The Self-Exclusion That Wasn't Enforced
A registered club in regional NSW has a self-exclusion register maintained at the reception desk. A patron, Denise, signed a self-exclusion deed six months ago for twelve months. On a busy Saturday, she enters through a side door used by staff and is served by a bar attendant who does not check the register. She plays for two hours before a gaming supervisor recognises her. The club's RCG policy says all staff must check the register before serving gaming patrons and that self-excluded patrons must be removed immediately. The supervisor is unsure whether to remove her, given she is already mid-session and appears calm. The club also has not conducted refresher RCG training for eighteen months.
1. Was the club's handling of Denise's self-exclusion compliant? Explain the obligations and the failures.
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No. A self-exclusion is a binding arrangement that the venue must actively enforce. Failures include:
- Entry control - the side door allowed entry without a register check; the venue must control all entry points to the gaming area or ensure staff challenge unknown entrants.
- Service check - the bar attendant served her without checking the register, breaching the venue's own policy and the RCG requirement to identify self-excluded patrons.
- Delayed response - once recognised, the supervisor should act immediately, not weigh whether she 'seems calm'. Calmness is irrelevant to the exclusion.
- Training gap - eighteen months without refresher training is inconsistent with maintaining RCG competency.
The correct action on recognition is to approach discreetly, remind her of the deed, escort her from the gaming area, and record the incident. The venue should also review entry controls and schedule training.
2. What should the supervisor do in the next ten minutes, and what follow-up should the club undertake?
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Immediate actions (next ten minutes):
- Approach Denise privately and calmly, confirm her identity, and remind her of the self-exclusion.
- Escort her out of the gaming area without public confrontation.
- Do not process any further gaming transactions.
- Record the time, location, staff involved, and duration of play.
- Offer information about Gambling Help NSW and counselling services.
Follow-up:
- Report the breach to the duty manager and, if required by the venue's policy or regulator, document it formally.
- Review why the side door was unmonitored and fix access control.
- Reinstate register checks at all entry points and at service.
- Schedule RCG refresher training for all gaming and bar staff.
- Consider whether the incident triggers notification obligations to the regulator under the venue's compliance framework.
The judgement being tested is that enforcement is immediate and procedural, not discretionary based on the patron's demeanour.