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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.

Our position on identifying customers at risk of harm

We have concluded that there must be an absolute requirement for a set of core indicators that operators must use to identify harm or potential harm. We consider it important to set these core indicators across all operators in order to drive more consistent minimum standards across the industry. The core indicators which we have concluded should be set as a minimum standard are:

  • customer spend
  • patterns of spend
  • time spent gambling
  • gambling behaviour indicators 
  • customer-led contact 
  • use of gambling management tools
  • account indicators.

This list now includes ‘time spent gambling’. We have concluded that the time indicator should be included in the list of indicators which operators must use. At this stage, we have concluded that we should not list this indicator as a separate requirement, nor should we set specific time thresholds for different products at which operators would have to conduct assessments. Operators are therefore able to implement time indicators that are suitable for their business and customers, but they must include time as one of the indicators of harm that they use.

Following consultation, we have retained the proposed requirement that operators would be required to monitor customer accounts for signs of harm from the point of opening. As we have seen in our casework, it is possible for customers to experience harm shortly after opening an account and for this harm to be significant. It is not appropriate to wait until an operator has information about a customer’s typical behaviour in order to identify if an action is unusual for that customer. Instead, it is important that unusual and risky patterns of behaviour are identified from account opening and action taken if necessary. It is still appropriate to identify changes in behaviour and consider that a risk flag, but not to ignore other signs which are apparent in the meantime.

We have also concluded that the proposed strengthening to specify that operators have responsibility for monitoring for each of these indicators of harm is necessary. In proposal 3, we also discuss taking action in a timely manner. This applies even where they use a third-party provider to offer their customers gambling products/games. The operator must always understand a customer’s gambling position. It is not sufficient to only be aware when a customer returns from using gambling products/games with a third-party provider.

We maintain that operators must consider the factors which make a customer more vulnerable to experiencing gambling harms and implement systems which allow indicators of vulnerability which are identified by the operator to be acted on. We reiterate the approach set out in the consultation that when an operator identifies that a customer is in a vulnerable situation, they should be required to act on such information. As was proposed in the consultation, this does not mean that all customers would be required to be screened for vulnerabilities as this may be intrusive for customers and disproportionate.

It is critical that operators understand that the core indicators are the minimum standards which must be met. Our guidance, which will be published by early June in order to reflect any queries from industry on the requirements, provides more detail on these indicators and sub-categories which should be considered by operators.

We will explore the issue of identifying unaffordable gambling and customers at significant risk of financial harm further in a future consultation. This consultation will consider requirements that will tackle three key and significant risks - unaffordable binge gambling, significant unaffordable losses over time, and identifying customers who are in a particularly financially vulnerable situation. We will work closely with Government to ensure that the consultation proposals are set in the wider context of the Government’s Review of the Gambling Act 2005.

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Respondents’ views on identifying customers at risk of harm
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