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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 D - Evaluate - Requirement 13

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.

13. Licensees must take all reasonable steps to evaluate the effectiveness of their overall approach, for example by trialling and measuring impact, and be able to demonstrate to the Commission the outcomes of their evaluation.


To provide assurance that the licensees customer interaction systems and processes are effective.

Formal guidance

13.1. Licensees are required by Social Responsibility (SR) Code Provision 3.4.3 to assess the overall effectiveness of their approach by bringing together information about the impact of interaction for individual customers. This should include quality assuring individual customer interactions by spot-checking records for those interactions including chat records, emails and records of changes in behaviour.

13.2. As well as checking that customers are getting the right support, this can also identify staff development needs and highlight good practice that you can share across your business and across the industry. Licensees should also trial different approaches to customer interaction to understand what works best, and what works best for different sections of their customer base (in line with requirement 13).

13.3. Whilst tracking of play data is the basic standard for evaluation of individual customer interactions, good practice is that licensees follow-up a sample of customers on an on-going basis to understand changes in problem gambling status based on problem gambling screens. Where possible, qualitative feedback on the quality and effectiveness of the interactions can also aid continuous development.

13.4. Licensees will need to keep effective records to meet this requirement. Records of interactions provide useful evidence of what types of indicators, methods of interacting and options for support and action work well for customers. This helps to inform the evaluation of the effectiveness of your overall approach to customer interaction.

13.5. Good evaluation helps you to understand which aspects of your approach are the most effective at identifying the right customers, and the types of tools or support that work well to help customers manage their gambling in a way that works for them. Reduction of indicators of harm following action is the key measure.

The following measures could also help to work out whether your approach is working well:

  • gambling management tools – increased take up and more customers sticking within their limits
  • customer retention
  • reduction in complaints.

13.6. The licensee is required to submit regulatory returns. We have clarified the definitions in regulatory returns to offer guidance on what should be included in a customer interaction (incident) log and make clearer what should be recorded. Your log should include as a minimum:

  • the identity or other identifier of the customer involved
  • the behaviour or activity that prompted the interaction
  • the action taken, advice or support given
  • the outcome of the interaction.

13.7. Licensees should have a process in place to ensure that industry learning (including public statements from the Gambling Commission casework), research and industry best practice is reviewed and implemented into police and procedures where appropriate. Licensees should be able to demonstrate how they keep up to date and how they implement any learning into policies and procedures.

The role of staff

13.8. Your staff have an important role to play to understand whether your approach works, and as a minimum, you should:

  • ensure that staff make records of all actions and customer interactions and use them to aid decision making. Such records should be used for evaluation purposes, for example dip sampling for quality assurance purposes, to assess whether a customer changed their behaviour as the result of an interaction
  • train staff to recognise when follow-up activity to an interaction is required
  • ensure that staff use customer interaction records as a decision-making tool
  • ensure that staff are properly supported in carrying out effective interventions.
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Section D - Evaluate - Requirement 12
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Section D - Evaluate - Requirement 14
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