Our lottery complies with the following policies:

Law and disorder policy

CNWL NHS Health Charity will refuse to be associated with any proposed lottery scheme or other gambling activity that may breach the law.
CNWL NHS Health Charity will refuse to contract with any contractors or agents who CNWL NHS Health Charity suspect may be associated with any potential or actual criminal activities.
CNWL NHS Health Charity will only use suppliers who are licensed by the Gambling Commission (External Lottery Managers), to run all or part of CNWL NHS Health Charity’s own lottery.
Our External Lottery Manager keeps a record of all lottery entries sold.
Our External Lottery Manager is able to provide information for police checks. They are able to provide address details and details of any monies sent in for tickets received.
Our External Lottery Manager operates from secure premises, and contract with reputable money transportation companies.
Our External Lottery Manager processes all entries and handles all monies received for a lottery, all monies are paid directly in to the CNWL NHS Health Charity bank account, and banking reports are issued by our External Lottery Manager on a weekly basis.
CNWL NHS Health Charity will require suppliers and contractors to ensure that all staff and contractors who are likely to be engaged with CNWL NHS Health Charity obtain relevant references.
CNWL NHS Health Charity will monitor their staff and self-employed agents on an ongoing basis, particularly regarding their direct or indirect association with potential criminal activities.
CNWL NHS Health Charity will ensure that it reports any actual or suspected criminal activities to the police.
CNWL NHS Health Charity will expect that any suppliers or consultants who are associated with their lottery/ raffle will report any potential and actual criminal activities to CNWL NHS Health Charity as soon as possible.
CNWL NHS Health Charity will expect that any suppliers or consultants who are associated with their lottery/ raffle will cooperate fully with the police and Gambling Commission should any actual or suspected criminal activities arise.
CNWL NHS Health Charity staff and volunteers involved in promoting lotteries or selling lottery tickets will be trained to a satisfactory standard to ensure compliance with CNWL NHS Health Charity gambling policy and procedures.

Fair and open draws policy

All draws are conducted at the External Lottery Manager’s premises using a random number generator.
Winning numbers associated with the lottery will be published on the CNWL NHS Health Charity website, with abbreviated details of winners. Winning numbers shall also be available by contacting CNWL NHS Health Charity’s fundraising team.
Rules are published on the CNWL NHS Health Charity Lottery website and with lottery marketing literature.
Printed versions of rules are available on request.
CNWL NHS Health Charity have a complaints procedure in place (please see below).
A record is kept of both online and offline sales.
CNWL NHS Health Charity will reserve the right to offer alternative prizes of equal value if, due to circumstances beyond its reasonable control, the stated prizes are no longer available.

Responsible gambling/ problem gambling procedure

CNWL NHS Health Charity has put in place the following procedures to encourage people to gamble responsibly and seek help should gambling become a problem:

The National Gambling Helpline number and begambleaware.co.uk website address is included on all tickets and entry forms to lotteries as well as our website address that includes information on gambling.
Information is displayed on our website encouraging people to gamble responsibly and to recognise the signs of problem gambling. We also include the National Gambling Helpline and website details for people to refer to should they need further help.
Players can request a self-exclusion to be added to the CNWL NHS Health Charity 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 the record on the CNWL NHS Health Charity database and will be in place for a minimum of six months. All reasonable steps will be taken to prevent any self-excluded individuals participating.
Self-exclusion can be requested by contacting customer services or by completing our online Self Exclusion form.
Self-exclusion flags will be added to the database within 2 working days of receipt. A record of card numbers to be excluded will also be kept where this is possible and complies with other legislation.
Staff are trained on self-exclusion and will signpost counselling and support services.
To stop receiving unaddressed mail delivered by your postman, visit the Royal Mail website.
Self-excluded customers will have any accounts closed and funds returned to them.
Where customer behaviour indicates problem gambling they will be contacted by our External Lottery Manager’s Supporter Contact Team.
A restriction of 5 lottery lines per customer will be in place unless customer interaction occurs. Interactions will be recorded and where the entries 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.
Relevant staff will be given appropriate guidance for interaction with customers demonstrating signs of agitation, distress intimidation, aggression or other behaviours that may inhibit customer interaction.

Protection of children and vulnerable people

We have taken steps to ensure that our lotteries do not attract young people. We have the following procedures in place to prevent underage players from participating in any lotteries promoted by CNWL NHS Health Charity:

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.
The minimum age for play is detailed on the back of all entry forms produced.
Any player who provides dishonest information regarding their age automatically forfeits the right to any prize. This fact is also stated on all entry forms.
Any player who is found to be under 18 years of age will have any monies paid in relation to the lottery returned to them.
Winners aged under 18 years old will receive cash prizes only. No alternative prize will be offered or provided.
In the event that a request to cease mailing lottery packs is received from a vulnerable person’s carer, we will remove their details from our mailing database immediately.
Websites carry a warning before chances are purchased stating that underage gambling is an offence. Customers are 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.
All relevant staff will be trained on the use of age verification procedures.
Website will permit filtering software to restrict the access to relevant pages.

Player queries and complaints procedure:

Complaints can be made via telephoning the Lottery Hotline on 01628 369183.
Email complaints can be sent to: cnwl.charitylottery@nhs.net
Postal complaints to CWNL NHS Health Charity Weekly Lottery, PO Box 1127, Maidenhead, Berkshire SL6 3LN
Initial complaints and queries are dealt with over the telephone by advisers in the telephone room of our External Lottery Manager (the company that manages the lottery on CWNL NHS Health Charity’s behalf).
A telephone log sheet is completed at the time of the call, detailing the caller’s CWNL NHS Health Charity details, details of the telephone adviser who took the call, the nature of the complaint and how the complaint was resolved.
The telephone log sheets will be kept on file for three years by our External Lottery Manager.
If an initial complaint can’t be resolved, the complaint is logged by our External Lottery Manager and we are notified immediately of the issue at which point it is taken internally to resolve in accordance with our policy and procedures.
In the event that a telephone or online complaint cannot be resolved by the External Lottery Manager or representatives of CWNL NHS Health Charity, third party arbitration will be provided via the Independent Betting Adjudication Service (IBAS). Independent Betting Adjudication Service, PO Box 62639, London, EC3P 3AS, 020 7347 5883, adjudication@ibas-uk.co.uk.

All general queries will be logged on the log sheets by the External Lottery Manager and held for future reference. Regarding written complaints:

Initial complaints and queries will be responded to within two days of receipt of complaint by the administration team of our External Lottery Manager.
All complaints are logged on our complaints log sheet, detailing the individual’s CWNL NHS Health Charity details, details of the administrator who has dealt with the complaint, the nature of the complaint and what steps were taken to resolve the complaint.
The complaints log sheets and written complaints will be kept on file at our External Lottery Manager for 3 years.
If the initial complaint can’t be resolved by our External Lottery Manager, the complaint is logged and forwarded immediately to CWNL NHS Health Charity staff to be resolved internally in accordance with our policy and procedures.
In the event that a written complaint cannot be resolved by the External Lottery Manager or representatives of CWNL NHS Health Charity, third party arbitration will be provided via IBAS. Independent Betting Adjudication Service, PO Box 62639, London, EC3P 3AS, 020 7347 5883, adjudication@ibas-uk.co.uk
All general queries will be logged on the log sheets by the External Lottery Manager and held for future reference.
CWNL NHS Health Charity will review all feedback and complaints on an ongoing basis so that we may address them, where possible. All lotteries will be reviewed in full at the end of each activity so any learning and issues can be reviewed and considered for future draws.