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Customer interaction guidance - for remote gambling licensees (Formal guidance under SR Code 3.4.3)

Customer interaction guidance for remote gambling licensees (Formal guidance under SR Code Provision 3.4.3).

Section C - Act - Requirement 11

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.

11. Licensees must ensure that strong indicators of harm, as defined within the licensee’s processes, are acted on in a timely manner by implementing automated processes. Where such automated processes are applied, the licensee must manually review their operation in each individual customer’s case and the licensee must allow the customer the opportunity to contest any automated decision which affects them.


To ensure that immediate, automated action is taken to minimise harm where strong indicators of harm are identified; and to support licensee compliance with automated processing in line with data protection requirements.

Formal guidance

11.1. To ensure a timely response to identification of significant harm there will be a need for licensees to have automated processes in place. For example, if a significant level of harm is identified, it may be appropriate to place an immediate block on further gambling, a block on further deposits, or to set a deposit limit. This immediate action may stay in place until one or more final action is applied, following consideration by a member of staff, that manages the risk of harm. The final action may in some cases still be a block on gambling or a maximum deposit limit applied.

11.2. The second part of Requirement 11 requires that, where a decision is made solely by automated means and which has legal effects or similarly significantly affects a customer (such as by disrupting customer choice), the licensee contacts the relevant customer to inform them of the decision and their right to contest it. If they exercise their right to contest the decision, a substantive (manual) review must be undertaken. A substantive (manual) review is not required in every case or if the decision is not contested.

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Section C - Act - Requirement 10
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