Customer interaction guidance for remote gambling operators
Customer interaction describes how you identify people who may be experiencing, or at risk of developing, problems with their gambling, and how you interact with them to offer help or support.
If you suspect a customer may be experiencing or at risk of developing problems with their gambling, you are required to interact with them to offer help and provide support.
This guidance sets out some of the issues around identifying potentially harmful behaviour in remote gambling. It talks about why it is important, makes our expectations clear, and suggests ways you could meet them. This includes some ways that remote gambling operators have told us they have found worked for them and their customers.
In our strategy for 2018-21, we set out our expectation for operators to intervene to make play safe and to protect consumers who may be at risk of gambling-related harm. This includes people who, due to their current circumstances, may be more vulnerable to developing problems with their gambling. In order to raise standards, we are committed to helping businesses be compliant: to ensure standards are understood, to facilitate sharing of best practice, and to give guidance.
As the industry continues to trial and evaluate new approaches to protecting consumers who are at risk of harm, and as new research is published, we will update this guidance. We expect that to continue to raise standards in this area, we will need to change the Licence conditions and codes of practice (LCCP), and will use evidence of good practice to set these minimum standards.
How to use this guidance
You should use this guidance to look at your own policies and procedures, and think about whether they meet our expectations, or if you could do more.
In this note, we refer to people who may be experiencing, or at risk of developing, problems with their gambling as being “at-risk customers”. When we talk about “indicators of harm” or “harmful behaviour”, we mean behaviour or activity which could indicate that someone is experiencing, or at risk of developing, problems with their gambling.
Customer interaction does not mean customer service or marketing, or requests for information solely for anti-money laundering purposes, and this note does not cover your responsibilities around anti-money laundering. For more information on this, see our advice on meeting your anti-money laundering responsibilities. However, because the signs of harmful behaviour can look similar to fraudulent activity, you could use your ongoing due diligence and monitoring procedures to identify both harmful and/or fraudulent activity.
Your regulatory responsibilities
All gambling operators are required to put into effect policies and procedures for customer interaction where they have concerns that a customer’s behaviour may indicate problem gambling, as set out in the LCCP, Social Responsibility Code 3.4. Recent public statements of lessons learnt show that a number of operators have failed to meet this regulatory requirement.
These policies should describe how you identify customers who might be experiencing problems with their gambling, and interact to help them. When deciding whether to interact with a customer, you should take into account:
- what you know about the signs of harmful gambling; and
- what you know about the customer.
We know that some of you are concerned about your responsibilities around consumer data protection, alongside gambling regulation. General Data Protection Regulation (GDPR) requirements should not stand in the way of using data responsibly to identify patterns of play and target interactions to protect customers. For more information, see our note on GDPR.
Summary of research and further reading