Effective interventions
Once an operator has detected a consumer who could be experiencing harm, we continue to be concerned that the interventions used are not strong enough, and are insufficiently evaluated to provide us with assurance they are effective. We welcome the work being carried out through the Gambling Commission’s research programme, and commissioned by GambleAware, to test and evaluate harm prevention measures online. This includes randomised controlled trials designed by the Behavioural Insights Team (BIT) with three large online operators.6 It also includes a collaborative project led by Revealing Realities, BIT and a further eight operators (including on and offline gambling).7 These are positive steps forward, particularly as they combine well-designed interventions with robust approaches to evaluation. We note, however, that these interventions still place emphasis on the consumer changing their own behaviour. Harms occur over a range of different levels of participation in gambling,8 and at the most severe end of this spectrum, it can be compulsive and even addictive. Placing reliance on the individual to change their behaviour in these circumstances is very unlikely to work.
We recommend the Gambling Commission, therefore, should encourage more operators to engage in testing and evaluating a wider range of intervention activities. These should include approaches which do not rely on a consumer who is experiencing harm being responsible for restricting their own behaviour. Co-ordination is vital. Our advice on the National Strategy highlighted that a key lesson learnt from the previous one, was there had been too much reliance on ‘letting a thousand flowers bloom’ and more co-ordination and direction would be needed in the future.9 Operators approaches to harm reduction still appear ad hoc and are largely unevaluated. The recently published Implementation Plan for the National Strategy to Reduce Gambling Harms provides the ideal framework to co-ordinate action to develop and evaluate stronger safer gambling interventions.10 This will, however, require strong leadership and dedicated resources if progress is to be made rapidly.
The development of effective interventions require input from experts by experience. The Gambling Commission, and its partners in the delivery of the National Strategy for Reducing gambling Harms, should take steps to learn how experts by experience are used in other public health contexts and apply this to gambling. We are delighted to see the formation of a partnership with the Health and Social Care Alliance Scotland. We look forward to taking part in the development of wider networks to engage experts by experience in England and Wales.
Although available as a multi-operator scheme since April 2018, the online self-exclusion scheme, Gamstop, has suffered delays and has not yet provided the Gambling Commission with sufficient assurance to make membership of it a requirement for all online operators.11 More encouraging is that an evaluation is now being undertaken, including a survey of service users to understand their experience and the schemes’ impact since it was introduced. This will provide a useful evidence base to inform future improvements. We welcome proposals by treatment providers, which recognise that self-exclusion tools alone will be insufficient for many users and are proposing additional support which can be offered alongside. We recommend that these ideas are explored and tested to understand better their potential to help reduce harms. Customers who return from a self-exclusion should already be treated as a high-risk group by operators. The Gambling Commission should consider how it can assure itself that operators processes and interactions are sufficiently robust with customers in these situations. Ideally, operators would be able to offer the option of longer periods of self-exclusion. For some people this might include lifetime self-exclusion. But we understand that there are practical and legal challenges to achieving this. As the multi-operator scheme develops, these options could be explored.
The financial services sector is an essential part of the gambling ecosystem. We recommend that the Gambling Commission explores expanding partnership work with financial service providers to enhance protections and help to reduce harms. Further work should be undertaken to build on the promising initial opportunities which have been created by banks who now offer blocking services on gambling transactions.12 For example, restrictions on gambling with debits cards on overdrawn bank accounts may also help reduce harm for people in constrained financial situations. The financial sector has the potential to generate other solutions and innovations to help reduce gambling harms.
We also note that the Gambling Commission frequently acts to prevent unlicensed gambling websites from transacting with consumers in Great Britain. Although a range of methods are used to disrupt and prevent this illegal activity, IP blocking may provide a valuable additional tool. We recommend that the Gambling Commission explore with government the feasibility of equipping the Commission with these powers, which may require updating legislation.
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Game design and product characteristics
Last updated: 25 March 2021
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