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Consultation response

Remote customer interaction: Consultation Response

This response document sets out our conclusions and actions in relation to the consultation around remote customer interaction.

Our position on overall requirements and process

We have concluded that the new and stronger requirement to conduct customer interaction should be introduced, and that the requirement to take into account the Commission’s guidance for remote operators will remain in place accompanied by new guidance to be published in June. We have decided that these overarching requirements should apply in order to address the risks to consumers, accompanied by the detailed minimum standards that we have concluded are appropriate (set out in proposals 2, 3 and 4). It is important that operators recognise the continuous and ongoing nature of customer interaction.

The overall requirement to implement effective customer interaction is an important overarching requirement. It is also important that the Commission sets out guidance on how to meet the strengthened requirements and that operators are required to take this guidance into account. A number of elements of the current guidance are being upgraded to requirements through proposals 2 and 3. Together, this package sets out stronger and clarified requirements on operators.

In the consultation, we explained that the requirement is on operators to identify harm, take action and evaluate. However, the proposed LCCP provision used the wording ‘identify, interact, evaluate’. We have concluded that the LCCP provision should follow the wording and expectation set out in the consultation – ‘identify, act, evaluate’.

Many respondents, both those who agreed and those who disagreed with the proposal, commented that the overall process must allow the operator to tailor their response to the individual risks associated with a customer. We strongly agree that this is the case. This overall process continues to allow responses to be tailored, but provides greater emphasis on the action which operators take as a result of identifying indicators of harm.

Some respondents commented that there should be more prescription in how operators implemented this overall requirement and increased oversight on how operators did so. This is partly addressed by proposals 2 and 3 where we separately proposed stronger requirements on operators on the process for identifying customers at risk of harm and the scale of action by operators in response to those risks.

The issues raised by respondents in relation to identifying unaffordable gambling will be addressed and explored in more detail in the next stage consultation which we outline in the ‘next steps’ section of this response document.

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Respondents’ views on overall requirements and process
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