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Interacting with the customer

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.

New guidance is available issued in August 2023 under Social Responsibility (SR) Code Provision 3.4.3. This Customer interaction guidance – for remote gambling licensees (Formal guidance under SR Code 3.4.3) is in effect from 31 October 2023, and remote gambling operators are required to take the guidance into account from this date.

When you are concerned that a customer may be experiencing harm, acting early and quickly could help stop or prevent the harm worsening.

For some customers, making them aware of why you are concerned may be enough to prompt them to think and make a change. Some customers will need more support or advice.

Your interactions should have an outcome. Knowing what impact your interaction has had will help you support the customer and help to keep improving your approach. To achieve this, it is vital to keep good records and make them available to staff to inform decisions.

Interact

We expect you to:

  • be curious, and if you spot behaviour or vulnerabilities that could indicate harm, to act on it.
  • make all reasonable efforts to make contact and interact with a customer, and find out what impact your interaction had.
  • you should choose the type of interaction based on the extent of the potential harm – from automated responses to human contact – and adapt your messaging to try to get the best outcome. You should trial and evaluate different approaches to achieve this. Importantly, this may include refusing service or ending the business relationship.
  • think about what information you should give the customer, such as describing the type of behaviour they display or practical help or support where appropriate.

There are a number of ways for you to interact with your customers, including email, telephone calls, live chat or pop-up messages.

The best way may depend on the circumstances:

  • what you need to know from the customer, and what you already know about them.
  • what information you want to give to the customer.
  • how urgent it is to make contact.
  • how many times you have already interacted with the customer.
  • the outcome you want to achieve.

A customer interaction has three parts

These are:

  1. Observation – behaviour or activity you have spotted or something the customer tells you.
  2. Action – contact to prompt the customer to think about their gambling, for you to find out more, and an opportunity for you to offer information or support.
  3. Outcome – what you or the customer did next. In some cases, you may need to monitor the customer’s gambling to spot any change which may prompt further action.
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Spotting harmful gambling
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Tailoring messages for your customers
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