Customer interaction guidance - for remote gambling licensees (Formal guidance under SR Code 3.4.3)
Section A - General requirements - Requirement 1
This current guidance was issued in August 2023 and is in effect from 31 October 2023. It replaces all earlier versions of guidance issued for remote gambling operators.
1. Licensees must implement effective customer interaction systems and processes in a way which minimises the risk of customers experiencing harms associated with gambling. These systems and processes must embed the three elements of customer interaction – identify, act and evaluate – and which reflect that customer interaction is an ongoing process as explained in the Commission’s guidance (see paragraph 2).
To set out the overall aim of the Customer Interaction requirements that licensees must have effective controls to minimise the risk of customers experiencing harms associated with gambling.
1.1. The systems and processes must embed the three elements of customer interaction which reflect that customer interaction is an ongoing process.
This is an ongoing process of monitoring, using indicators of harm to flag signs that a customer may be at risk.
Act to minimise harm
Tailoring the action to the number of types of indicators of harm is critical. Review the indicators and escalate action in response to those indicators. In some cases, this will require automated action, in line with the requirements. Record the action or interaction taken. Continue to monitor and ramp up action where necessary.
To consider the effectiveness of the action taken and whether further action is required. Evaluation processes should be built in from the beginning – they are not an afterthought.
This means that licensees must build processes which include the need to identify risk, take appropriate action and evaluate the impact of that action, which then returns to further monitoring, identification, action and evaluation. This is not a one-off process but should be considered throughout the customer’s relationship with the licensee.
Additional guidance and information (not required to be taken into account)
The continuous and ongoing process outlined in the formal guidance can be visualised as follows:
Section A - General requirements - Requirement 2
Last updated: 23 August 2023
Show updates to this content
Guidance updated following the 'Remote customer interaction - consultation on guidance'.