Individual premises licence holders may wish to consider further compliance measures:
Premises licence holders may wish to incorporate its age verification policy in training materials, including the ‘16-point/2-hour’ mandatory staff training. In any event, the policy must be communicated to all staff involved in the sale or supply of alcohol and that communication must be auditable.
However, it should be noted that the statutory requirements of mandatory staff training for those serving alcohol have not been amended by the requirement to have an age verification policy. Under the Licensing (Scotland) Act 2005, those requirements include training in relation to: (1) Offences under the Act, particularly those involving persons under the age of 18; and (2) Proof of age under Sections 102 and 108 of the Act and the relevant regulations.
Further useful steps which might be taken to show due diligence and compliance with the terms of the age verification policy may include periodic company test purchases whereby a company agent aged 18 is sent in to premises to attempt to purchase alcohol; monitoring of staff by senior members, particularly of new staff; and signage placed at the bar or on tills where it can be seen by staff reminding them of the policy and their duties. But again these are not specific legal requirements under the terms of the Alcohol etc. (Scotland) Act 2010.