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The importance of interacting with customers

We have requirements in our Licence Conditions and Codes of Practice (LCCP) which set out the minimum standards that we expect you to comply with.

Customer interaction

3.4.1 Customer interaction for premises-based operators

The following code is relevant to this section: LCCP: Social Responsibility (SR) Code Provision 3.4.1 - Premises-based customer interaction.

This requirement applies to customer interaction in premises-based gambling. The requirements originally came into effect in October 2019 and includes a requirement to take into account our guidance for gambling operators.

Customer interaction: formal guidance for premises-based operators.

3.4.2 Customer interaction for lotteries

The following code is relevant to this section: LCCP: Social Responsibility (SR) Code Provision 3.4.2 - Customer interaction – lotteries.

This requirement applies to lottery licences.

3.4.3 Customer Interaction for remote customer interaction

The following code is relevant to this section: LCCP: Social Responsibility (SR) Code Provision 3.4.3 - Remote customer interaction.

We published the outcome of our consultation on requirements for customer interaction in remote gambling in April 2022.

The majority of these requirements are in force from 12 September 2022. Paragraph 10 is in force from 12 February 2023. In Paragraph 1, the words ‘as explained in the Gambling Commission’s guidance (see paragraph 2)’; and the entirety of requirements 2 and 3 are in force from 31 October 2023.

In January 2023, we closed a consultation on proposed guidance relating to these new requirements (opens in new tab) which we proposed gambling operators would be required to take into account. The Commission has considered the responses received in relation to this consultation before making a fresh decision on guidance related to Social Responsibility (SR) Code Provision 3.4.3 – Remote customer interaction.

The Commission does not always consult on guidance. On this occasion, there was a specific opportunity to use the consultation exercise to explore recent experiences of stakeholders in the implementation of a set of new requirements and we hoped that there would be examples of good practice to share during the consultation period.

Following the consultation, the Commission has amended and updated the guidance and published it in August 2023. Remote gambling operators are required to take into account the following guidance from 31 October 2023.

Customer interaction guidance – for remote gambling licensees (Formal guidance under SR Code 3.4.3).

Previous formal customer interaction guidance for remote gambling operators was in effect from 31 October 2019, and additional formal guidance on customer interaction to remote gambling operators was issued on 12 May 2020. Both the previous formal guidance for remote gambling operators and the additional guidance ceased to be in effect from 11 September 2022 and operators are not required to take them into account.

Problem gambling rates by activity

Paragraph 14 of Social Responsibility (SR) Code Provision 3.4.3 requires licensees to take account of problem gambling rates for the relevant gambling activities, as published by the Commission, in order to check whether the number of customer interactions is, at a minimum, in line with this level. Those rates are as follows:

Problem gambling rates by activity
Gambling activity Problem gambler (according to the Problem Gambling Severity Index (PGSI) or DSM-IV1)
Lotteries and related products:
Other lotteries 1.3 percent
Machines and/or games:
Football pools 5.1 percent
Online gambling on slots, casino or bingo games 8.5 percent
Betting activities:
Online betting with a bookmaker 3.7 percent
Betting exchange 10.7 percent

Source: The percentage of people identified as problem gamblers (according to the Problem Gambling Severity Index (PGSI) or DSM-IV1) by individual gambling activities are set out in table 16 of the Health Survey for England 2018: Supplementary analysis on gambling (opens in a new tab). Note that table 16 covers all gambling activities, some of which are not relevant for the purposes of Social Responsibility Code Provision 3.4.3 (such as premises-based gambling).

Notes

1 The DSM-IV screening instrument is based on criteria from the fourth edition of the Diagnostic and Statistical Manual of the American Psychiatric Association (DSM-IV).

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