Customer interaction guidance - for remote gambling licensees (Formal guidance under SR Code 3.4.3)
Section D - Evaluate - Requirement 12
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.
12. Licensees must implement processes to understand the impact of individual interactions and actions on a customer’s behaviour, the continued risk of harm and therefore whether and, if so, what further action is needed.
The aim is that licensees evaluate the impact of their interventions to determine whether further action is needed to minimise harm, and that the further action is delivered in a timely and effective manner.
12.1. This requirement means building in evaluation of the impact that the licensee’s action, has delivered. In this context, by impact we mean a change in the customer’s gambling activity which could be attributed to the interaction. This includes follow up interactions with monitoring of changes in play data including number of products used, spend, deposit patterns and more nuanced play patterns (such as chasing losses, increasing spin speeds and so on).
12.2. Not every customer who receives an interaction will require active follow up, but many will. In these cases, follow up activity should continue to be proportionate to the severity or extent of the harm being displayed.
As set out in requirement 9b of Social Responsibility (SR) Code Provision 3.4.3, if the interaction so far has not had the impact required, there is a need to increase the strength of action taken next.
12.3. Understanding the impact of the action on the customer includes being able to look at and compare:
- the indicators of harm and behaviour before the action
- whether the chosen action was customer-led or licensee-led
- how you acted and what was communicated to the customer
- the change in indicators of harm and behaviour following the action.
12.4. Some ways to work out that impact include:
- if your action was to set a limit on behalf of the customer, did the limit have the desired impact? Are there continued indicators of harm, and is further action needed?
- if your interaction was a call to action for the customer for example encouraging the use of gambling management tools, did the customer start using those tools in a manner that prevents or reduces harm? If not, is it necessary to set a limit on behalf of the customer?
- was there a positive change in behaviour? Did the customer’s gambling change after the interaction?
- are you content that protections are in place for customers that you are aware are in a vulnerable situation?
- is there a need for further or follow up action?
Section D - Evaluate - Requirement 13
Last updated: 23 August 2023
Show updates to this content
Guidance updated following the 'Remote customer interaction - consultation on guidance'.