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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.

Topic 6: Section D of the guidance – Evaluate


In Section D of the proposed guidance, we grouped guidance associated with requirements 12 to 14 which relate to evaluating the impact of the effectiveness of customer interaction.

The key issue associated with Section D of the proposed guidance is guidance associated with ensuring interactions are, at a minimum, in line with problem gambling rates. The requirement is intended as a backstop protection to ensure a certain level of interaction is taking place, but the guidance did not specify what type of customer interaction should be counted towards this.

Consultation questions

  • Problem gambling rates: Do you have any comments on the guidance for operators who offer more than one gambling activity to show how they should calculate one overall problem gambling rate in proportion to the activities they offer?
  • Other comments Section D: Do you have any other comments about Section D of the proposed guidance document, relating to evaluation?

Respondents’ views

Some respondents felt that the proposals for guidance relating to evaluation had positive attributes, and these were predominantly:

  • that it is understood there is a need for a simple approach and to create a minimum standard for levels of interaction
  • it is right that the Gambling Commission has highlighted evaluation - it is important to move beyond what should work in theory and understand what works in practice
  • the consideration of individual product type when identifying the need for customer interactions was welcomed
  • some feedback indicated that, whilst the approach is not perfect and will need to evolve, it is acceptable for now.

In relation to assessing customer interaction levels in line with problem gambling rates for the relevant product and in proportion to Gross Gambling Yield (GGY)1, respondents made a number of comments as set out in the following paragraphs.

Industry respondents said that using quotas may deplete the quality of interaction or encourage gambling operators to only hit those quotas and could shift them to looking at a narrow indicator for harm, rather than taking a holistic approach.

Customers who play across lots of products may not be correctly assigned to a category and there is a risk that creating one problem gambling rate across products may mask the risk in those products where problem gambling rates are higher.

The 12 month targets for interaction do not reflect seasonal fluctuations in gambling behaviour across the year.

Industry respondents expressed concerns with the evidence being used due to three main issues; timeliness, relevance (as they said problem gambling rates are reducing and there was a mismatch between Health Survey and quarterly telephone survey results) and robustness of the data (due to the inability to prove causation). These respondents also suggested the following changes:

  • to allow gambling operators to select the most appropriate problem gambling rate for their business and evidence how they selected it, or allow them to report their own problem gambling rates
  • that estimated problem gambling rates should be based on the demographic profile of the players, rather than activity profile
  • that problem gambling rates should be looked at in a different way, focusing on player portfolio, rather than prevalence in relation to individual activities
  • the prevalence rates by activity from the Health Survey 2018 are not granular enough for business use, and therefore gambling operators should have more discretion
  • further guidance would be needed on the types of interaction which are can be towards meeting requirement 14.

Other respondents commented that there is a risk that gambling operators will be double counting interactions with individual customers, preventing sensible read-across to problem gambling rates, and that gambling operators may count very light-touch interactions in the figures. Overall, these respondents felt that the proposed guidance did not specify enough detail to ensure consistency and meaningful evaluation.

Our position

The Gambling Commission welcomes the commitment from industry respondents to continue to build evaluation processes for customer interaction to measure impact on the outcomes we seek.

In relation to the backstop protection of ensuring that the number of interactions are at a minimum in line with problem gambling rates, the responses often commented on the requirements of Social Responsibility (SR) Code Provision 3.4.3 rather than the guidance content. We have made no changes to the guidance at this time as we consider that the guidance content explained the requirements and how a gambling operator should be compliant in an effective manner. For example, we consider it helpful to explain the timeframe over which gambling operators should consider whether they have met the minimum proportion of interactions as annual.

As the proposed guidance stated, interactions - if designed to identify risk of harm - should be capable of identifying a broader range of people at an earlier stage to reduce risk of harm.

In relation to concerns about requirement 14 decreasing the quality of customer interactions in order for gambling operators to hit specified levels, we would like to stress that this requirement sits as part of all the new requirements in Social Responsibility (SR) Code Provision 3.4.3 which should be considered together. The aim of these requirements is ultimately to improve the quality and effectiveness of customer interactions whilst also ensuring a proportional amount of the customer base is being interacted with.

Customer interactions are actions taken by a gambling operator in response to indicators of harm in connection with a customer - the types of actions are set out at requirement 9. The requirement in relation to problem gambling rates specifies that: 'For the avoidance of doubt, this provision is not intended to mandate the outcome of... customer interactions'. Therefore, we have simply added a cross-reference to requirement 9 in this part of the guidance in order to assist gambling operators.

In relation to research, the Health Survey 2018 is currently the most relevant source of figures of problem gambling rates by activity. The Commission's quarterly telephone survey - when it was live - did not include rates by activity. The intention of the requirement and guidance is to seek to drive consistency in this between gambling operators.

The Commission will consider the timing and how to embed new participation and prevalence methodologies into the information we provide associated with this requirement following the new methodology being rolled out as official statistics.


1 The amount retained by gambling operators after the payment of winnings prior to operating cost deductions.

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Topic 5: Section C of the guidance – Take action for customers at risk of harm
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Topic 7: Further consultation questions
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