Customer interaction guidance - for remote gambling licensees (Formal guidance under SR Code 3.4.3)
Section B - Identify - Requirement 4
4. Licensees must have in place effective systems and processes to monitor customer activity to identify harm or potential harm associated with gambling, from the point when an account is opened.
The aim is to ensure that there are effective systems and processes to monitor all customer activity and identify harm. In particular, the aim is that customers who may be at risk of harm are identified from the point at which an account is opened and that indicators of harm are not overlooked while the operator waits for a pattern of behaviour to emerge.
Licensees must identify customers that may be at risk of harm using all of the information available about the customer. This means balancing all the financial, time and behavioural indicators and applying knowledge about their overall customer base and individual customers.
There is a wide and growing evidence base about patterns of spend and behaviour that are linked to risk. This knowledge can be used to consider the position of a customer and apply proportionate customer interaction as a result.
We set out in paragraph 5 of the code (3.4.3) the seven required indicators that licensees must monitor:
- a. customer spend
- b. patterns of spend
- c. time spent gambling
- d. gambling behaviour indicators
- e. customer-led contact
- f. use of gambling management tools
- g. account indicators.
At paragraphs 7 and 8 of the code (3.4.3) the need to act in a timely way once an issue has been identified in order to minimise harm. Licensees with more active customers will need comprehensive systems, which will inevitably include a mix of automated and manual processes, and should draw on all available sources of data to give a comprehensive picture of the customer. These indicators for identifying harmful gambling draw on:
- in-play real or near time monitoring to identify harmful behaviour as it occurs
- monitoring of customer contacts with the licensee.
The right information can mean better and quicker decisions. To meet the requirements, you will need to integrate your systems so that staff have a more complete picture of the customer’s activity, and this includes records of previous customer interactions and/or action taken.
Unmonitored overnight gambling carries an increased risk. Research indicates that the highest risk customers were much more likely to gamble overnight than non-problem gamblers. Processes must be in place to offer the same level of protection overnight as during the day, and at the weekend. Automated processes will be necessary as set out at requirement 11 in the code (3.4.3) to reduce further harm.
To meet this requirement, it is important that all staff receive training so that they are aware of the signs that could indicate that a customer may be experiencing harms associated with gambling. This is not an exhaustive list, but you should ensure that:
- staff are trained to identify the signs of harm and are able to refer back to documents that include the types of behaviour that may trigger customer interaction at an appropriate moment
- staff know how to escalate a situation if they are unsure or require support
- as a minimum, staff receive training at induction as well as refresher training.
Licensees should aim to identify those experiencing or at risk of harm and intervene to reduce harm at the earliest opportunity. Reliance on deposit or loss thresholds that are set too high will result in failing to detect some customers who may be experiencing significant harms associated with their gambling. It is therefore imperative that threshold levels are set appropriately.
Historically, gambling licensees have not systematically considered customer affordability when developing their customer interaction policies. Many have used deposit or loss thresholds as a main or sole prompt for a customer interaction, but these have often been set at levels that were inappropriately high, in comparison to the average amount of money that the majority of people have available to spend on leisure activities. This has led to a number of examples of customers spending more than they could afford, and this not being identified sufficiently early, as seen in much of the Commission’s compliance and enforcement casework.
Open source data exists which can help licensees assess affordability for their Great Britain (GB) customer base and improve their risk assessment for customer interactions. Thresholds should be realistic, based on average available income for your customers. This should include the Office of National Statistics publications on levels of household income (opens in a new tab).
In considering these thresholds, you should be aware of the difference between ‘disposable income’ and ‘discretionary income’ which refers to the amount left after living costs are taken into account, but it does still include many other unavoidable costs.
Most people would consider it harmful if they were spending a significant proportion of their discretionary income on gambling. We expect that guidance on financial risk will be updated following further consultation on measures to address gambling harm associated with financial risks of binge gambling; clearly unaffordable gambling over time and financial vulnerability. Licensees should be considering how they manage those risks now.
Keep meaningful records of all actions for and interactions with customers. Make these records available to staff and use them to aid decision-making. This should also take place in circumstances where an interaction has been delayed at that moment for example because the customer is displaying signs of agitation.
Effective systems and processes would address the key risks we have identified in current licensee practices:
- processes that are too slow
- processes that rely solely on manual action
- lower levels of protection for new customers
- insufficient knowledge of customers to understand risk of harm
- licensees who contract with third parties failing to have sufficient processes for account monitoring.
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Section B - Identify - Requirement 5
Last updated: 24 June 2022
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