Customer interaction guidance - for remote gambling licensees (Formal guidance under SR Code 3.4.3 - not in effect)
Section D - Evaluate - Requirement 13
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.
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.
Licensees must 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 spotchecking records for those interactions including chat records, emails and records of changes in behaviour.
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.
Whilst tracking of play data is the minimum expected standard for evaluation of customer interaction, 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 screens2. Where possible, licensees should also gain more qualitative feedback on the quality and effectiveness of their interactions to aid continuous development.
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.
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.
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.
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
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.
2 More detail on widely used screens (including those used by the Commission).
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Section D - Evaluate - Requirement 14
Last updated: 15 September 2022
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