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Customer Interaction – additional guidance during Covid-19

This Covid-19 guidance builds on the Customer interaction - formal guidance for remote gambling operators that we published in July 2019, specifically Social Responsibility Code Provision 3.4.1. The following explains how to use this customer interaction guidance.

How to use the customer interaction guidance

The purpose of this guidance is to share knowledge based on research, current practice and lessons learned in order to support licensees in determining how they can meet the outcomes. It sets out why customer interaction is important and makes our expectations clear. Not all of the content of the guidance will be relevant to all operators, but licensees must take it into account and be able to demonstrate how they have done so.

How the Commission will use this guidance

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.

Our understanding of gambling harms and how they manifest is constantly evolving, so for the purposes of raising standards, protecting consumer interests, and preventing harm to consumers, we will update and re-issue guidance where new evidence or risks emerge which may have a meaningful impact on how the outcomes can be met.

Based on our understanding of data relating to the present situation and the likelihood that some customers may be experiencing harms, we judge this additional guidance to be necessary to address the emerging risks.

Can you give further guidance on the expectations of interaction with customers who have been playing for an hour in a single session of play?

As part of their drive to make gambling as safe as possible, operators should be using all the information they know about a customer to determine the most suitable form of interaction. See also section 3 in Customer interaction - formal guidance for remote gambling operators titled ‘Interact’.

Are affordability assessments a new requirement?

The requirement to consider affordability is not new. Considering what a consumer can afford to spend is referenced within the July 2019 Guidance at 2.8 to 2.11.


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