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Spotting harmful gambling

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.

How you monitor activity depends on your business. Larger operators with more active customers will need comprehensive systems, which could include a mix of automated and manual processes, and should draw on all available sources of data to give a comprehensive picture of the customer’s gambling.

Options for spotting harmful gambling include:

  • in-play real time monitoring to identify harmful behaviour as it occurs.
  • daily reports on activity.
  • chatroom monitoring and moderation.

The right information can mean better and quicker decisions. You should aim to integrate your systems so that staff have a more complete picture of the customer’s activity, and this includes records of previous customer interactions.

Unmonitored overnight gambling carries an increased risk. Remote gambling research (PWC 2017) found that the highest risk customers were much more likely to gamble overnight than non-problem gamblers. Some operators have full 24-hour dedicated safer gambling monitoring and support, so that customers have the same level of protection overnight as during the day. Another option could be more training and extra responsibilities for customer service staff or chat hosts to provide that support.

Because VIP customers can also experience gambling harms, it is good practice to carry out a safer gambling check when upgrading a customer to VIP status, and to keep this under review. You should also use these opportunities to carry out checks for Anti-Money Laundering (AML). This could also help you to support customers who have had major wins.

The role of staff

It is important that all staff receive training so that they are aware of the signs that could indicate that a customer may be experiencing harms associated with gambling.

This is not an exhaustive list, but you should ensure that:

  • staff are trained to identify the signs of harm and are able to refer back to documents that include the types of behaviour that may trigger customer interaction at an appropriate moment. Staff should know how to escalate a situation if they are unsure or require support.
  • staff understand how indicators of harm could be displayed differently in VIP or ‘high value’ customers, and know how to spot the signs.
  • as a minimum, staff receive training at induction as well as refresher training.

Identify: questions to consider

These include:

  • Are you curious about your customers?
  • Are your indicators relevant to your products and customers?
  • Do you rely too much on financial indicators like deposit levels or losses?
  • Do you consider all types of vulnerability?
  • How do you decide the right level of your thresholds? Do you set your thresholds based on the staff you have to manage the workload, or do you think about what is right for your customers?
  • Do you take into account all relevant information, and act quickly?
  • Do all appropriate staff have access to customer interaction records?
  • How could you assess the risks around new customers? What can you find out about your customers? What protections could you put in place until you know enough about your customers?
  • Can your monitoring process keep up with demand?
  • Do you offer the same level of protection for all your customers, no matter how long they have been a customer, what time of day they play, or whether they are VIPs?
  • Do you track customers across your different platforms and do enough to spot multiple customer accounts?
  • Is staff training on customer interaction meaningful and engaging?
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