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Consultation response

Changes to LCCP on ADR, CI and RET contributions

A summary of the responses to our consultations on changes to LCCP requirements for customer interaction and alternative dispute resolution (ADR) providers.

Proposed changes to Social responsibility code 3.4.1 (1c)

Social responsibility code 3.4.1 (1c) for operators to understand the impact of the interaction on the customer and the effectiveness of the licensee’s approach

Consultation question 7:

To what extent do you agree with the proposed wording of the code, for operators to meet the outcome to understand the impact of the interaction on the customer and the effectiveness of the licensees’ approach?

Consultation question 8:

What other tools or data would be beneficial to licensees to help them understand and evaluate the effectiveness of their approach?

Consultation question 9:

And how could that be provided?

Consultation question 10:

What other types of data could be used to help understand the impact on consumers at an industry level?

Consultation question 11:

Do you have any other comments?

The majority of respondents to the main consultation agreed with this proposal, as did half of survey respondents.

We also asked what tools or data would be beneficial to licensees to help them understand and evaluate the effectiveness of their approach, and how this could be provided. A common theme was a need for more data sharing between licensees to understand how their own interactions compare across the industry, and sharing evaluation.

Respondents suggested that financial data such as average salaries across different industries or job roles could help assess what a customer could afford to gamble and help to identify more personalised thresholds for interaction. Other examples included general data from credit card companies, consumer feedback and surveys, more independent academic studies, use of gambling management tools and an increased use of clinical screens e.g. Problem Gambling Severity Index.

Suggestions also included seeking direct customer feedback, learning from current practice, in particular what is less effective, and insight from customers who access support and treatment services.

Some respondents welcomed the National Strategy to Reduce Gambling Harms in particular the aim to establish a data repository in order to help facilitate research into potential harmful gambling and to embed well designed approaches to evaluation.

Responses included developing partnerships with organisations with first-hand experience of working with service users, such as GamCare (opens in new tab) and Citizens Advice (opens in new tab), and through commissioned research in partnership with industry and independently by industry into early detection and safer gambling. In terms of helping to understand the impact on consumers at an industry level, respondents referred to work being carried out by stakeholders such as the Remote Gambling Association working group on affordability, GAMSTOP (opens in new tab) and the multi-operator self-exclusion schemes data and insight from treatment and support providers such as GamCare and Gordon Moody (opens in new tab).

Respondents suggested a role for the Advisory Board for Safer Gambling to provide guidance on evaluation, working collaboratively with licensees to determine best practice.

Respondents gave examples of their own practices, such as a review of internal controls in light of regulatory settlement statements, and use of customer interaction software applications, which are growing in number.

A provider of geolocation solutions suggested ways that customer devices could be anonymously tracked, to provide insight into the totality of a customer’s gambling across multiple accounts, help maximise tools such as self-exclusion and blocking and signpost to local and accessible treatment options.

The proposal was seen as an important development and potentially crucial for the industry’s long-term survival.

Our position

We welcome the range of responses which show licensees are actively considering the types of tools and data that could help them evaluate effectiveness and offered such a range of relevant examples which could assist at both an individual licensee and industry level. Further work on developing guidance, resources and support for evaluation is being taken forward under the National Strategy to Reduce Gambling Harms.

We note that use of both general and customer specific financial data and the concept of individual affordability was raised. Our expectations around affordability have been included in our guidance on customer interaction and more detail is in our recently published Enforcement Report 2018 to 2019.

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Proposed changes to Social responsibility code 3.4.1 (1a)
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Proposed changes to Social responsibility code 3.4.1 (2)
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