PIV Comments/Suggested Edits - 11 VAC 5-70-130 - Identification Cards
B. Identification Card
1. An identification card shall display a photograph of the licensee and, at a minimum, indicate:
- The individual's name;b. License Number
 We respectfully recommend a license number to be included on I.D. cards to allow for ease of reference for employees, operators, and the VA Lottery.
C. A licensee:
- Shall wear or otherwise prominently display the licensee’s identification card at all times while working unless otherwise approved by the Director for a specific date and time;
 We respectfully recommend that this provision apply to only those employees who are located inside the Commonwealth, and not employees physically located outside of the Commonwealth working for the online sportsbook Permit Holder.
G. Surrender and Reissuance of Identification Card.
- The employer of the individual who was issued an identification card under this section shall make all reasonable efforts to ensure that the licensee’s identification card is surrendered to the Director if the:
 If an employee separates employment, it may be difficult for the Employer to ensure that we get their license back unless we possess it during their employment. Recommend language requiring Employer make reasonable efforts to recover the identification card to return it, then the director shall NOT proceed with any enforcement action.
- If an identification card is not surrendered as required under this subsection, the licensee’s employer may be subject to enforcement action under this chapter.
 See previous comment. As online operators/permit holders are not situated the same as Brick and Mortar casinos, it is our recommendation that an Enforcement action is heavy handed action in this scenario: We respectfully recommend that where Employer makes all reasonable efforts to ensure that a licensee’s identification card be surrendered to the Director, that no enforcement action be taken.