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Vulnerability

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.

Following our consultation on customer interaction, Social Responsibility Code Provision 3.4.3 for remote gambling operators has been introduced and the majority of requirements are in effect from 12 September 2022. We issued this update on the regulatory requirements and status of formal guidance regarding customer interaction for remote gambling operators. The guidance issued in June 2022 under Social Responsibility Code Provision 3.4.3 is not in effect and is subject to further consultation. Operators are not required to take it into account.

Life events or changes to an individual customer’s circumstances may mean that a person becomes more or less vulnerable to experiencing gambling harms. Those circumstances could include bereavement, loss of income or other factors, as follows.

It will not always be obvious or clear to an operator when such events have occurred, but knowing your customers, and ensuring staff ask questions when there are potential signs of vulnerability, will help to determine whether those individual circumstances present an increased risk.

As part of ‘know your customer’ and developing customer interaction policies and procedures, operators should consider the factors that might make an individual more vulnerable to experiencing gambling related harm.

Factors include:

  • personal and demographic - if the individual is experiencing poor physical or mental health, physical or cognitive impairment, suffering side effects from a brain injury or medication or has an addiction
  • situational - if the individual is experiencing financial difficulties, is homeless, is suffering from domestic or financial abuse, has caring responsibilities, experiences a life change or sudden change in circumstances
  • behavioural - if an individual has a higher than standard level of trust or high appetite for risk
  • market-related - if an individual is engaged in an activity which is highly complex; that they have a lack of knowledge and/or experience of the market
  • access - if an individual has difficulty accessing information because of poor literacy or numeracy skills, knowledge, dyslexia.

We have seen examples through our casework of customers who should have received some interaction but did not, including customers who were particularly vulnerable, and more susceptible to experiencing gambling harms.

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Spotting harmful gambling

Last updated: 15 September 2022

Show updates to this content
  • Information in the callout at the beginning of the guidance page has been updated.
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