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 7: Further consultation questions
Proposals
The consultation document explored and asked open questions about the following three additional cross-cutting themes:
- research
- consumer experience
- financial impact
- equalities impacts.
Consultation questions
- Research: Are you aware of any recent developments in research which may suggest additional or different content for the guidance document?
- Consumer experience: Do you have any experience of actions which have been taken by operators which may inform good practice in implementing the requirements?
- Financial impact: Do you have any information or views about whether the proposed guidance would be likely to result in increased costs, above and beyond those costs that would be incurred in any event as a result of Social Responsibility (SR) Code Provision 3.4.3?
- Equalities impact: Do you have any comments or evidence in relation to any potential equalities impacts of the proposed guidance? In particular, do you have any concerns that the guidance could have a negative or disproportionate impact on persons with protected characteristics?
- Other matters: Do you have any other comments about any part of the proposed guidance document or any content which should be included in the guidance document?
Respondents’ views
In relation to research, we were pleased respondents shared a number of research studies with us in response to this question, which flagged that there was awareness of key components of the current key evidence base for these respondents.
There were a number of comments about potential costs - both stating that the costs would be negligible for responsible businesses, and also at the other end of the scale, that the increased staff costs of more granular customer interaction approaches which might be associated with the requirements may be significant and disproportionate. Some smaller gambling operators commented they considered the financial impacts would be more significant for them.
Some respondents suggested that the Gambling Commission should confirm that its guidance has been checked for compliance with the Equality Act as well as data protection laws. Some respondents suggested that a fuller detailed economic analysis would be appropriate.
One respondent stated that the industry accepts that implementing these systems will create a safer gambling environment and reduce problematic play.
Our position
The key evidence base for the Gambling Commission to inform the preparation of our guidance was the lessons learned from our casework. Information about our casework leading to regulatory sanctions can be reviewed on our Regulatory actions public register. We have also updated the guidance to link to additional information on the Commission's website where further evidence is available and also to work to build our evidence base which is currently is taking place.
The Commission continues to consider that the introduction of guidance which gambling operators are required to take into account is overall positive for gambling operators in understanding the Commission's approach. There is a cost to reviewing the Commission's guidance and taking it into account. However, the Commission considers that using the guidance to inform work taken in compliance and so on also reduces the costs of compliance as it helps give a clear picture of the Commission's approach when utilising the guidance. We consider this to be particularly relevant for smaller gambling operators
The Commission has considered equalities issues arising in the course of this consultation and specific considerations are contained in this document.
The responses to the consultation did not flag any issues relating to equalities impacts of the guidance which led us to consider changes to the guidance. However, we have added text to the content relating to customers in a vulnerable situation to reinforce and emphasise that not all factors automatically mean that a customer is vulnerable to gambling harm. It is important that any action in relation to vulnerability will include consideration of the entire picture for that customer and be tailored and proportionate to the risk.
The Commission has also considered issues associated with data protection implications of the proposed guidance and specific considerations are contained in this document.
Topic 6: Section D of the guidance – Evaluate
Last updated: 18 August 2023
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