Consultation response
Customer interaction guidance for remote gambling operators: Consultation Response
This response sets out our position in relation to the consultation around the guidance on new, more prescriptive, customer interaction requirements for operators.
Contents
- Executive summary
- Introduction
- Summary of responses
- - Topic 1: The overall format, structure and language of guidance
- - Topic 2: Introduction and Section A of the guidance – overarching content
- - Topic 3: Section B of the guidance – Identify customers at risk of harm
- - Topic 4: Section B of the guidance continued – Identify vulnerability
- - Topic 5: Section C of the guidance – Take action for customers at risk of harm
- - Topic 6: Section D of the guidance – Evaluate
- - Topic 7: Further consultation questions
Topic 2: Introduction and Section A of the guidance – overarching content
Proposals
We proposed that the introduction section in the guidance document explains how the Gambling Commission intends the guidance to be used by gambling operators and how the Commission will itself use the guidance on Social Responsibility (SR) Code Provision 3.4.3. We explained that we are interested in views on the approach set out.
We also proposed that the first main section of the guidance document (Section A) addressed requirements 1 and 2, which relate to the overarching requirement for customer interaction and the requirement to take into account the guidance.
Consultation question
- Do you have any other comments on the introduction section or on Section A of the proposed guidance document?
Respondents’ views
A number of respondents to this question discussed the importance of informal and ongoing collaboration between the Commission and gambling operators, to allow for engagement outside of formal compliance assessments.
Some respondents commented that introduction and Section A clearly demonstrate the Commission’s expectations and would allow gambling operators to have a clear understanding and clear definitions to refer back to. One respondent also said that the guidance creates sufficient scope for a variety of approaches between gambling operators.
Our position
We have retained an introduction section which sets out the Gambling Commission's approach to using the guidance.
In particular, in the paragraph ‘How the Commission will use this guidance’, the guidance document states: ‘Social responsibility (SR) Code Provision 3.4.3 sets out the requirements relevant licensees must comply with in relation to remote customer interaction. For compliance and enforcement purposes, we will expect licensees to demonstrate how their policies, procedures and practices meet the required outcomes. This can be through implementing relevant parts of the guidance or demonstrating how and why implementing alternative solutions equally meet the outcomes’. We consider that this helps gambling operators understand how the Commission will use the guidance in its work, a query that was raised in some responses.
We have also decided to retain Section A in order to explain the overarching requirement to conduct customer interaction.
We will continue to engage with the gambling industry outside of formal assessment through regular engagement at Chair and Chief Executive Officer (CEO) Roundtables and through ad hoc discussions. The guidance is designed to evolve as necessary over time, and it is important that we receive information about good practice and lessons learned. Although not a statutory requirement, when considered appropriate we may consult on guidance and engage in other ways.
Topic 1: The overall format, structure and language of guidance Next section
Topic 3: Section B of the guidance – Identify customers at risk of harm
Last updated: 18 August 2023
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