Consultation response
Changes to LCCP on ADR, CI and RET contributions
A summary of the responses to our consultations on changes to LCCP requirements for customer interaction and alternative dispute resolution (ADR) providers.
Contents
- Executive Summary
- Introduction
- Alternative dispute resolution
- Customer interaction
- Introduction
- Consultation proposal
- Proposed changes to Social responsibility code 3.4.1 (1a)
- Proposed changes to Social responsibility code 3.4.1 (1c)
- Proposed changes to Social responsibility code 3.4.1 (2)
- Our proposal to remove ordinary code 3.4.2
- Amended Social Responsibility Code 3.4.1 Customer Interaction
- Research, Prevention and Treatment contributions
- Appendix A: Amended social responsibility code of practice 6.1.1 – complaints and disputes
- Appendix B: Amended social responsibility code of practice 3.4.1 – customer interaction
- Appendix C: Amended social responsibility code of practice 3.1.1 – combatting problem gambling
What are the issues? Anonymity within premises-based gambling
Premises-based gambling presents different challenges and opportunities to online gambling. Offering gambling in person provides the opportunity to observe and engage with customers face to face. However, where gambling is not account-based it is more difficult to track consumer behaviour and provide gambling management tools to players. Most premises-based gambling can be undertaken anonymously.
Anonymity within premises-based gambling combined with the use of cash poses inherent challenges to identifying and acting on suspicious gambling activity. Even when identity is not a factor, we still see the challenge that premises-based environments such as casinos encounter, in delivering regulatory requirements when interacting with customers who are primarily engrossed in a social leisure activity. Operators must implement successful methods to engage to prevent harm and comply with preventative money laundering measures required in legislation.
The risk of harm in premises-based environments is linked to the number of staff working in those premises, as that determines the type and level of interaction that can take place with consumers.
Premises can be locations for crime, and we see examples such as violent or abusive behaviour toward staff or other customers, physical damage to the premises, money laundering and drug use or dealing.
Schemes such as Betwatch, a community-based crime prevention scheme between the Gambling Commission, the police, local council, and bookmakers, are designed to tackle localised anti-social and criminal behaviour in and around betting shops. Whilst these schemes have been successful in tacking some of these issues, they are not nationally nor industry wide.
GC action
We will continue to work closely with key regulatory partners to ensure gambling is fair, safe and crime free – including local licensing authorities.
GC action
We will continue to engage with premises-based gambling operators to deliver industry engagement and a programme of initiatives to raise standards informed by and complementary to our compliance and enforcement activity.
Coronavirus (COVID-19) has had a severe impact on premises-based gambling and the full impact of this on consumer behaviour is not yet known. As premises reopen and adapt to the new environment, there is an opportunity for land-based gambling to make a case for creative solutions to enhance their products and services in a way which goes hand in hand with enhanced consumer protections.
GC action
We will continue to challenge industry to implement consumer protections through a product design working group.
Last updated: 25 July 2024
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