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Challenge 25 Training 

Introduction 

Every year thousands of children are taken to hospital because of drink related illness or injury, solvent abuse or incidents involving knives or fireworks.

When it comes to alcohol, young people are drinking more, and drinking more often. Recent statistics show that 19% of 10 -15 year old's drink at least once a week.

Laws which restrict the sale of certain products aim to safeguard the health of young people and are not, as some might think, just to make life difficult for retailers and licensees.

As a retailer of age-restricted products you have a responsibility to your community and to protect children from harm. 

The Challenge 25 policy ensures that only people who can prove they are old enough can buy alcohol, tobacco, solvents, fireworks, lottery tickets, DVD's and computer games. 

Challenge 25 exists not only to protect children, but also the communities you serve and to protect yourself from possible prosecution. 

If you make an underage sale you could end up in court, possibly facing an unlimited fine or even imprisonment. Of course that's bad for you and for your employer too, but what if your sale also resulted in a young person's death? Think how much worse you would feel, not to mention the devastation to the parents and family who have lost someone forever. 

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It is very important to read through this training pack and ensure that you fully understand the law and the Challenge 25 policy. Complete the Quiz at the end and submit your answers so that your employer knows that you have read all of the information. If you don't use Challenge 25 you risk making an underage sale and breaking the law. 

The purpose of this training is to: 

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  • Clarify the legislation relating to age-restricted products and explain what can happen to a retailer who breaks the law

  • Provide training materials that, if used appropriately, will help safeguard you from the pitfalls of selling products to people who are too young to buy them

  • Provide information that will help you to establish the age of a potential customer. It offers guidance on the best practice for dealing with those customers who may become aggressive or abusive when they are refused a sale

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This training contains all the information that you need to avoid illegally selling age-restricted products. Furthermore, not only does this pack clarify the legislation, it also explains why it is necessary to restrict the sale of these products by describing some of the effects that they can have on the health and wellbeing of younger people. The advice in the pack is given freely and without liability. It will be reviewed if the law or other circumstances change and updated versions of this training will be issued as appropriate. 

Social Responsibility

As someone working for a company involved in the sale of alcohol it is important that you are aware of your 'social responsibility' in relation to alcohol, the term is generally used to define the actions taken to sell alcohol in a way that promotes sensible consumption and in no way promotes alcohol misuse. This is important because alcohol, whilst perfectly compatible with a healthy lifestyle when consumed in moderation, can have serious negative consequences on both health and society if consumed irresponsibly 

Anti-social behaviour is a collective term for offences such as vandalism, noise nuisance littering, physical and verbal abuse and intimidation. Communities affected by anti-social behaviour suffer, in particular the more vulnerable members of society and the elderly. One of the main aims of Challenge 25 is to reduce instances of anti-social behaviour across the County. By minimising sales of age-restricted products, such as alcohol to young people, instances of anti-social behaviour in local communities is reduced. 

Retail staff are the front line of enforcement and therefore it is your responsibility to ensure that under 18's and drunken people cannot acquire alcohol on your premises. We advise maintaining a 'Refusals Register' (see Part 5) to record any instances where a member of staff has declined a sale and why. 

It is up to the store's Designated Premises Supervisor (DPS) to ensure that all staff are adequately trained to deal with alcohol sales and understand the law regarding all age- restricted products. 

This training pack helps you to do this, along with the point of sale materials provided. Following the principles of the Challenge 25 policy will help to further reduce any margin of error. 

Underage sales laws are not there to punish sellers who make an honest mistake or an occasional lapse - but unless you are normally diligent and take precautions, you might find it difficult to show that one mistaken sale isn't one of many. 

What are the consequences?

Challenge 25 Training Pack consequences for: Failing to act responsibly with ALL age -restricted products can have serious consequences for:

1) You, the seller - 

  • You could be interviewed by the Police and possibly taken into custody, fingerprinted, photographed or have to give a DNA sample

  • You could receive an £90 on-the-spot fine (known as a Penalty Notice for Disorder or PND) that YOU would be liable to pay - can you afford this?

  • Your breach of the law will be recorded in your work file, your employment could be terminated and future employment could be jeopardised

  • ​​​You could face court proceedings, with a possible fine of up to £10,000

 

2) The shop 

  • A sale from your shop could result in bad publicity and a poor reputation

  • A shop's licence to sell alcohol could be suspended or revoked meaning a loss of sales, inconvenience to customers and possible long terms effects such as loss of jobs or store closure

 

3) The Community

  • Young people having access to age-restricted products may contribute to behaviour that damages the health and wellbeing of the community and its younger members

  • Drain on local health services

  • You could be contributing to the sort of anti-social behaviour that often results from the misuse of some age-restricted products

  • Crimes fuelled by alcohol

  • Knife attacks

Think about all the products you sell in your store and the consequences of selling these to someone underage.

What the law says

Alcohol

The law

The Licensing Act 2003.

Where alcohol is sold to an underage person, the person who sold the alcohol is responsible in law. Depending on the circumstances, a personal licence holder who authorised the sale, the Designated Premises Supervisor (DPS) and the premises licence holder may also be responsible in law and may be prosecuted.

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The products

Spirits, wine, ale, beer, cider, alcopops and any other alcoholic liquor.

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The offences

  • Selling alcohol to anyone under 18

  • Selling liqueur chocolates to anyone under 16

  • Selling alcohol if you are under 18 without the licensee or other responsible person over 18 knowing about the sale

  • Selling alcohol if there is no licence to do so

  • Failing to display the summary licence

  • It is an offence for anyone under 18 to purchase or attempt to purchase alcohol

  • Persistently selling alcohol to young people (two or more occasions in a period of three consecutive months)

How to prevent underage sales
Most people find it difficult to judge the age of a young person, particularly customers that are in their late teens. Furthermore young people can often look older than they really are. Whether or not someone appears to be over 18 is subjective and will depend on who is making the decision. The best way to prevent underage sales is to not try to guess their age but to ask for a valid form of photo ID.
 

By operating the Challenge 25 policy the risk of error is significantly reduced because anyone who looks under 25 can be challenged to prove that they are, in fact, the age required to purchase the item they want.

The informative notices displayed in the store help customers understand that a Challenge 25 policy is operated in the store and that it is there for staff to avoid making underage sales and prevent them from breaking the law.

Customer notices on the premises can be used to make customers aware of what they can legally purchase and to alert them to the fact that a sale is likely to be refused unless they can produce proof of age. If applicable, till prompts may also remind you that the item is age-restricted and that you can use the Challenge 25 policy.

Remember that you have the full support of your store manager as well as Trading Standards in implementing the Challenge 25 policy.

Steps you can take to avoid committing an offence
Before the customer approaches the till point:

  • Keep an eye on the people in the store and/or queue- who do you think looks under 25? By being aware of the customers around you, you will be assessing their age before they come to the till and are therefore more ready to ask for ID

  • If there are young people looking at or selecting alcohol in the aisle you can always give them a friendly forewarning that they will need to show ID at the till. This may stop young people under 18 attempting to buy in the first place

 

When the customer is at the till point:

  • If you are under 18 yourself, you cannot sell alcohol without being authorised to do so and supervised make sure you know who your supervisor is whenever you are at work. If you are unable to have the sale supervised and make the sale anyway you will be committing an offence

  • As the customer places the item on the counter, pull it towards you. This will give you ownership of the item while you are deciding whether to serve the customer or not

  • Take a good look at the customer and unless it is beyond reasonable doubt that a customer is the required age you must take reasonable steps to check the customer's age. Never assume the age of the young person. Remember that just because someone is tall, wearing smart clothes etc it doesn't necessarily mean they are older -look closely at their face

  • Do not fail to ask for proof of age simply because you think you might cause offence- remember that if you sell to someone under the required age you will be breaking the law

  • Remember that the young person at your till could be a volunteer carrying out a test purchase on behalf of the Council

  • Never ask a person's age, always just ask for ID to prove they are over the required age. This will avoid a confrontation if they tell you they are 18 and then you go on to ask for ID

  • Avoid starting your sentence by saying "I'm sorry....but I need to ask you for ID" this makes it sound as if you shouldn't really be asking. Instead be confident and polite. You are only doing your job by asking for ID and if this cannot be provided then you are within your rights to refuse the sale. Explain the policy if necessary with the support of the point of sale materials provided

  • ​Ask for proof of age and only accept a passport, photo driving licence or a PASS accredited proof of age card 

  • Even if you have seen a young person's ID before be consistent and ask to see ID every time - this is because:

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A) The young person should be prepared to show their ID every time, as it may not be the same person that serves them each time. If they wanted to make a purchase and didn't have their ID they may get refused by someone else

 

B) You don't know who is in the store witnessing the sale. If someone thinks you are making an underage sale they may report you to Trading Standards who will investigate the complaint. Or it may even be observed by a Trading Standards Officer!

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C) If you don't ask one young person for their ID and make a sale, yet you ask another young person in the queue behind them and refuse their sale, you could be facing a conflict- "Why ask me and not them?", "How come they got away with it and you're not serving me?"

 

  • If the young person at your till attempting to buy an age-restricted product is accompanied by a few other young people you should check the ID of the entire group. You may think this seems excessive, but it could be that the person attempting the purchase in the group is 18, whereas the rest are underage. For example, if the 18 year old is buying alcohol they may be buying it on behalf of the group due to being old enough and having ID. This is in effect 'proxy purchasing - more on this topic later in the training

How to refuse a sale

If you think that someone might be too young to buy an age-restricted product, politely refuse to sell them it and give them an explanation. If you have any doubts, speak to the manager or owner.

It is best to have a particular quote ready when you are refusing a sale, such as

"I'm sorry, but without proof of age I can't sell you this. The best thing would be to carry ID with you"

By having a quote ready and not stumbling over your words you will appear more confident in delivering the refusal message to the customer.

 

Remember that a refusal could embarrass or frustrate a customer, so be tactful and professional.

  • Try to stay calm, polite, understanding and firm even if the customer tries to pressurise you into making an underage sale

  • If the customer becomes violent or aggressive, speak to your manager immediately so that he or she can call the police or escort the customer from the premises

  • If you have a CCTV system, ensure that it is recording when you start your shift. It could deter violence and its records could be used as evidence to prosecute an offender

 

If a customer protests about your refusal to sell a product, try to follow these basic calming

techniques:

  • Keep your voice calm, your hands open and try to maintain eye contact

  • Do not respond to verbal abuse

  • Do not waver. Stick to your reasons for refusing the sale

  • Try to ensure that the customer understands why the sale cannot take place

  • Knowing the law and following these guidelines will help you to stay calm and be sure of your ground

 

By refusing to sell age-restricted products to underage persons, or to those who you believe are buying for underage persons, you may be exposed to hostility and aggression. If a potential customer uses abusive language or becomes aggressive, then try to stick to these guidelines:

  • Do not allow yourself to be provoked, remain polite and calm

  • Do not shout, interrupt or point at the customer

  • Keep to a safe and non threatening distance

  • Keep your voice low and your movements slow

  • Be consistent in your reasons for not selling, emphasise that it's nothing personal, state it's the Challenge 25 policy

  • Use the point of sale materials to help you

  • Make it clear that you are not picking on anyone and that the same law applies to everyone

  • Do not hesitate to ask for help and support from your colleague or manager

 

If the customer doesn't have any ID, or an acceptable form of ID, you can offer them an application form for one of the PASS approved ID card schemes, the details of which are in Part 6. This is a positive step towards them not being refused a sale in the future and can help defuse any conflict situation.

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If you experience any harassment problems you should contact the Neighbourhood Policing Team at your local police station. Your Neighbourhood Police Officer will also be able to pay you a visit and offer you advice on personal safety or other related matters.

It is good practice to record any refusal you make in the refusals register.

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Refusals Register

The law recognises that despite your best efforts, mistakes can be made. It is good practice to keep a record of refused sales, as it is a useful way of showing that you are being diligent and trying not to sell products to those underage. This may also help your case in the event that an underage sale takes place.

Depending on the facilities in the store the refusals register can take the form of an electronic record from the til's electronic point of sale (EPOS) system and/or a manual record whereby the details of the refusal are written in a refusals register.

The refusals register should be checked regularly by your supervisor to see if any patterns emerge. It is a useful insight into which staff members are refusing sales and those that are not, highlighting anyone who may need further training. It can also act as a deterrent to young people attempting to buy.

The refusals register should always be kept up to date and accessible. The enforcing authorities might want to see it.

What if I've made ​a genuine mistake?

Trading Standards officers accept that no matter what precautions are in place, from time to time a mistake will happen and a sale to a young person will take place.

So long as it is a rare event and you can demonstrate that you take great diligence in preventing underage sales taking place, then it is unlikely that the action that will follow will be as severe as a prosecution.

Officers are often more keen to educate and to work with you than they are to take more formal action and will take a lot of factors into consideration. Having said that, the policy of each enforcement agency may vary and so leniency cannot and should not be assumed.

As stated previously, underage sales are always taken seriously. The best thing you can do is to always ask for ID from someone who appears to be under 25.

Refusals Register 

How to use the refusals register: 

  • Keep it in a safe place close to the counter but out of sight of customers

  • It is essential that staff know where it is kept

  • Record the details of the refusal as soon as possible

  • Both the person refusing the sale and the supervisor should sign it

  • Any completed books should be kept- do not throw them away. The register may need to be produced in the event that Trading Standards Officers undertake enforcement activity, or if a threat of legal action against the premises' manager or staff arises 

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The information that should be recorded in the register is: 

  • Date & time

  • A brief description of the person attempting to buy the goods (male/female,. approximate age, type of clothing, hair colour etc.)

  • The product that was attempted to be purchased

  • Any observations

  • If any proof of age was produced (e.g. fake, seems to belong to someone else)

  • Reason for refusal

  • The staff member who refused the sale 

Acceptable forms of identification (ID)

Trading Standards recommend that only the following forms of proof of age are accepted:

  • A DVLA photographic driving licence

  • A current British passport (unless you have staff who can specifically identify genuine passports from other countries)

  • A Proof of Age card that carries the PASS logo​

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The Proof of Age Standards Scheme (PASS) is the UK's national guarantee scheme for proof of age cards endorsed by the Government and supported by the Association of Chief Police Officers (ACPO), the Trading Standards Institute (TSI) and the Home Office.

 

A PASS card shows the holder's:

  • Full name

  • Date of Birth

  • Passport standard photograph

  • Distinctive 3D PASS hologram with the word PASS printed in the centre in large silver letters, and then repeated in the background in smaller print.

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Even if a card carries a genuine PASS logo, make sure that it has not been tampered with. Some people may try to change the dates or names on a card. 

If a person provides ID to you take hold of it - don't allow them to just wave it in front of you!

Examples of acceptable forms of photo ID

UK Passport

PASS Proof of Age Card

Young Scot PASS card

UK provisional or full driving license

Five step checking process

Step 1: Check the photograph

  • Ensure that the photo is of the person presenting the card

  • The photo must be printed directly on to the plastic of the card, not on top of the plastic

Step 2: Check the date of birth

  • Calculate the age of the person from the date of birth on the card

  • Make sure they are old enough to buy alcohol 

  • The date of birth must be printed on the plastic, not hand written or stuck on top of the plastic

Step 3: If a PASS card

  • Look for the 3D hologram effect

  • Look for the small PASS text in the background 

  • The PASS hologram must be flush with the plastic, not stuck on top of the plastic

Step 4: Check the ID itself

  • Ensure the ID has not been tampered with or altered

  • Feel the ID, it should be smooth with no ridges or anything stuck on it

Step 5: Check the person matches the ID​

If you refuse a sale on age grounds, report this to your supervisor and record the details in the refusals register

Proxy Purchasing

​You have a responsibility to protect children from harm, so you should not sell alcohol to someone if you believe that they are buying it for someone underage-known as proxy purchasing.

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What constitutes an off sale proxy purchase?

Section 149 of the Licensing Act 2003 makes it an offence for a person to purchase or attempt to purchase alcohol for a child. For example; if an adult accepts money from a child to buy alcohol for them, then makes that purchase and gives the alcohol to the child that adult has made a proxy purchase.

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The consequence of a proxy purchase can be:

  • Getting a fixed penalty notice of £90

  • And even an unlimited fine

 

Exemption

A parent buying alcohol and subsequently giving it to his/her child would not commit an offence whereby the alcohol is consumed in the home under his/her supervision.

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How to spot a potential proxy purchase

  • Young people are loitering around the store, stopping different customers as they are about to enter the store

  • Sales of alcohol only, especially products that appeal to young people such as cheap wines, cider and lager

  • Purchases made using lots of small change

  • An adult who is purchasing alcohol separately to their other shopping and with a different set of money

 

If you have any suspicions at all that a customer is buying alcohol for someone underage you should not make the sale.

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Politely explain to the customer that they would be committing an offence if they were buying the alcohol for children. Refer them to the point of sale posters about proxy purchasing to support this message.

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Again, like any refusal situation, you might want to have a quote ready so you are not stumbling over your words and sound more confident in delivering the refusal message.

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You might want to say something like:

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"Did you know that if you are buying this alcohol for children, you would be committing an offence"

Notices required by law

Alcohol
It is recommended that you display notices stating that it is illegal to purchase or attempt to purchase alcohol if you are under 18, and notices about proxy purchasing.
If any members of your staff are under 18 it would be good practice to display a notice saying that they are not permitted to sell alcohol. This might avoid confusion or arguments with customers.
 

Remember!

  • There are times when you may feel pressurised into making a sale - but don't give in if you are unsure about anything as it's you that will be responsible

  • The law is there for a reason-to protect young people from harm, not to make your job harder

  • The consequences of getting it wrong can be devastating to children, the community, the store and yourself

  • If you always adhere to the Challenge 25 policy you will not make an underage sale and you will be doing a great job!

Please click on Challenge 25 Quiz to finish your training

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