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Raising Standards: Reducing the risks from online gambling

Introduction

  • We published our corporate strategy in 2017 and since then we have been working hard to challenge and disrupt old behaviours and ways of thinking as a means of encouraging a gambling market that is fairer and safer for consumers. We have implemented a much tougher compliance and enforcement regime, intended to significantly change behaviour by operators and those who run them.  Alongside that tough approach to enforcement, we have been seizing opportunities to encourage collaboration among gambling operators. 

 

  • We now stand at a crucial juncture. Consumer behaviour and technology are changing so quickly that simply seeking further, incremental market development and improvement is not going to be enough to keep pace with emerging risks and opportunities. A bold and innovative approach is now required.

 

  • We know that 24 million adults in Great Britain gamble, but we also know that consumer experience of gambling is not always positive.  We want to see consumer and public confidence in gambling improve significantly, alongside a reduction in the numbers of people who are experiencing gambling related harm or are at risk of harm.  It is simply unacceptable that there are more than 300,000 problem gamblers in Great Britain and many more at risk of suffering gambling related harm.

 

  • We asked our advisory groups to provide their independent views on how the risks from online gambling could be reduced and we now have the advice from:
    • The Advisory Board for Safer Gambling (ABSG)[1] – whose role is to provide independent advice on safer gambling and the delivery of the National Strategy for Reducing Gambling Harms[2].
    • The Digital Advisory Panel[3] – which was created to provide us with greater insight to digital industries and technologies to help us keep pace with change online.
  • We are publishing their advice in full[4] alongside this paper, which sets out our response to the advice and recommendations, including the actions we are already taking. We have not addressed every individual recommendation here. Our response is grouped into five distinct themes. We will consider specific recommendations as we progress our work to reduce online harms and provide further updates.

 

  • The advice has already influenced our work – reflected in the challenges to industry we set out in October.[5] Although our approach is to collaborate with operators to make progress, if the risks we have identified are not addressed, mandatory regulatory action will follow.

Building our knowledge – including experts by experience

  • We, and our advisors, recognise the need to keep pace with the rate of change online – be it new products, technologies or shifts in consumer trends and behaviour. In doing so, we know that our need for expert advice goes beyond input from current advisory groups. It requires the views of consumers themselves, including those who have previously been harmed by gambling.

 

  • To access this, we have formed a new consumer reference group – allowing us to speak to a wide range of consumers about their experience of gambling – including the good and the bad. We are working to support the creation of new forums that will allow those who have lived experience of gambling harms to inform and influence policy and action by the Gambling Commission and others.  These will be supported to protect participants’ personal welfare and to ensure their contributions make a real impact.[6] A partnership has been created with the Health and Social Care Alliance to develop these structures in Scotland. We are working with partners in England and Wales to develop equivalent forums.

 

  • We take an outcomes-focused approach, so no matter what new technologies or products operators offer – obligations to protect their customers from harm always remain the same. We dedicate resources to horizon scanning, which is achieved through a range of techniques from media scanning to participation at industry events. By forming the Digital Advisory Panel, we have access to a group of advisors with deep knowledge of how digital industries work.

Data and transparency

  • We agree with our advisors that greater transparency is required of all operators and improved use of data are essential to making online gambling safer.

 

  • Data on how people gamble presents a vital opportunity to reduce harms online. We agree that more could be done to use this to its full potential. Building on the Digital Advisory Panel’s advice, we issued a challenge to the industry to work together to develop ways data could be used to create a ‘single customer view’.[7] This is intended to help overcome one of the weaknesses in the approach currently taken by operators - which is limited to only observing a customers’ gambling on their own products. Because most gamblers have more than one online account,[8] this gives a narrow view, rather than the full picture. It means interventions can be inconsistent between operators and insufficient to prevent the harms a customer could be experiencing.

 

  • Success of the ‘single customer view’ will only be achieved by working in collaboration with industry. We stand ready to play our role, providing clarity about the outcomes to be delivered, facilitating access to appropriate experts, and holding operators to account – especially ensuring that all relevant operators play their part in its development and ensuring that a level playing field is created when it is implemented. It will also require a better understanding of good practice in the use of algorithms to detect harmful gambling. The Gambling Commission is ready to start the process by running a collaborative event early in 2020.

 

  • We hope this activity will provide a unique opportunity to understand markers of harm across a players’ full range of online gambling activity and for more targeted and effective interventions, at an earlier stage, to prevent harm. Whilst a move to a single consumer view would provide a much wider view of a consumers’ gambling behaviour, and increase the chances of identifying consumers at risk of harm, this does not reduce the responsibility of operators to use the data they have now. It is vital that operators continue to improve their processes to identify and interact with consumers who may experience harm based on the data they hold on an individual now. Strengthened requirements (in LCCP and associated guidance) for this came into effect on 31 October 2019, and operators are responsible for ensuring that they meet these standards.

 

  • We will explore other ways that transparency and data can be used to drive progress. We are not convinced, however, that publication of assurance statements is the best tool to achieve this. As these are operators’ own claims about what works, we think alternative options would be more successful. We have, for example, started to explore how a data repository could be established to give academics greater access to industry and regulatory data.[9]

Game, product and app design

  • Both pieces of advice highlight concerns about game and product design. The Digital Advisory Panel draws particular attention to ‘habit-forming apps’. The ABSG highlight the growing links between gambling and sports news, gambling and video gaming, and social casino games. The current National Strategy recognises the importance of improving understanding of the link between game design and gambling harms.

 

  • One of the three challenges we recently issued to industry relates directly to game, product and app design. We have called for all relevant parts of the industry to collaborate on the creation of an Industry Code for Game Design, to be published no later than our Raising Standards Conference in Spring 2020.

 

  • We expect this code will cover apps and online games – and articulate the key risks associated with each product and how these are mitigated. The code should also set out a clear explanation of what is not acceptable in game and product design. Compliance with such a code should not be optional. We will take steps to mandate compliance into our Licence Conditions and Codes of Practice (LCCP).

 

  • The ABSG has pointed to the lack of limits on stakes and speed of play online as an area that needs to be reconsidered and we have already stated that we will consider the case for stake limits online and work on how this could be implemented.[10] Unless operators can clearly demonstrate it is not needed, particularly through progress on the challenges we have set out, introducing a regime of stake and prize limits could become necessary.

 

  • We are also conscious of the risks associated with other features of online gambling. We are taking steps to address the risks related to gambling on credit cards,[11] and as pointed out by ABSG, are also considering other potentially risky features, such as reverse withdrawals.[12]

More focus on prevention and what works

  • ABSG’s advice highlights the importance of learning more about what works in harm prevention and incorporating robust independent evaluation. This is directly in line with the approach set out in the National Strategy which highlights the need to trial new approaches to harm education, evaluate what works, and share the findings.

 

  • We have previously called on operators to test new approaches and to be open about what they find through evaluating their actions. At present we are co-ordinating operators’ participation in research work through the Behavioural Insights Team to test out different ways of reducing online harms, and the results will be published once these trails are complete.[13]

 

  • A further challenge to industry, issued at the Raising Standard Briefing,[14] called for the development of a code of conduct for the use of incentives for high value customers. We want to learn from our past compliance and enforcement action, where exposure of poor treatment of customers, classed as VIPs by operators, has shown serious failings.[15] A code of conduct should help reduce such failings, and subject to piloting and testing to demonstrate it is effective, we will take steps towards mandating wider compliance across the industry.

 

  • There are further opportunities, outside the direct realm of the gambling industry to better utilise data on people’s gambling behaviour. We agree that significant opportunities exist in collaboration with banks and the financial service sector. We have already agreed a partnership with the Money and Mental Health Policy Institute to co-ordinate activity with the financial sector to progress on the National Strategy to Reduce Gambling Harms.[16]

Marketing and advertising

  • We share the concerns expressed in both sets of advice on the issue of high levels of exposure to marketing and advertising online and the potential for this leading to a negative impact on children, young people and vulnerable adults.

 

  • Gambling marketing and advertising is subject to strict content, scheduling and targeting rules which are written by the Committees of Advertising Practice (CAP) and enforced by the Advertising Standards Authority (ASA). We work very closely with them and if a gambling operator is found to be in serious or repeated breach of their rules, we have powers to take action.

 

  • We also believe there are opportunities to go further to address specific concerns about levels of exposure, particularly for children, young people and those who could be vulnerable to suffering gambling harms. At the Raising Standards briefing, we set industry the challenge of making demonstrable progress on the use of ad-tech to proactively target online marketing for gambling away from children, young people and those who are vulnerable to harms. As ABSG points out, tools exist to identify if people have made online searches which might suggest they are suffering harm from their gambling. Operators should be using these tools to reduce the risk of these individuals seeing their marketing. Our challenge is for industry to create a plan, and make clear progress by April 2020, on new standards for how the gambling industry will embrace and deploy ad-tech with the aim of reducing the risk of harm.

 

  • Recent research by the University of Stirling and Ipsos MORI provided valuable insights on the levels of gambling marketing to which children, young people and those who are vulnerable are exposed.[17] We look forward to phase two of this research, to be delivered in February 2020, which will give new evidence on the impact of this exposure. Once this is available, we will work closely with CAP and ASA to consider the findings and take appropriate actions. We continue to work very closely with our co-regulators to raise and enforce standards online. These standards have improved but there is much more to be done.

Conclusion

  • The advice we have published from ABSG and the Digital Advisory Panel reinforces our view that incremental developments and improvements are not enough to keep pace with the emerging risks and opportunities presented by online gambling.  Only a bold and innovative approach will allow us to achieve the reduction in the numbers of people experiencing or at risk from gambling related harm that we need to see. 

 

  • We want to support the industry to develop, implement and evaluate the following initiatives, which we consider are likely to have the biggest impact on key areas of risk:
    • Responsible product design
    • Incentivisation of high value customers
    • The use of Ad Tech to prevent children and vulnerable people being exposed to gambling related advertising online
    • A single customer view.
  • These priorities will add value to on-going pieces of work to improve use of markers of harm, understanding of affordability and more effective customer interaction.

 

  • We look forward to being able to report that demonstrable progress has been made on all of them by the Spring.


[1] Advisory Board for Safer Gambling

[2] National Strategy to Reduce Gambling Harms 2019-2022, Gambling Commission, April 2019

[3] Digital Advisory Panel

[4] Digital Advisory Panel: Advice on the impact of online platforms on gambling-related harm

Advisory Board for Safer Gambling: advice to the Gambling Commission on actions to reduce online harms 

[5] Raising standards, breakfast briefing, Gambling Commission, October 2019

[6] Gambling Commission calls for collaboration on engaging people with lived experience, National Strategy for Reducing Gambling harms micro-site, Gambling Commission, September 2019

[7] Raising standards, breakfast briefing, Gambling Commission, October 2019

[8] Gambling participation in 2018: behaviour, awareness and attitudes, annual report. Gambling Commission, February 2019 (page 23)

[9] Independent repository of gambling industry data – a scoping study, University of Leeds, August 2019

[10] Raising standards, breakfast briefing, Gambling Commission, October 2019

[11] Consultation on gambling with credit cards, Gambling Commission, November 2019

[12] Review of online gambling, Gambling Commission, March 2018 (page 48)

[13] Can behavioural insights be used to reduce risky play in online environments, The Behavioural Insights Team, October 2018

[14] Raising standards, breakfast briefing, Gambling Commission, October 2019

[15] Raising standards for consumers, enforcement report 2018/19, Gambling Commission, 2019

[16] Collaboration - implementation, National Strategy for Reducing Gambling harms micro-site

[17] The effect of gambling marketing and advertising on children, young people and vulnerable adults: synthesis report, Ipsos MORI, July 2019

Raising Standards: Reducing the risks from online gambling

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