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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 (1a)

Social responsibility code 3.4.1 (1a) - for operators to identify customers who may be at risk of or experiencing harms associated with gambling

Consultation question 1:

Do you agree with the proposed approach that the social responsibility code provision focuses on the outcomes that gambling operators must meet – that is, to identify and interact effectively with customers who may be experiencing harms associated with gambling?

Consultation question 2:

If you don’t agree, please explain why?

Consultation question 3:

To what extent do you agree with the proposed wording of the code, for operators to meet the outcome to identify customers who may be at risk of or experiencing harms associated with gambling?

Consultation question 4:

Do you have any other comments?

The majority of respondents agreed with our proposed overall approach for licensees to identify and interact effectively with customers at risk of or experiencing harms associated with gambling.

There was also broad agreement for our proposed specific wording for licensees to identify relevant customers. Some concerns were raised around how the code would work in practice, including challenges in the retail environment in terms of monitoring activity and understanding the impact of interactions without being able to track play.

Some gambling industry respondents questioned enforcement of the code and cited the need for open, objective and transparent processes for taking action.

Respondents suggested reinstating the requirement for staff training and that the requirement should state what policies and procedures must be designed to do, and that licensees should ‘facilitate’ interactions with customers.

Concerns were expressed about the use of customer data with regard to profiling and privacy, whether this information would be shared with other licensees and whether customers would have access rights to it.

Our position

We note the specific challenges raised by respondents in relation to retail premises. Licensees should consider their individual circumstances and put in place appropriate measures to meet those specific challenges.

We expect licensees to demonstrate how their policies, procedures and practices meet the requirement. This can be through implementing relevant parts of the guidance or by demonstrating how implementing alternative solutions equally meet the outcomes.

We note the calls for a re-wording of the proposed code. However, these suggestions begin to divert the focus away from meeting the outcomes, and more towards meeting prescribed requirements.

We do not propose that licensees routinely share individual customer data with other licensees. However, there remains an LCCP requirement for licensees to identify individual customers and this includes across other companies in their group (Social Responsibility Code 3.9 Identification of individual customers).

We have published information on our website in relation to the General Data Protection Regulation (GDPR) but licensees should seek advice on how to achieve compliance with GDPR while meeting their regulatory responsibilities under the Gambling Act 2005 (opens in new tab).

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Proposed changes to Social responsibility code 3.4.1 (1c)
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