Evaluating the effectiveness of the approach
This formal guidance for remote gambling operators is not current and from 12 September 2022 operators are no longer required to take it into account. It was published in July 2019 and remained in effect from 31 October 2019 to 11 September 2022.
Following our consultation on customer interaction, Social Responsibility Code Provision 3.4.3 for remote gambling operators has been introduced and the majority of requirements are in effect from 12 September 2022. We issued this update on the regulatory requirements and status of formal guidance regarding customer interaction for remote gambling operators. The guidance issued in June 2022 under Social Responsibility Code Provision 3.4.3 is not in effect and is subject to further consultation. Operators are not required to take it into account.
Records of interactions provide useful evidence of what types of indicators, methods of interacting and options for support work well for customers. They will help to inform an evaluation of the effectiveness of your overall approach to customer interaction. Good evaluation helps you to understand which aspects of your approach are the most effective at identifying the right customers, and the types of tools or support that work well to help customers manage their gambling in a way that works for them.
The following measures could help to work out whether your approach is working well:
- gambling management tools – increased take up and more customers sticking within their limits.
- customer retention.
- reduction in complaints.
- numbers of customer interactions appear to be in line with the prevalence of gambling harm for the product, as follows.
Statistics which estimate the numbers of problem and ‘moderate risk’ gamblers are published regularly, based on the combined health surveys in England, Scotland and Wales (NatCen 2018). This data is broken down to gambling activity type, and by region, and can help you to work out the percentage of your customers you should be interacting with. When looking at the potential percentage of your customers who may be experiencing harm, remember to consider the percentage of gamblers participating in that activity and not the percentage of the adult population.
Currently the only industry-wide quantitative measure of identifying and interacting with customers who may be experiencing harms associated with gambling is data on the numbers of customers who received an interaction, submitted to the Commission as part of regulatory returns. We have clarified the definitions in regulatory returns to offer guidance on what should be included in a customer interaction (incident) log and make clearer what should be recorded.
Your log should include as a minimum:
- the identity or other identifier of the customer involved
- the behaviour or activity that prompted the interaction
- the advice or support given, and
- the outcome of the interaction.
Keeping your policies and procedures under review and up to date by taking into account research and industry best practice will help you to identify customers you should be interacting with, which will help you target your resources where they are most needed, in ways which may lead to better outcomes. You should also review your internal controls following the publication of a regulatory settlement, to address any similar weaknesses which could exist in your own processes.
The role of staff
Your staff have an important role to play to understand whether your approach works.
As a minimum, you should:
- ensure that staff make records of all customer interactions and use them to aid decision making. Such records should be used for evaluation purposes, for example dip sampling for quality assurance purposes or to assess whether a customer changed their behaviour as the result of an interaction
- train staff to recognise when follow-up activity to an interaction is required
- ensure that staff use customer interaction records as a decision- making tool
- ensure that staff are properly supported in carrying out effective interventions.
Evaluate: questions to consider
- Do you know how many of your customers may be experiencing some level of harm associated with gambling?
- How do you know you are delivering positive outcomes for your customers?
- How could you improve on your policy and procedures? How do you plan to make improvements over time?
- How could you share your good practice with the industry?
Understanding the impact of individual interactions
Last updated: 15 September 2022
Show updates to this content
- Information in the callout at the beginning of the guidance page has been updated.