Single Consumer View
Online gambling operators have taken some steps to protect vulnerable adults from problem gambling in line with their licence requirements. They use technology to monitor the activity of their customers and search for indicators of harm, allowing them to identify problem gamblers or gamblers at risk and engage with them to reduce the likelihood of unhealthy behaviour. Furthermore, research12 carried out by PwC on behalf of GambleAware shows that the current accuracy of detection by operators could be improved by expanding the demographic and behavioural markers and by using other techniques such as specific daily triggers to complement the predictive markers allowing operators to investigate and intervene almost immediately. Thirty-nine specific triggers are identified in the report.
There is a major flaw in the current approach. Gambling operators can only see gambling activity on their website or app. This means that it is easy to miss a problem gambler that does not show indicators of harm with a single operator. However, across a number of operators, it would be more obvious when a gambler is spiralling out of control. Since the average mobile gambler has four apps on his/her mobile device, and the average problem gambler uses many more, the probability of this risk is very high. Each operator does not have a full picture of their customer’s online gambling activity, so it is unreasonable for the GC to expect them to identify and engage with all at-risk or problem gamblers successfully.
If there were a service that could identify problem gamblers based on gambling activities across all operators, identification of problem gamblers would be much more successful. Best practice could be built into that service, and that best practice could be developed over time. In that way, the GC could ensure that all operators are using a consistently high standard of problem gambler identification.
The service would accept various parameters concerning the gambler’s identity in an industry-standard format, along with transactional level information about bets placed. The service could then return an array of coefficients of harm that could be used by operators to segment their customers and protect them accordingly.
The technologies are available to build this type of service and progress has been made with the variety of problem areas that would have to be addressed to make such a service successful, such as:
Security. It is of paramount importance that any solution is secure because sensitive information about gamblers is being processed. Tokenisation and encryption techniques have been developing rapidly in recent years. These techniques and open source libraries could be used to create a service with robust end-to-end security.
Identification. Debit or credit card13 details provide a good start in this area but there are more advanced techniques used in other spheres, such as online identification deployed by HMRC and the pornography industry to protect suppliers from accusations that they are selling their products to children.
Analytics. The capability to process structured and unstructured data has developed significantly in the last ten years. It will be important to process the data provided by operators efficiently. This capability is widely available now.
The proposed service would benefit all if using these services became obligatory for all licensed operators in Great Britain. The challenge is to decide the roles of each organisation in creating these services.We propose the Gambling Commission take the lead to facilitate the introduction of such a service,, setting standards and ensuring those regulations and standards are adhered to.
We propose that the larger operators cooperate through a joint venture to create the required service spreading the costs across all licensees. This would allow each organisation to take responsibility for the part of the challenge that is consistent with their core competencies:
Standards setting and research
For example, research into the indicator of harm should continue to be driven by the Gambling Commission.
Developing a secure service
Developing a secure software service protected with the latest technology, leveraging leading practice in data warehousing, analytics, security to be owned by a joint venture between major firms operating at arm’s length from their owners (i.e. operators will not have access to the transactional data of their customers from other firms).
Identification
There is a range of options that the joint venture might use to identify an individual gambler. The Gambling Commission should define the requirement, and the joint venture should be responsible for designing, building and testing solutions.
Handling people identified as having problems or at risk of having problems
Responsibilities for handling individual gamblers will continue to be the responsibility of the operators. The Gambling Commission will continue to define standards for those interactions.
Policing standard and regulations
Policing standard and regulations should continue to be the responsibility of the Gambling Commission.
This exercise will not be a short-term project. It will require the Gambling Commission to engage in a consultation process with the industry to ensure the requirements defined have practical solutions.
It will be important to take an incremental approach to the development of these services. A big bang development would be a mistake. A simple service could be developed based on the current understanding of markers of harm, while the Gambling Commission pursue research projects to explore improvement with markers of harm and specific triggers in parallel. This improved understanding can be incorporated into the service at a later date.
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Last updated: 27 July 2023
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