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Consultation response

Remote customer interaction: Consultation Response

This response document sets out our conclusions and actions in relation to the consultation around remote customer interaction.

Respondents’ views on overall requirements and process

The majority of respondents to our consultation agreed with the proposed overall requirements and process for customer interaction. Many of these respondents had detailed comments about what needed to be in place to ensure that the process was effective.

A sizeable minority disagreed that the process was appropriate. Their reasons for disagreeing varied greatly. Many respondents focussed on the issue of affordability in their responses to this question, rather than on the overall approach.

The comments on this proposal included the following points:

  • this process is not effective and there should be stronger requirements on operators. Suggested requirements included assessing all customers before they begin gambling, putting in place limits for all customers, putting in place stake limits or deposit limits for all customers and banning all advertising
  • in theory this process would be effective, but it is not happening in practice. The process risks inconsistent application and requires effective scrutiny
  • an individual process is needed – not one-size fits all
  • operators are overcomplicating the process and not following key risks associated with spend
  • the weight of responsibility should be on the customer.

Whilst this question did not focus on affordability, many of the comments did focus on this issue:

  • the process (including considering affordability) is too intrusive and some considered it would be the end of betting and racing. Betting customers considered that this process was relevant only or mainly for casino or other online gaming
  • operators will use the excuse of protecting customers to restrict winning accounts for commercial reasons
  • this process, including accessing data, should apply only to those who have a history of losing, or other clear vulnerabilities. Leisure customers do not want to be bothered with this process; many customers consider that this does not apply to them
  • rather than ask the customer for data, the data should be accessed via credit reference systems.
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Consultation questions on overall requirements and process
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Our position on overall requirements and process
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