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.
Contents
- Executive Summary
- Introduction
- Alternative dispute resolution
- Customer interaction
- - Introduction
- - Consultation proposal
- - Proposed changes to Social responsibility code 3.4.1 (1a)
- - Proposed changes to Social responsibility code 3.4.1 (1c)
- - Proposed changes to Social responsibility code 3.4.1 (2)
- - Our proposal to remove ordinary code 3.4.2
- - Amended Social Responsibility Code 3.4.1 Customer Interaction
- Research, Prevention and Treatment contributions
- Appendix A: Amended social responsibility code of practice 6.1.1 – complaints and disputes
- Appendix B: Amended social responsibility code of practice 3.4.1 – customer interaction
- Appendix C: Amended social responsibility code of practice 3.1.1 – combatting problem gambling
Proposed changes to Social responsibility code 3.4.1 (2)
Social responsibility code 3.4.1 (2) – for operators to take into account the Commission’s guidance on customer interaction
Consultation question 12:
To what extent do you agree with the approach to use guidance to provide good practice and support to operators to help deliver effective customer interactions?
Consultation question 13:
To what extent do you agree with the approach to use guidance to provide good practice and support to operators to help deliver effective customer interactions?
Consultation question 14:
What else would you wish to see included in the guidance?
Consultation question 15:
What other tools regulatory or less formal – do you or would you find useful to assist you in delivering effective customer interaction? This could include research and insight, copies of evaluations, sharing good practice, workshops etc
Consultation question 16:
Do you have any other comments?
The majority of consultation respondents and just over half of survey respondents agreed with this approach. We also shared draft guidance and asked what else respondents would wish to see included.
Responses included questions around the status of guidance and the consequences of non-compliance, as well as the level of engagement and the notice period that licensees would be given for subsequent changes.
Respondents referred to the continuing developing nature of our understanding about gambling harms, and the balance between a standardised approach and proportionate expectations. Specific elements suggested for inclusion were coaching, practices such as suspending accounts where there are concerns and examples of what good looks like.
One respondent welcomed the sense of collaboration between the Commission and industry and welcomed the guidance. Another felt the availability of a reference document was vital in raising standards.
Many respondents called for more workshops to support formal guidance, ideally facilitated by the Commission. It was noted that our co-creation workshops had been well received and one respondent hoped that we would continue to pursue similar activities and widen the current level of engagement.
Other suggestions included e-learning platforms and case studies, a specialist nudge unit to look into interactions and shared analysis of Assurance Statements data.
Licensee led collaboration would continue to be important, and trade associations were expected to have a role particularly in the area of shared evaluation. The work of organisations offering prevention and treatment interventions was also cited as potential sources of further guidance and support.
Our position
We wish to make clear that social responsibility codes hold the same weight as a licence condition. However, the requirement here is to take into account the Commission’s guidance on customer interaction. We expect licensees to develop, implement and maintain processes to identify and interact with customers to minimise the risk of harms associated with gambling, and to understand the impact of those interactions and the effectiveness of their approach.
The guidance is designed to support licensees in developing those processes, which should be proportionate and appropriate to the individual business. Not every aspect of the guidance will be appropriate for every gambling business, and where a licensee chooses to implement alternatives to the guidance, they should be able to justify why and how their approach enables them to deliver the outcome.
As new research and good practice becomes available, guidance will be updated to reflect such developments. Any future changes to the requirements and changes to the guidance will be subject to consultation.
Proposed changes to Social responsibility code 3.4.1 (1c) Next section
Our proposal to remove ordinary code 3.4.2
Last updated: 20 August 2021
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