Organising incentive prize draw for a closed community - is it legal?

(Robert McIntosh) #1

Has anyone looked into the law regarding lotteries and prize draws when it comes to incentivising activity within a closed community?

Background: I want to encourage members to add personalisation to their profiles - photos, bios, links. This is not a data collection exercise, or to gain new members, it is to add vibrancy to the community.

I was thinking of doing a random draw to reward one or more members for having added this data (so, picking a member at random from the full list of those with a profile image for example).

There is no cost to take part, and there is no skill required beyond knowing how to add your photo.

If this was a community that ANYONE could join, then I believe it would count as a free prize draw and therefore be exempt from UK lottery / gambling regulations, BUT …

This is intended for a community associated with a membership organisation, and the community membership is exclusive to those members. There is no cost for members to join the community either, but they do have to pay a fee to become a member of the society.

In other words, if a random member of the public decided they wanted to take part in the competition (for around £10 worth of wine, so not massive), they would, in theory, have to pay the £40 membership dues before they could.

Does this count as a “fee to participate” or is the fact that the community and the competition itself are completely free exempt this draw from the regulations?

Has anyone any experience of such a scheme?