Customer interaction guidance - for remote gambling licensees (Formal guidance under SR Code 3.4.3 - not in effect)
Section A - General requirements - Requirement 1
This guidance was originally published in June 2022. It is not in effect and operators are not required to take it into account.
Following our consultation on customer interaction, Social Responsibility Code Provision 3.4.3 for remote gambling licensees has been introduced and the majority of requirements are in effect from 12 September 2022.
We have issued this update on the regulatory requirements and status of formal guidance regarding customer interaction for remote gambling operators. We intend to conduct further consultation on matters to be addressed in the guidance associated with Social Responsibility Code Provision 3.4.3, by way of a consultation on the guidance document itself, likely to commence in late September. This consultation will be available on our consultations page.
In paragraph 1, the words ‘as explained in the Commission’s guidance (see paragraph 2)’ are not yet in effect.
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.
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 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
The continous and ongoing process outlined in the Formal guidance can be visualised as follows:
Section A - General requirements - Requirement 2
Last updated: 15 September 2022
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