The following is the feedback I submitted to REACH (the Government Feedback Unit) on the National Council On Problem Gambling’s Public Consultation on the Casino Exclusion Measures.
The consultation paper can be found here. REACH is accepting feedback until 31 January 2007, for those interested in giving their inputs.
What are your views on the draft procedures of the Voluntary Self-Exclusion? Are there any other ways to make the voluntary self-exclusion procedure simpler and more effective? How can we encourage problem gamblers to apply for self-exclusion?
It is good that NCPG will allow applications by mail or online. However, the procedures for self-exclusion should be made even simpler.
If someone makes a self-exclusion application online using his SingPass, there is no reason to have to verify it a second time by way of a phone call. If people can apply to set up a business or collect their Progress Package using their SingPass without any additional verifications, I don’t see why a simple voluntary self-exclusion from a casino needs it.
Mail-in applications accompanied by the applicant’s NRIC should also not require any phone verification. One can apply for a credit card using a photocopy of one’s NRIC, so why not a casino self-exclusion?
Informing applications that they will receive a phone call could deter some people from applying as they may not wish to have any personal contact with a “live” person about this application. The applicant may also fear — however unfounded — that the caller will be a social worker trying to help him treat his gambling problem.
Some individuals may also want to exclude themselves even if they do not have a gambling problem — perhaps for symbolic reasons. Trade & Industry Minister Lim Hng Kiang and his wife have both pledged to exclude themselves from the casino. In a Parliamentary statement on 21 Apr 05, the Minister said, “Well, in my family, my wife is dead set against gambling. So we have decided that when the time comes, both of us can send in our exclusion forms.” (The speech can be found on the Hansard at http://www.parliament.gov.sg/reports/public/hansard/section/20050421/20050421_S0004.html.)
Is NCPG really going to call up Minister Lim to personally confirm his application?
Your paper has indicated that, “These steps are taken to guard against impersonations”.
NCPG’s fears are largely unfounded. There might be rare cases of fraudulent applications, but this will by far be the exception rather than the rule, given Singapore’s strict law enforcement and punishment for impersonations. NCPG’s concerns stem from a kiasu Singapore habit of assuming the worse in people, and shaping the rules to fit the lowest common denominator. If someone had his NRIC or Singpass stolen to make a fraudulent application, he will have far worse things to worry about than being excluded from a casino.
What are your views on the draft procedures of the Family Exclusion? Under what circumstances, if any, could it be better for families/social workers to persuade the problem gambler to opt for self-exclusion instead of proceeding with family exclusion? How can we better support families going through family exclusion orders?
This option should (1) be made less onerous and (2) allow for extended family to make this application and (3) allow anonymous applications.
My reasons as follows:
(1) This option should be made less onerous
If a family (say a wife) has decided to make an exclusion application, chances are that she has assessed that her gambler husband will be unwilling to make a self-exclusion application, or has failed to convince him to do so. Therefore to go back to the gambler and persuade him to apply for a self-exclusion will be counter productive. In fact, it may heighten tensions within the family, rather than lessen it.
The gambler’s family — not NCPG or any social worker — is in the best position to assess if the gambler needs to be excluded. Their assessment of the situation which affects their own family should be taken at face value. To put in place additional roadblocks to approving the application will only deter families from applying for the exclusion.
While the idea of tying in a social worker interview and referrals to help agencies is well-intentioned, it should be noted that the objective of this procedure is to exclude problem gamblers from the casinos, not to treat gambling addictions. The latter can be dealt with through other means. To force an applicant or his family to go through “counselling” before application approval will only serve to deter genuine applications.
(2) Allow extended family to make this application
Very often, a problem gambler’s family may not be in a position to make the application, for fear of the consequences. A wife who has a problem gambler husband who comes home and beats her up in frustration after suffering gambling losses will not dare to make this application out of fear for her personal safety. Therefore the respondent’s extended family (e.g. his siblings, parents, in-laws) should be allowed to make an application as well.
(3) Allow anonymous applications
By anonymous, I do not mean that someone can make an application without providing their own name. But just like tips offs to the Corrupt Practices Investigation Bureau (CPIB) the applicants’ names do not need to be revealed to the respondent. This will be more effective if suggestion (2)
above is adopted.
In all the above three circumstances, if the person objects, he can always appeal and receive a COA hearing to confirm or dismiss the application (the same way as for the Third Party Exclusion Procedure).
What are your views on the draft procedures of the Third Party Exclusion? How can the NCPG implement the Third Party Exclusion in an effective and sensitive way?
I have no comments on this Third party Exclusion procedure, except to point out that the government appears to have reserved the right to exclude persons from the casino, while not giving that same right to members of a problem gambler’s extended family. (See point 2 above.)
What are your views on the draft procedures of the Panel of Assessors? What criteria should be used to select persons to sit on the Panel? Who should not sit on the Panel of Assessors? (Please note that we are not asking for names of persons.)
The government should be very objective in selecting appropriate persons for this panel. Since the duty of these assessors is to assess if persons merit being excluded from the casino, assessors should be those who understand the trauma that is faced by the families of problem gamblers and interact on a regular basis with dysfunctional families. For this reason, social workers, psychiatrists and religious leaders who counsel and assist broken families are the most appropriate candidates.
Professionals like corporate lawyers and company executives who have little or no interaction with dysfunctional families should not be included on the Panel just to make up the need for “diversity”.
Persons who have a vested interest in the success of the casino should not be included, as this could lead to conflicts of interest. These include people who work in the casinos or officials from the economic ministries and agencies who pushed for the establishment of the casinos.
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