48 hours of receiving the complaint.
The subsequent logging and resolution procedure is that of telephone complaints.
The steps taken to resolve the complaint, and the outcome, are also recorded for future reference.
In the event that a written complaint cannot be resolved by the ELM (Woods Valldata) or representatives of CAFOD, Woods Valldata will provide free third party arbitration via IBAS.

Responsible gambling

The following procedures have been put in place to encourage people to gamble responsibly and seek help should gambling become a problem:

The raffle website carries information encouraging people to gamble responsibly, and recognise the signs of problem gambling. The National Gambling Helpline and begambleaware.org website details are also included for people to refer to should they need further help.
The National Gambling Helpline number and GambleAware website address is included on all tickets and entry forms as well as our website address that includes information on gambling.
The National Gambling Helpline number and GambleAware website address is included in any paid promotion.
Players can request a self-exclusion to be added to the CAFOD database so that they are removed from further addressed lottery communications including post, telephone, email and SMS. All self-exclusion requests along with the date of the request will be captured on to the record on the CAFOD database and will be in place for a minimum of six months. Self-exclusion cannot be reversed within that period. All reasonable steps will be taken to prevent any self excluded individuals participating.
To stop receiving unaddressed mail delivered by your postman, visit the Royal Mail website.
Staff are trained on self exclusion and will signpost counselling and support services.
A restriction of 60 tickets per customer will be in place unless customer interaction occurs. Without customer interaction chances will not be entered in to the draw. Interactions will be recorded and where the tickets are purchased beyond the limit, records will be kept for 3 years.
All relevant sources of information will be used to identify customers at risk of problem gambling.
Lotteries are only conducted with an External Lottery Manager (Woods Valldata) who is registered with the Gambling Commission (licence number 003586-N-103664-013).

Gambling responsibly and problem gamblers

The majority of people do gamble responsibly. For some, however, gambling can become a problem. If you are concerned about the amount you are gambling (or you are concerned for a friend or relative) then the following questions may help give you some guidance.

Have you lied to cover up the amount you have gambled or the time you have spent doing it?
Do arguments, frustrations or disappointments make you want to gamble?
Do you gamble alone for long periods?
Do you stay away from work or college to gamble?
Do you gamble to escape from a boring or unhappy life?
Are you reluctant to spend 'gambling money' on anything else?
Have you lost interest in your family, friends or pastimes due to gambling?
After losing, do you feel you must try to win back your losses as soon as possible?
When gambling and you run out of money, do you feel lost and in despair, and need to gamble again as soon as possible?
Do you gamble until your last penny is gone?
Have you lied, stolen or borrowed just to get money to gamble or to pay gambling debts?
Do you feel depressed or even suicidal because of your gambling?

If you are answering 'yes' to some of these questions, then it is likely that a gambling problem exists. For friendly and helpful advice from trained counsellors call the National Gambling Helpline on 0808 8020 133. The helpline operates 24 hours a day, 7 days a week, 365 days a year. You can also visit the GambleAware website begambleaware.org for more information and advice.

Sometimes just telling someone about your problem can be a relief and it is the first step towards dealing with your problem.

Protection of children and the vulnerable

We have taken steps to ensure that our raffles do not attract young people. We have the following procedures in place to prevent under-age players from participating in any raffles promoted by CAFOD:

Where possible we check our database to ensure persons are above the legal age limit before data is supplied for the use of a lottery.
Chances may only be purchased once the player has self-certified that they are over the required age to play.
Any player who provides dishonest information regarding their age automatically forfeits the right to any prize.
Any player that is found to be under the required age to play will have any monies paid in relation to the lottery returned to them.
If in doubt, Age Verification software will be used to ascertain the age of the entrant.
Any portals for remote customers will carry a warning before chances are purchased stating that underage gambling is an offence. Customers will then be required to confirm they are of legal age.
The age verification system will be reviewed regularly and we will implement all reasonable improvements that may be made as technology advances and information improves.
The website will permit filtering software to restrict the access to relevant pages.

Age Verification Policy

Players must be over the age of 18 to purchase chances.
Players will not be able to proceed to the payment page until they have self-certified that they are over the required age to play.
If there is any doubt as to the age of a self-certified player we will use Age Verification software to seek confirmation. For any records which are not matched, we use a secondary stage service where records are run against the electoral role. If this proves unsuccessful, where possible we will try to contact the player by telephone.
Once payments have been successfully processed, a confirmation email is sent to entrants confirming their playing status. This email includes a self-certification statement confirming the entrant is over the required age to play.
Where data is bought in from a cold list provider, CAFOD requests that the provider screens cold data to exclude all persons under 18 years of age before supplying the data to CAFOD.
When data is extracted from the database for use in a raffle mailing, all individuals found to be under 18 years of age are excluded.
The minimum age for play is detailed on the back of all tickets.
If we are unable to verify the age of a player the payment will be returned to the entrant.
Any player who provides dishonest information regarding their age automatically forfeits the right to any prize.
Any player who is found to be under the required age to play will have any monies paid in relation to the lottery returned to them.
Any player who is found to be under 18 years of age will forfeit their right to any prize and have their entry money returned to them.
In the event that a request to cease mailing raffle packs is received from a vulnerable person’s carer, we suppress them from raffle mailings immediately. If the person has been sent a raffle pack as a result of their details being supplied to us through a cold list, we will advise the carer of how to have that person’s details removed from the list owner’s mailing records too.

Records

CAFOD maintains electronic records of the following for a minimum of three years:

Full name and address of all people sent raffle tickets.
The quantity of tickets sent to each person.
The date tickets were dispatched.
The quantity of sold and unsold tickets.
A full banking history of each sold ticket.
A record of when sold tickets were received.
The method of payment for each sold ticket.
A record of all winning ticket numbers.
A record of all winners.
The date of the draw.
The total proceeds of the raffle.
The amount and percentage deducted for prizes, and any prizes from rollovers.
The amount and percentage deducted for costs incurred in organising the raffle.
The amount and percentage applied directly for charitable purposes.
The last CAFOD e-mail, advertisement or page on the CAFOD website you clicked before arriving at our raffle website

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