Customer interaction guidance - for remote gambling licensees (Formal guidance under SR Code 3.4.3 - not in effect)
Section C - Act - Requirement 8
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.
8. Licensees must take appropriate action in a timely manner when they have identified the risk of harm.
To ensure that once licensees identify harm or potential harm that action is taken in a timely way to minimise further harm. The action should be a proportionate response to address the harm, or potential harm, identified.
When a Licensee is concerned that a customer may be experiencing harm, acting early and quickly is important to help stop or prevent the harm worsening. Identifying signs of harm and taking early action is a preventative measure, designed to enable a customer to gamble safely, or take action to reduce or prevent gambling where necessary.
Licensees are required to take action in a timely manner (which in some cases will mean through automated, real-time measures), and the action needs to reflect the seriousness of the indicators of harm, including refusing service and ending the business relationship where necessary.
Licensees must tailor the type of action they take based on the number and level of indicators of harm exhibited. Importantly, this may mean taking strong or stronger action straight away, rather than increasing action gradually. This will include giving consideration to refusing service or ending the business relationship where necessary.
If a customer has been exhibiting low level indicators of harm and this progressed to higher levels of concern, it would be appropriate for there to be an escalation in the strength of response. But if there was a high level concern identified, such as immediately after registration, the strength of the action the licensee takes should match that immediately.
Licensees interactions should have an outcome. Knowing what impact your interaction has had will help you support the customer, through the consideration of whether further action is necessary, and to keep improving your approach. To achieve this, it is vital to keep good records and make them available to staff to inform decisions.
When contacting customers you could consider how the customer prefers to contact you, to decide the best way to interact with them about their gambling.
Messages that get customers to think and make their own decisions based on the information they are given can be more effective than messages that seem to be 'nagging'. Research entitled 'Testing normative and self-appraisal feedback in an online slot-machine pop-up in a real-world setting' (Auer and Griffiths 2015) (opens in a new tab) also shows that personalising feedback can also improve the impact it has on customers. You should test different types of messaging to see what works best.
Encourage customers to think about their gambling. Their responses will help you work out the right kind of help and support to offer.
If you have difficulty making contact with a customer, depending on the level of concern it could be appropriate to suspend or restrict the account access until you are able to interact with them, or take any other action.
A self-assessment questionnaire can help customers think about their own gambling. Their shared responses, alongside their gambling behaviour, can help both you and the customer work out the right kind of help and support they may need.
You will need to direct some customers to information about safer gambling, and/or suggest suitable gambling management tools. This will include signposting to sources of help and specialist support from organisations who deal with advice and treatment for gambling harms.
You will need to interact with some customers a number of times if the earlier actions or interactions have not delivered the impact required. Your records of previous interactions with customers will help you decide whether there is a need for escalating action.
Feedback from customers shows that they often respond better to being informed about their behaviour and why, rather than being 'told' what to do. But for some customers, and particularly if the behaviour continues to cause concern, there is need to take a more proactive approach. In some cases, you may need to take action for the customer, such as setting limits; preventing direct or targeted marketing or ultimately refusing service by closing their account.
The role of staff
You should ensure that your staff:
- understand the types of action that can be taken and how to interact appropriately. For example, whether action on behalf of a customer is necessary, and how to ramp up action in line with the number and type of indicators
- know the type of help or support to offer when supporting customers through interaction, such as information, signposting customers to specialist support or the gambling management tools which are available. These may be the minimum required under the LCCP or the Remote Technical Standards, or tools you offer which go beyond minimum requirements
- know the circumstances and process for refusing service to customers, such as by applying limits or closing an account
- understand their respective responsibilities and who is designated to carry out customer interactions, if only certain staff members are authorised to interact.
Whilst training on the legislative framework is important, staff also need to be trained on the skills and techniques they need to help them carry out customer interactions, including what to do if a customer becomes distressed of there is a risk of suicide.
Good record keeping allows you to demonstrate when and why you have interacted with customers, and helps with ongoing monitoring of customers. You should:
- keep records of all actions and interactions, including where an interaction didn’t take place or was delayed, the reasons for this, and how it was followed up
- make use of and record all relevant sources of information to guide and deliver effective customer actions and interactions, including your records of previous actions and interactions.
Good records should include:
- the behaviour or activity before the interaction
- how you interacted and what was said or done, for example advice or suggestions to help the customer manage their gambling, or to take a break from their gambling
- behaviour following an interaction and decision on whether further action required
- what happened next.
Section C - Act - Requirement 9
Last updated: 24 November 2022
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