Reaction: Gambling Commission sets out new rules for action for at-risk customers

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EPIC Risk Management’s director of safer gambling, Dan Spencer, reacts to the Gambling Commission’s unveiling of new rules ensuring online gambling businesses do more to identify and take action to protect consumers at risk of harm…

Fourteen months on from the Gambling Commission’s call for evidence into remote customer interaction, today we received an update with the UKGC setting out guidelines and considerations for changes to the Licence Conditions and Codes of Practice’s social responsibility code. These changes will come into effect from 12th September this year, with further details being published in a ‘guide to interactions’ in June.

Having focussed almost all of my work on improving operator interactions since I completed the call for evidence over a year ago, I’m pleased to see an update from the UKGC and one that isn’t far from what the vision I set out in my own response.

Having lived with a gambling addiction for 16 years and now in successful recovery for four, I’m now proud to head up our operator partnerships at EPIC Risk Management as director of safer gambling. From my experience, direct interactions with players are the most effective way that we can prevent harm today. Sure, we need great data, and from what I’m seeing working with the likes of Entain, Flutter and Kindred, I know that the industry are striving for intelligent systems that can pick up this data and identify harm at an earlier point in a customer’s journey. However, it’s what we do with that data that really counts.

Today the UK Gambling Commission have set out a call to actions for all operators in the UK market:

• monitor a specific range of indicators as a minimum, to identify gambling harm

• flag indicators of harm and take action in a timely manner

• implement automated processes for strong indicators of harm

• prevent marketing and the take-up of new bonuses for at-risk customers

• evaluate their interactions and ensure they interact with consumers at least at the level of problem gambling for the relevant activity

• evidence their customer interaction evaluation to the Gambling Commission during routine casework

• comply with these requirements at all times, this includes ensuring the compliance of third-party providers.

On the whole, I don’t see this causing widespread panic across the industry, with our clients already at the level of compliance needed to satisfy the above. We’ve been providing safer gambling training and consultancy on a global scale - dealing with many different regulatory markets - for a number of years, and the UK market is clearly changing at pace, however the principles remain the same.

Where I do think this will improve things is amongst smaller operators. “A rising tide floats all ships” as they say, and here is where we have set a new watermark. Operators should be actively seeking indicators on problem gambling, we all know that, but now the UKGC has set out which specific markers they want to see included:

• customer spend

• patterns of spend

• time spent gambling

• gambling behaviour indicators

• customer-led contact

• use of gambling management tools

• account indicators

Seven markers, and none that I personally disagree with. Every client that I work with is already going further than this. Many use automated services like Mindway AI which already include many more indicators such as time of day, number of deposits, loss chasing and fluctuating wagers.

The data is out there and solutions exist to be more proactive in uncovering early signs of harm. The ambition though is to detect the signs that lead to harm. Why? Because we want to interact early, and that’s where I think todays update makes the connection in the right way.

If we actively look for the indicators and understand the risk, we have a better chance of an effective interaction with a customer. An effective interaction can happen in many ways, but for me the gold standard is a proactive phone call. Yes, it’s difficult, but the industry is on a journey of improvement and from I’m seeing we are educating customers and that’s leading to a better response from them.

As time goes by, we are seeing customers even expecting the affordability interaction; they’ve had it from other operators and know why you’re calling. Of course, some operators are further ahead that others in this area, if you’re not proactively reaching out then you’re behind right now. Do your customers not answer the phone? You didn’t get there early enough! Using the data in this way will help us get there at point where harm can be prevented and customers can continue to play at a safe level. If it’s left too late, harm can occur and the quality level of that interaction will suffer as a consequence.

Lastly, the commission addresses evaluation. They want to see evidence of operators evaluating their interactions. Now this may seem a bit obvious in terms of my advice here, but marking your own homework is never a great idea and I’m sure the Commission know this; they talk about third parties and ensuring their compliance in this area.

My team at EPIC have been evaluating operator interactions for over a year now and have seen incredible success in terms of improvement, confidence levels of the teams and output back to the commission. We do things differently here at EPIC and I like to think that our evaluation can only exist alongside the current robust in-house process.

The operators’ evaluation should answer the question “did my team carry out this interaction in the way we want them to?”. EPIC’s evaluation is conducted by those in recovery from gambling addiction and answers the question “If I was that customer, how would this interaction affected me?”.

It’s powerful stuff, and I hope to see it implemented on a wider basis. Transparency with a trusted third party is an important tool in safer gambling right now. The largest operators already know this, so it’s time to set a new benchmark for all…