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Using the right indicators for your business

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.

Change compared with previous gambling activity is a general trigger for customer interaction. Building up your knowledge of your customers is key to helping you spot changes in their behaviour.

You should use a range of indicators based on research, experience and shared practice. The PWC remote gambling research (2017) identified some account and play indicators, but they are not a definitive list.

Your list should include the following.

Time and spend indicators

Amount and frequency of time and deposits, time of day (according to research (PWC 2017), a higher percentage of overnight gamblers were found to be problem gamblers, than during other times of day), increasing length of sessions or escalation in deposit levels, large losses.

Account indicators

Cancelled withdrawals, failed deposits, multiple or more expensive payment methods, pre-loaded cards and e-wallets which could indicate gambling with money the customer does not have.

Use of gambling management tools

Changing deposit limits, trying to ‘switch off’ the reverse withdrawal option to prevent re-staking prior to withdrawal, previous self-exclusions, frequent or repeated use of the time out facility or previous customer interactions.

Customer-led contact

Information or hints from customers, frequent complaints about not winning, requests for bonuses following losses, or talking about the negative impacts of their gambling.

Play indicators

chasing losses, erratic betting patterns, gambling on higher risk products or unusual markets or outcomes on which the customer is unlikely to have been able to make an informed choice. People who bet in-play may place a higher number of bets in a shorter time period than people who bet in other ways, as in-play betting offers more opportunities to bet.

Some studies have shown that placing a high number of in-play bets can be an indication that a customer is at an increased risk of harm from gambling.

A ‘big win’ or a windfall

Research (Parke and Parke 2017) shows high staking following a win could hide or even lead to harmful behaviour. Suddenly having more money than usual can lead to increasing staking, which can lead to harms not associated with wealth or resources.

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Understanding the impact of gambling harm
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Affordability and customer’s personal circumstances
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