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

Guidance

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

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

Published
20 June 2022

Last updated
23 August 2023 - Changes

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Contents

Section A - General requirements - Requirement 1

This current guidance was issued in August 2023 and is in effect from 31 October 2023. It replaces all earlier versions of guidance issued for remote gambling operators.

1. Licensees must implement effective customer interaction systems and processes in a way which minimises the risk of customers experiencing harms associated with gambling. These systems and processes must embed the three elements of customer interaction – identify, act and evaluate – and which reflect that customer interaction is an ongoing process as explained in the Commission’s guidance (see paragraph 2).

Aim

To set out the overall aim of the Customer Interaction requirements that licensees must have effective controls to minimise the risk of customers experiencing harms associated with gambling.

Formal guidance

1.1. The systems and processes must embed the three elements of customer interaction which reflect that customer interaction is an ongoing process.

Identify harm

This is an ongoing process of monitoring, using indicators of harm to flag signs that a customer may be at risk.

Act to minimise harm

Tailoring the action to the number of types of indicators of harm is critical. Review the indicators and escalate action in response to those indicators. In some cases, this will require automated action, in line with the requirements. Record the action or interaction taken. Continue to monitor and ramp up action where necessary.

Evaluate

To consider the effectiveness of the action taken and whether further action is required. Evaluation processes should be built in from the beginning – they are not an afterthought.

This means that licensees must build processes which include the need to identify risk, take appropriate action and evaluate the impact of that action, which then returns to further monitoring, identification, action and evaluation. This is not a one-off process but should be considered throughout the customer’s relationship with the licensee.

Additional guidance and information (not required to be taken into account)

The continuous and ongoing process outlined in the formal guidance can be visualised as follows:

A diagram showing a box to the left containing the words 'Identify', 'Act' and 'Evaluate'. An arrow, pointing to the right, is coming out of this box and is pointing at eight circles, all of which have words inside them, that have all been arranged in a larger circle to represent the continuous nature of this process. The eight circles contain the following words individually: 'Monitor', 'Identify', 'Auto measures', 'Review and Escalate', 'Interact and record', 'Continue to monitor', 'Ramp up action if necessary' and 'Evaluate'. From this circle of words an arrow is coming out pointing downwards to a box which contains the words 'Cease business relationship if necessary'.

Next section
Section A - General requirements - Requirement 2
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