Guidance
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 B - Identify - Requirement 5
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.
5. Licensees must use a range of indicators relevant to their customer and the nature of the gambling facilities provided in order to identify harm or potential harm associated with gambling. These must include:
- 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.
Aim
To provide a minimum requirement of seven relevant categories of indicators that licensees must use to help identify gambling related harm. We consider this group of indicators to be key in understanding risk. The list is the minimum requirement and therefore not exhaustive; licensees should use their own additional indicators.
Formal guidance
5.1. Licensees must use a range of indicators relevant to their customer and the nature of the gambling facilities provided in order to identify harm or potential harm associated with gambling. These must include:
- 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.
5.2. In order to identify which indicators should be used in addition or as subcategories to the minimum list. Licensees should use a range of indicators based on research, experience and shared practice. The PricewaterhouseCoopers (PwC) remote gambling research entitled 'Helping detect and mitigate harm from problem gambling' (2017) (opens in a new tab) identified some account and play indicators, but they are not a definitive list. The following examples include those that we have made requirements:
- a, b, c:
- Time and spend indicators: amount of money and time as well as and frequency of deposits (including identification of binges), high amounts at set times for example payday, time of day (a higher percentage of overnight gamblers were found to be problem gamblers, than during other times of day), increasing length of sessions or escalation in deposit levels. Amounts spent compared with other customers, taking account of financial vulnerability.
- d:
- Gambling behaviour indicators: gambling on multiple products, chasing losses, erratic betting patterns, gambling on higher risk products or unusual markets or outcomes on which the customer is unlikely to have been able to make an informed choice. People who bet in-play may place a higher number of bets in a shorter time period than people who bet in other ways, as in-play betting offers more opportunities to bet. Some studies have shown that placing a high number of in-play bets can be an indication that a customer is at an increased risk of harm from gambling. A ‘big win’: high staking following a win could hide or even lead to harmful behaviour.
- e:
- Customer-led contact: information or hints from customers, frequent complaints about not winning, expressions of anger, requests for bonuses following losses, or talking about the negative impacts of their gambling.
- f:
- Use of gambling management tools: changing deposit limits, previous self-exclusions, frequent or repeated use of the time out facility, a refusal to use gambling management tools, or setting limits so high as to be meaningless.
- g:
- Account indicators: failed deposits, multiple payment methods, pre-loaded cards and e-wallets which could indicate gambling with money the customer does not have, regularly failing to withdraw winnings (particularly where associated with other indicators of harm), becoming evasive or showing an unwillingness to provide information.
5.3. The following list is provided to support licensees with implementation. Licensees should:
- use a range of indicators relevant to your business but which must include the indicators set out in requirement 5
- use realistic thresholds and trigger points, designed to identify those experiencing harm. Not every customer who is experiencing or at risk of harm will trigger every indicator. It is important therefore that systems are not missing identification of potential harm because they are not sensitive to behaviour against individual indicators where in isolation they might be enough to indicate harm
- monitor all customer activity so that you are able to act early and quickly
- invest in systems and staff to embed the indicators of harm into the process effectively
- make sure your process keeps pace with any increase in demand – through growth, mergers or other internal changes
- train your staff to know their roles and responsibilities, and ensure they are supported and able to act promptly when they spot or are alerted to indicators of harm, particularly for any customer facing staff ensure that there is a consistent level of protection, whatever time of day there is play, as well as for new customers.
Assessing whether there are strong indicators of harm will depend on the circumstances of individual cases – for example:
- there could be one indicator which itself is a strong indicator
- there may be a behaviour that is an indicator because it is particularly pronounced or unusual
- there may also be a number of less serious indicators might cumulatively amount to a ‘strong’ indicator.
Additional information (not required to be taken into account)
The following list duplicates the categories of indicators of harm set out previously in requirement 5, which are required and sets out additional information about further subcategories which could be considered:
- Customer spend - Amounts spent, taking into account affordability. Amounts spent compared to other consumers
- Patterns of spend - Binges. High amounts at set times for example payday. Escalation of gambling
- Time indicators - Amount of time spent gambling. Time of day for example late night
- Behaviour - Multiple products. Chasing losses. Choice of higher-risk products. In-play betting. Erratic patterns
- Customer-led contact - Complaints. Indicators of vulnerability such as bereavement. Hints of not coping. Chat room comments
- Use of gambling management tools - Refusal to use tools. Changing limits. Previous self-exclusion. Repeated use of time out
- Account indicators - Failed deposits. Multiple payment methods. Types of payment.
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Section B - Identify - Requirement 6
Last updated: 23 August 2023
Show updates to this content
Guidance updated following the 'Remote customer interaction - consultation on guidance'.