The Gambling Commission define an ELM as: An External Lottery Manager (ELM) is a person that makes arrangements for a lottery on behalf of a society or authority of which he is not (a) a member, (b) an officer, or (c) employee under a contract of employment. [GA2005, s257] Don’t you just love legalese!
For further clarification they have said:
“If their only role is to post tickets to people to participate in the lottery from a list provided by the society or ELM, the Commission does not think they are doing any of the things that fall into the definition above of promoting a lottery. However, where a person or body is responsible for and manages part or all of the lottery and decides issues such as where to target promotional material, sources people to enter the lottery and deals with ticket transactions, they are carrying out functions that are caught by the definition of promoting a lottery and require a licence.”
“Where the person or body making any of the arrangements for a society or local authority lottery, for example, has control of how the lottery is promoted and managed, the Commission’s view is that they will be acting as an ELM and will need to hold the relevant operating licence issued by the Commission if they are to avoid committing an offence under the Act.” [Source Woods Whur during Woods Valldata Gambling Commission Roadshow, January 2023]
The crux of it is that an ELM helps you run your lottery. You appoint them to help you run all or part of your lottery. They can help you promote the lottery, process entries, do the draws on your behalf and help make sure that everything is as it should be.
You can manage everything in house (some charities do – but not many). However, working with an ELM gives you that added level of security – a partner to share the load if you like. Plus – as they’re likely dealing with multiple prize-led programmes they will be more up-to-speed with requirements and best practice.
ELMs are bound to the Gambling Commission Licence Conditions and Codes of Practice (LCCP) and need to comply in much the same way as your charity will need to comply.
In fact, it’s worth remembering that your responsible persons (personal management licence (PML) holders) are still ultimately responsible for what happens in your prize-led programme. Be aware that not all companies who are registered as ELMs will take their responsibilities as seriously as others. It’s important when you’re looking for support with your weekly lottery or raffle programmes that you do your due diligence and find the right fit for your charity.
Your ELM will be managing data on your behalf. Make sure that they’re as secure in dealing with your player’s details as possible.
Do they have all relevant systems and processes in place to deal with prize-led fundraising?
Make sure that they know what to do if they encounter someone wanting to play a lottery who may be vulnerable including those under 18 and those who may wish to self-exclude (i.e. a problem gambler).
Make sure they know how to manage a fair and open draw according to remote and non-remote requirements.
Do they know their 80/20 rule, ticket requirements and remote technical standards?
Can they help lead you through what you need to do for GC compliance?
Can they support you across multiple elements of the programme such as printing, mailing, data selections, player websites, response handling, thanking, supporter services, banking, draw management?
Woods Valldata are proud to be an ELM for over 60 UK charities, many have been with us for over 15 years. For us, being an ELM is definitely about making sure we adhere to the current Gambling Commission Licensing Conditions and Codes of Practice (and other high standards of compliance!) and support our charity partners in their compliance of it too.
But being an ELM is also about being a partner with charities looking to develop and grow their prize-led fundraising programmes. We’re in it with you; sharing knowledge and expertise, making proactive recommendations and thinking strategically about your programme so you can achieve your prize-led fundraising ambitions.
We’d love to chat with you about our suite of weekly lottery products – each one designed with specific needs in mind, so you’re sure to find your perfect fit. Contact us to arrange a meeting or demo today.
Why not come along to our open day? We’d love to meet you and show you behind the scenes at Woods Valldata so you can see for yourself why we’d make your ideal ELM.
Any terms that are unfamiliar to you? Check out our Glossary for some short and sweet explanations.