As the GiveCircle Lottery is a gambling product, it is important that it is promoted in a socially responsible manner.
In this article, we will provide some guidance on how charities can promote the GiveCircle Lottery in an appropriate and responsible way.
This article does not constitute legal advice and is provided for general information purposes only to assist GiveCircle's partner charities with their advertising compliance.
We give no warranty as to this guide’s fitness for purpose, accuracy or completeness. If you require any specific advice regarding any matter covered in this guide, you are encouraged to seek independent legal advice.
Table of Contents
- What gambling rules and regulations need to be followed when promoting the GiveCircle Lottery?
- What other rules and regulations need to be followed when promoting the GiveCircle Lottery?
- Engagement of third parties to promote the GiveCircle Lottery
What gambling rules and regulations need to be followed when promoting the GiveCircle Lottery?
It is important that any promotion of your lottery is done in a socially responsible way. You should be mindful of legal requirements and industry best practice. The most important sources relating to responsible gambling advertising include:
- For operators licensed by the Gambling Commission, the Licence Conditions and Codes of Practice (the LCCP);
- The UK Code of Non-broadcast Advertising and Direct & Promotional Marketing (the CAP Code);
- The UK Code of Broadcast Advertising (the BCAP Code);
- The Gambling Industry Code for Socially Responsible Advertising (the Gambling Industry Code).
The Social Responsibility Code contained within the LCCP states that licensed operators must comply with the CAP Code and the BCAP Code.
The Ordinary Code contained within the LCCP states that licensed operators should follow the Gambling Industry Code. Although the Ordinary Code does not have the status of licence conditions, it helps operators demonstrate best practice in the exercise of their licensed functions.
Age restrictions and the protection of minors
The minimum age to enter the GiveCircle Lottery is 18.
All marketing activities should be conducted in a way that minimises the risk of under 18s attempting to purchase lottery tickets.
Whenever promoting a lottery, licensed operators should be mindful of the below requirements in relation to the protection of minors:
| Do | Don't |
| Include an ‘18+’ symbol or a ‘no under 18s’ type message in all digital and print marketing materials. | Advertise your lottery in a manner that would make it of strong appeal to children or young persons, especially by reflecting or being associated with youth culture. |
| Include an ‘18+’ symbol or a ‘no under 18s’ type message on your social media page (and, where practicable, posts on that page) that is primarily focused on promoting your lottery. |
Include a person or character in marketing materials whose example is likely to be followed by those under 18 years or who has a strong appeal to those aged under 18 (for example, a celebrity or social media influencer who has a strong following amongst children and young people). There is an exception to this if:
|
| If conducting sponsored/paid-for social media advertising, ensure that such ads are targeted at consumers aged 25+ (or 18+ in respect of Facebook and Snapchat). | Feature anyone who is, or seems to be, under 25 years old participating in gambling in any marketing communications relating to your lottery. |
| If conducting any lottery promotion on YouTube, ensure that your channel is age-restricted to 18+ which requires users to log in to age-verified accounts to view content. | Direct marketing communications to those aged under 18, such as by selecting media distribution which has a strong appeal to children and young people. |
| If conducting radio or other broadcast advertising, include a brief 18+ message. | Exploit the susceptibilities, aspirations, credulity, inexperience or lack of knowledge of children, young persons or other vulnerable persons. |
Responsible gambling
Lotteries are considered gambling products and therefore operators should ensure that all advertising is socially responsible. This may include, for instance, regular reminders to ‘play responsibly’ and the signposting of organisations that assist problem gamblers, such as BeGambleAware.org.
As a minimum, GiveCircle ensures that all marketing materials that it provides include the BeGambleAware logo.
You can download the BeGambleAware logo on the following links: https://www.begambleaware.org/download-logos
https://www.begambleaware.org/for-professionals/using-gambleaware-logo
Whenever promoting a lottery, licensed operators should be mindful of the below requirements in relation to responsible gambling:
| Do | Don't |
| Include the BeGambleAware logo and/or a ‘play responsibly’ type message in all digital and print marketing materials. | Portray, condone or encourage gambling behaviour that is socially irresponsible or could lead to financial, social or emotional harm. |
| Include the BeGambleAware logo and/or a ‘play responsibly’ type message on your social media page (and, where practicable, posts on that page) that is primarily focused on promoting your lottery. | Suggest that participating in a lottery can provide an escape from personal, professional or educational problems such as loneliness or depression. |
| If conducting radio or other broadcast advertising, include a brief safer gambling message such as ‘play responsibly, BeGambleAware’. | Suggest that participating in a lottery can be a solution to financial concerns, an alternative to employment or a way to achieve financial security (however, you may refer to other benefits of winning a prize). |
| Portray participating in a lottery as indispensable or as taking priority in life; for example, over family, friends or professional or educational commitments. | |
| Suggest peer pressure to participate nor disparage abstention. | |
| Suggest that participating in a lottery can enhance personal qualities, for example, that it can improve self-image or self-esteem, or is a way to gain control, superiority, recognition or admiration. | |
| Link participating in a lottery to seduction, sexual success or enhanced attractiveness. | |
| Portray participation in a lottery in a context of toughness or link it to resilience or recklessness. | |
| Suggest participation in a lottery is a rite of passage. | |
| Suggest that solitary gambling is preferable to social gambling. | |
| Exploit cultural beliefs or traditions about gambling or luck. | |
| Condone or encourage criminal or antisocial behaviour. | |
| Condone or feature gambling in a working environment (an exception exists for workplace lottery syndicates and gambling premises). |
Restrictions by location
Lotteries can only be entered by individuals living in Great Britain only. You should avoid promoting the lottery to other geographic locations and should include a notice that "the lottery is for residents of Great Britain only".
For the avoidance of doubt, individuals living in other countries including Northern Ireland are not eligible to play the lottery.
Branded lottery
The GiveCircle Lottery is a branded lottery. This means that multiple charities use the GiveCircle Lottery to raise funds for their cause.
This should be made clear to supporters when they enter the lottery.
You may wish to use a statement such as "Charity Name Lottery is part of the GiveCircle Lottery" or "Play the GiveCircle Lottery on behalf of Charity Name" in any marketing.
What other rules and regulations need to be followed when promoting the GiveCircle Lottery?
In addition to the above requirements in relation to the protection of minors and responsible gambling, operators should also comply with general advertising requirements.
Guidance is available from the UK government here.
- Ensuring that marketing communications and advertisements do not amount to or involve misleading actions or misleading omissions.
- Ensuring that any significant terms and conditions which apply to marketing incentives are provided transparently and prominently to consumers.
- Ensuring that consumers are not sent direct electronic marketing communications (for example, email or SMS) unless the recipients have positively opted-in to receiving such communications, and that all recipients are given the opportunity to easily optout with each communication.
These general marketing principles, are also key requirements referenced in the LCCP.
General advertising requirements are also contained within the CAP Code (for nonbroadcast advertising) and the BCAP Code (for broadcast advertising). Lottery operators should maintain a strong awareness of these advertising codes whenever conducting marketing activities.
Regulations relating to payment methods
The GiveCircle Lottery allows supporters to pay via their mobile phone. In order to comply with regulations relating to this payment method, any marketing of the lottery must explicitly mention that each ticket costs £2 per week.
Engagement of third parties to promote the GiveCircle Lottery
Lottery operators licensed by the Gambling Commission are responsible for the actions of third parties who they engage to provide marketing or advertising services relating to their lottery. You should refer to the LCCP for more information in respect of contracting requirements with third parties.
We request that no third party operators are engaged to promote the GiveCircle Lottery without our prior knowledge and consent. We will assist you in ensuring that any third party has the knowledge and skills to carry out marketing to the required standard.
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