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Where self-exclusion has expired

You should also take the same steps to prevent marketing to customers whose self-exclusion has expired but who are yet to make a positive decision to return to gambling.

Issues to be aware of and manage to prevent failures from occurring within your business

Operators who have sent marketing material to self-excluded customers in error have reported that this occurred for one or more of the following reasons:

  • individual members of staff using manual “workarounds” of systems designed to ensure that the accounts of self-excluded customers are excluded from e-mail and SMS marketing campaigns
  • members of staff not following policies and procedures
  • the recycling of old customer lists which had not been updated to remove the contact details of self-excluded customers
  • technical vulnerabilities in control systems
  • failures to clearly differentiate between those customers who had taken advantage of other gambling control tools (such as time-outs) and those who had self-excluded.

Operators have informed us that following incidents of this kind, they have taken steps to prevent a recurrence including:

  • addressing single point of failures (that is, parts of the relevant systems that, if they fail, will stop the entire system from working)
  • removing the ability for staff to use manual workarounds
  • introducing additional checks, controls and failsafe mechanisms.
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