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Keeping records

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.

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 customer interactions, including where an interaction didn’t take place, 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 interactions, including your records of previous interactions.

Good records should include:

  • the behaviour or activity before the interaction.
  • the change in behaviour or prompt for 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, and
  • what happened next.

You should also record situations where an interaction was prompted but did not take place, and how you followed that up.

In some cases, you will need to monitor the customer’s gambling to spot behaviours which could indicate further harm.

Interact: questions to consider

  • Where concerns arise, are you able to intervene early and engage with a customer?
  • How do you decide the best way of interacting with a customer? Do you use different methods for different groups of customers?
  • Do you tailor your method and message depending on the extent of the harm?
  • Do you know if the customer received and acted on the information you gave?
  • Have you allocated sufficient resources to be able to interact with customers early and effectively when you have concerns?
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