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Licensing Sub Committee minutes

Committee minutes · Licensing Sub Committee · Mon 1 Dec 2025 · Hastings Borough Council

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Decided · A decision has been taken.

A representation objecting to the application was received from an interested party, and because mediation was not possible the Sub-Committee held a hearing to determine the application. p9p10

The Sub-Committee decided to grant the application for a bingo premises licence, subject to conditions. p26p27

The conditions include opening hours of 9am to midnight, double manning at all times the premises is open, a facial recognition camera at the entrance, and a requirement that the premises be presented and advertised as bingo, with the word Bingo displayed no less prominently than references to gaming machines or slots. p27p28

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  • p9On 14 July, a planning application was submitted to change the use of the premises to an adult gaming centre; however, whilst the application had not yet been determined at the time of writing the report, it had subsequently been refused, subject to appeal. It was noted that planning and building control matters would be dealt with separately and would not form part of the consideration of the premises licence. Merkur Slots also held another premises licence for 40–41 Queens Road, which had never been opened or operated. The application process required advertising and full consultation, which had been completed. Copies of the application were served on all responsible authorities as required. Interested parties and responsible authorities were invited to make written representations to the Licensing Authority. In Part 20 of the application, the applicant outlined measures to ensure social responsibility, including staff training to protect vulnerable individuals, CCTV coverage, supervised customer areas, and a group-wide security alert system. Additional measures included an internal fraud team, national security alerts via the Betting and Gaming Council, static alarm systems supported by a nationwide security company, and a robust late-night working policy. Employees would receive six-monthly refresher training covering licensing objectives, anti-money laundering procedures, and compliance with the Proceeds of Crime Act. Age verification policies, compliance testing by independent partners, and comprehensive training programmes for managers were also detailed. No representations had been received from responsible authorities regarding the Gambling Act or associated regulations. However, a representation was received from an interested party objecting to the application.
  • p10The objection cited concerns about the applicant’s track record in protecting customers, the suitability of the business location, the number of existing gambling premises in the area, the absence of facial recognition software for ID checks, inadequacies in the local risk assessment, and high levels of crime and antisocial behaviour in central Hastings. Following public consultation, a copy of the representation had been supplied to the applicant’s agent at their request. As a representation had been received and mediation had not been possible, the Council was required to hold a hearing to determine the application pursuant to Section 162 of the Gambling Act. Members were provided with policy guidelines to assist in decision-making, as set out in Appendix D. It was confirmed that the panel would have regard to the Gambling Commission’s code of practice under Section 24 of the Act and the Commission’s guidance to local authorities, fifth edition. In addition, the panel was required to apply the principles set out in the Council’s Statement of Principles and the Gambling Act, prepared pursuant to Section 349 of the Act. Members noted that a decision to grant a licence must be in accordance with guidance, codes of practice, and policy statements. The authority was under a duty to act fairly and rationally, and any conflicts between the Commission’s codes or guidance and the Council’s policy statement must be resolved in favour of the Commission’s codes, which took precedence under Section 153. It was emphasised that the licensing authority must not consider the expected demand for gambling premises when determining an application. All determinations should be based on the individual merits of the application, with decisions being evidence-based, justified as appropriate for promoting the licensing objectives, and proportionate to what they intended to achieve. Findings on issues of fact should be made on the balance of probabilities.
  • p26Those measures were specifically designed to address issues identified in Hastings. The Applicant rejected the suggestion of lacking knowledge, expertise, or relevant controls for Hastings-specific issues. Each premises must succeed in its own environment, and the submitted material provided detailed information about the nature of the bingo offering, including pages 172 to 185 and Mr Davis’s witness statement. Reference was made to a Stockport application and conditions imposed there, as well as the Sheffield case. It was clarified that those cases were distinct, turning on their own facts and circumstances, and therefore not relevant to the current application. Conditions in those cases involved significant engagement with responsible authorities, which was not the case here. Mr Ambrose then spoke briefly about the provision of bingo. He stated that he began working in bingo in 1992, progressing through management and managing Europe’s largest bingo club with 2,500 seats in Cricklewood. He later moved to arcades and managed prize bingo operations. He highlighted the evolution of bingo over the years and noted that whilst the current offering caters to a slightly different audience, the purpose remains to provide bingo. He emphasised that bingo was no less important to the organisation than traditional bingo clubs. The Sub-Committee retired to deliberate at 13.02. The Sub-Committee reconvened at 14:17 to announce its decision to GRANT the licence, subject to conditions. DECISION In coming to our decision we have considered the Code of Practice under s24 of the Gambling Act 2005, the relevant s25 Guidance issued by the Gambling Commission, and believe this decision is reasonably consistent with the s1 licensing objectives and the s349 HBC Statement of Licensing Principles (Gambling Policy) 2023-2026 and relevant case law.
  • p27Our decision is to grant the application for a bingo premises licence subject to the following conditions:- Those conditions offered by the Applicant at page 21 and 22 to the supplementary agenda Any mandatory conditions And the following additional conditions (where these are inconsistent with those conditions offered by the applicant the following shall prevail). Opening times and manning Opening time to be 9am-Midnight Double manning as a minimum at all times the premises is open. Customer Interaction: Recording, Review and Training The premises licence holder must operate and maintain an electronic log of all premises-based customer interactions carried out pursuant to SR Code 3.4.1. Each entry must, at a minimum, record: date/time, staff member, reason/indicator(s) for the interaction, actions/tools offered (e.g. time-outs, limits, self-exclusion), outcome/decision, and any required follow-up. A shift handover note must be completed on every shift, confirming that the electronic log has been reviewed and identifying any customers requiring follow-up or enhanced monitoring on the next shift. The Premises Manager (or deputy) must review all new interaction entries within 24 hours and record any feedback/escalation. An Area/Cluster Manager must audit a sample of entries at least monthly and record their findings and any actions taken. Where the electronic system is unavailable, a paper fallback must be used and transcribed to the electronic log within 24 hours of restoration. Training: No staff member may work unsupervised until they have completed training covering SR Code 3.4.1 and the use of the interaction log; refresher training at least every 6 months. Training records must be kept for 24 months. All interaction logs, handover notes, reviews and audits must be retained for not less than 12 months and be produced to the licensing authority or police on request within 24 hours.
  • p28Facial recognition/ID - The Applicant to ensure:- (a) there is a facial recognition camera on the entrance to the premises that is capable of capturing all entrants to the premises for the purposes of identification, and that (b) all customers not previously identified by the facial recognition system should be required to provide valid identification to enable a valid check against any self-exclusion database and for the purposes of protecting vulnerable customers. Presentation compliant with HBC Policy The premises must be presented and advertised as a bingo premises. The main entrance frontage and any digital/window media visible from outside must display “Bingo” (or “Bingo played here”) no less prominently than any reference to gaming machines /“ slots” at the relevant location to the satisfaction of HBC Licensing. Priory Meadow Security Within 28 days of the licence taking effect, the licence holder must: a) nominate a member of staff as the premises’ contact for town-centre security and notify HBC Licensing and HBC BID of their details; b) ensure the nominated staff member attends relevant Priory Meadow Security meetings/briefings (or any successor scheme) and acts as the point of contact; c) when open and where operational, maintain live contact via the approved town-centre radio system or other authorised channel; d) share relevant incident summaries with HBC Licensing/HBC BID on request, in accordance with data-protection law; and e) keep records of attendance, radio participation, and information shared for 12 months, and produce them on request to HBC Licensing. Surrender Extant licence To surrender the licence to 40-41 Queens Rd prior to when the premises to this application proposes to commence trading. REASONS ASB/vulnerability - Opening times and manning conditions This is a bingo premises licence; machines are incidental.

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