Identifying and intervening to assist customers who may be at risk from gambling-related harm
All gambling operators are required to put into place policies and procedures to interact with customers where they have concerns that a customer’s behaviour may indicate problem gambling. LCCP social responsibility code 3.4 sets out the minimum standards we expect operators to meet.
In our corporate business plan for 2017-18, we set out our commitment to carry out a review of how the industry identifies, and intervenes to assist, players that are at risk of being harmed by gambling, and to publish our plan of activity in this area.
Why are we doing this work?
The National Responsible Gambling Strategy sets out a series of priority actions for the gambling industry and other stakeholders to progress towards the overall aim to minimise gambling-related harm. In carrying out this review and our continuing programme of work, we are contributing towards delivering two of those priority actions: Improving methods of identifying harmful play and Piloting interventions.
Gambling is an enjoyable and entertaining experience for many people, but we know that it can cause harm to some individuals. The industry has developed ways to identify some of the more overt behaviours that could mean someone is experiencing problems with their gambling, and interact with them.
More recently, our focus, along with government and organisations such as the Responsible Gambling Strategy Board, has moved towards achieving a better understanding of the risks associated with gambling, and how that can lead to gambling-related harm, and we expect the industry to do the same.
Operators should be able to identify and intervene to reduce the risk of gambling-related harm, and to do this in an effective and proactive manner. Early detection and intervention in this area can help reduce the risk of greater harm, not only to the individual, but also to the people around them.
Some of these indicators of harm are harder to detect online, and we have seen through our enforcement work a number of cases where there were failings in customer interaction - operators didn’t spot or didn’t act upon the signs of gambling-related harm - as shown in our recent public statement about failings at 888. Because of this, and the increasing opportunities to gamble through growth in online gambling, we prioritised engagement with the remote sector for review at this stage.
What have we done so far?
At our Raising Standards Conference last November we held workshops with both remote and non-remote operators to get a better understanding of the barriers to customer interaction across the whole gambling industry, and to talk about what works. We have also looked at case work examples and complaints and reviewed a sample of customer interaction policies. We looked at regulatory returns data, and our own research and compliance assessments.
We have also more recently engaged with a sample of 25 remote gambling operators to better understand how they identify and intervene with players at risk of harm.
What have we found so far?
We found wide variety across the industry in the policy, approach and delivery of customer interactions. This may be because operators interpret the term ‘customer interaction’ differently. We also found that the majority of operators were often unaware of the impact their customer interactions had on their customers, and how best to measure the effectiveness of their approach.
From our sample of remote operators, we found inconsistencies in the approach and execution of customer interaction across the remote sector. A number of operators are already developing and operating algorithm-based systems to identify harmful behaviours and activity.
Some operators have started to tailor their methods for interaction to a customer’s preferences. Most operators monitor indicators in addition to time and/or spend, most commonly cancelled withdrawals.
However, while most operators undertake quality assurance of individual customer interactions, we found very few operators were able to review and evaluate the effectiveness of their approach, and that a number of very small operators were relying on manual systems for monitoring customer activity, which might not keep pace with rapid growth.
Research and related activity
Research commissioned by the Responsible Gambling Strategy Board, through GambleAware, has been published, looking at behavioural analytics in remote gambling to identify markers of harmful or risky behaviour.
The industry is also working collaboratively with GambleAware to identify good practice and pilot responsible gambling messaging and understand the information players need to help them manage their own gambling, as well as new approaches to staff training around social responsibility.
As our own work moves forward, we will draw on the findings and learnings from this research to inform our ongoing approach to raising standards across the industry.
What do we plan to do next?
We expect that in order to raise standards in this important area of player protection we will need to make changes to our LCCP.
There is still much work to do to develop our understanding of the most effective methods of identifying people at risk of gambling-related harm, and intervening to assist them. Our focus over the next year will be to continue to build our evidence base leading up to consultation on changes to the LCCP.
So far we have carried out thematic work looking at customer interaction in the remote sector. Next, we will carry out a review of customer interaction in gambling premises, looking at the effectiveness of current approaches to identifying and intervening to assist players at risk of harm in the non-remote environment.
We will take the findings of the thematic work, plus research and evaluation as it becomes available, and issue guidance to the industry. We expect to define our expectations around customer interaction, set out our position regarding provision for dealing with VIPs, and share good practice.