Customer interaction guidance - for remote gambling licensees (Formal guidance under SR Code 3.4.3 - not in effect)
Section D - Evaluate - Requirement 12
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.
12. Licensees must implement processes to understand the impact of individual interactions and actions on a customer’s behaviour, the continued risk of harm and therefore whether and, if so, what further action is needed.
The aim is that licensees evaluate the impact of their interventions to determine whether further action is needed to minimise harm, and that the further action is delivered in a timely and effective manner.
This requirement means building in evaluation of the impact that the licensee’s action, has delivered. In this context, by impact we mean a change in the customer’s gambling activity which could be attributed to the interaction. Licensees must follow up interactions with monitoring of changes in play data including number of products used, spend, deposit patterns and more nuanced play patterns (such as chasing losses, increasing spin speeds etc.)
Not every customer who receives an interaction will require active follow up, but many will. In these cases, follow up activity should continue to be proportionate to the severity or extent of the harm being displayed. If the interaction so far has not had an impact, there is a need to increase the strength of action taken next.
Understanding the impact of the action on the customer includes being able to look at and compare:
- the indicators of harm and behaviour before the action
- whether the chosen action was customer-led or operator-led
- how you acted and what was communicated to the customer
- the change in indicators of harm and behaviour following the action.
Some ways to work out that impact include:
- if your action was to set a limit on behalf of the customer, did the limit have the desired impact? Are there continued indicators of harm, and is further action needed?
- if your interaction was a call to action for the customer for example encouraging the use of gambling management tools, did the customer start using those tools in a manner that prevents or reduces harm? If not, is it necessary to set a limit on behalf of the customer?
- was there a positive change in behaviour? Did the customer’s gambling change after the interaction?
- are you content that protections are in place for customers that you are aware are in a vulnerable situation?
- is there a need for further or follow up action?
Section D - Evaluate - Requirement 13
Last updated: 15 September 2022
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