National Strategic Assessment 2020
The person gambling - Identification of at-risk behaviours and vulnerability
Identifying customers at risk of, or experiencing harm, can be complex. It is true that each consumer is different, and licensees cannot – in isolation – be sure that an indicator of harm for one consumer is relevant to their circumstances. Some consumers respond negatively to interventions by licensees.
However, the reality is that it is simple to identify consumers that may be at risk of harm, based on ﬁnancial, time and behavioural indicators and applying knowledge about average consumers or what is already known about a particular consumer based on their behaviour and previous engagement with the licensee. Tailored interventions minimise the risk of alienating consumers.
There is a growing evidence base about patterns of play and behavioural indicators that are linked to risk. This knowledge is not consistently used to consider the position of a consumer and undertake proportionate customer interaction.
Often monitoring and oversight of customers to enable early identiﬁcation of changes in behaviour which may indicate a risk of harm are ineffective. Identifying at-risk behaviour and interacting effectively are central to harm prevention.
We will continue to support collaborative projects to understand how research can guide operator processes to raise standards in the real world. As an example, Gambling Research Exchange received funding from regulatory settlements to deliver research and knowledge exchange to support the National Strategy to Reduce Gambling Harms. In November, they began a trial project with a representative sample of gambling operators to share knowledge and learning about customer interaction approaches.
The prioritisation of commercial considerations over regulatory requirements in respect of managing High Value Customers (HVC) has been a recurring theme of our casework. We have found the use of incentivisation schemes as aggravating factors in circumstances where indicators of harmful play have been missed or overlooked. The pursuit of aggressive commercial outcomes using HVC schemes has also resulted in lax controls in preventing the acceptance of proceeds of crime.
HVC schemes should only be offered with rigorous oversight, clear senior accountability for their operation and outcomes, and should only serve those consumers for whom the licensee has undertaken thorough due diligence checks. That is why we recently strengthened the requirements around how these schemes operate.
We are implementing the outcome of the consultation strengthening requirements on how licensees manage high value customers (VIPs).
When consumers are in a vulnerable situation, they may be less able to understand the risks of gambling and the terms and conditions; consequently, they may be at higher risk of experiencing negative outcomes.
There are many reasons a person may be in a vulnerable situation and changes to an individual customer’s circumstances may mean that a person becomes more or less vulnerable to experiencing negative outcomes. A vulnerable situation can be permanent, temporary or intermittent, and may be related to health, capability, resilience, or the impact of a life event.
Those circumstances could include bereavement, loss of income or other factors. This information may not always be available to a licensee, but they should be ensuring staff ask questions when there are potential signs of vulnerability, to help to determine whether those individual circumstances present an increased risk.
Persons in vulnerable situations can face challenges when interacting with a range of ﬁnancial, digital or complex consumer products. The Financial Lives 2020 survey conducted by the Financial Conduct Authority (FCA) has found that just under half (46%) of UK adults, aged 18 and over display one or more characteristics of vulnerability.
The risk increases as more than one vulnerability characteristic is present and where those needs are not met. The Money and Mental Health Policy Institute (MMHPI) found that people with mental health problems are three and a half times more likely to be in problem debt.
When looking at gambling speciﬁcally, a recent report by the Money and Mental Health Policy Institute included ﬁndings from a survey of their research community of people with lived experience of mental health problems 16. This identiﬁed that a quarter (24%) of respondents have experienced ﬁnancial problems because of gambling online, and one in three (32%) have bet more than they could afford to lose.
Licensees are not consistently taking account of information that may indicate vulnerability which they receive as part of customer service, information about source of funds or in dealing with complaints. This means they are missing the opportunity to take account of vulnerability.
We will publish a statement setting out the principles and key areas of work in our approach to vulnerability.
The person gambling - GC action Next section
The person gambling - Engaged gamblers who participate in multiple products across different providers