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Guidance

Customer interaction guidance - for remote gambling licensees (Formal guidance under SR Code 3.4.3 - not in effect)

Customer interaction guidance for remote gambling licensees (Formal guidance under Social Responsibility Code 3.4.3 - not in effect)

Section C - Act - Requirement 9

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.

9. Licensees must tailor the type of action they take based on the number and level of indicators of harm exhibited. This must include, but not be limited to, systems and processes which deliver:

  • a. tailored action at lower levels of indicators of harm which seeks to minimise future harm
  • b. increasing action where earlier stages have not had the impact required
  • c. strong or stronger action as the immediate next step in cases where that is appropriate, rather than increasing action gradually
  • d. reducing or preventing marketing or the take-up of bonus offer where appropriate
  • e. refusing service or ending the business relationship where necessary.

Aim

There are two key aims of this requirement:

  • to set minimum requirements for the type of action that must be included within a licensee's systems and processes to minimise harm
  • to ensure that a licensee’s response is proportionate to the indicators of harm.

Formal guidance

Licensees have a range of actions they will apply in response to identified harm. This measure requires licensees to have the following suite of actions in place:

Early generic action

Actions at this level may apply to all customers, or where there are only very low levels of indicators of harm. It would include:

  • pop-ups
  • safer gambling emails promoting gambling management tools
  • generic safer gambling messages
  • having in place backstop protections or limits while checks are being undertaken.

Early tailored action

At lower levels of indicators of harm which seeks to minimise future harm.

Actions at this level would include:

  • the licensee encouraging the customer to use the gambling management tools they offer
  • sharing information on spend or behavior to encourage change and enhancing their knowledge and monitoring of the customer.

Medium tailored action

Increasing action where earlier stages have not had the impact required.

Actions at this level would include:

  • phone calls to conduct a customer interaction
  • tailored encouragement for the customer to consider behaviour
  • signposting to help and support
  • preventing direct marketing or access to new bonus offers.

Strong or stronger action

As the immediate next step in cases where that is appropriate, rather than increasing action gradually.

Actions at this level would include:

  • requiring the customer to set a spend limit
  • providing hot transfers to help and support (so the customer can be transferred without requiring them to dial again)
  • using technological solutions to help support a customer for example by reducing the visibility of products in a tailored way
  • preventing the take up of offers or incentives
  • setting spend limits or setting time outs on behalf of a customer.

Very strong

Ultimately, if the licensee’s concerns about a customer persist because the licensee’s actions have not resulted in sufficient protections in place or behaviour change by the customer, the licensee should refuse service or completely end the business relationship. In these cases, signposting to support and help will be important.

Examples of types of action at increasing strength levels

A visualisation of the types of actions at increasing strength levels is set out as follows:

  1. Prevention measures

    Reduce risk to consumers upfront.

    Encourage or mandate the setting of limits.

    Build in safer gambling.

  2. Early generic customer interactions

    Pop-ups.

    Emails signposting to gambling management tools.

    Generic safer gambling messages.

    Setting backstop limits for consumers while checks are being conducted.

  3. Early tailored customer interactions

    Encouraging the use of gambling management tools.

    Sharing information on spend or behaviour.

    Enhanced checks and/or enhanced monitoring.

  4. Medium tailored customer interactions

    Phone calls to conduct an interaction.

    Encourage customers to consider behaviour.

    Signposting to help and support.

    Preventing direct marketing or access to new bonus offers.

  5. Stronger customer interactions

    Requiring the customer to set a spend limit.

    Technology solutions: reducing the products visible to the consumer.

    'Hot' transfer to help and support.

  6. Strong customer interactions

    Preventing the take up of offers and incentives.

    Setting spend limits on hehalf of consumers.

    Setting a time out on behalf of consumer.

  7. Very strong customer interactions

    Ending the customer relationship.

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Section C - Act - Requirement 8
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Section C - Act - Requirement 10
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