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.
Contents
- Summary
- Next steps
- Introduction
- Proposal 1 - Overall requirements and process
- Overall requirements and process
- Consultation questions on overall requirements and process
- Respondents’ views on overall requirements and process
- Our position on overall requirements and process
- Proposal 2 - Identifying customers at risk of harm
- Identifying customers at risk of harm
- Consultation questions on identifying customers at risk of harm
- Respondents’ views on identifying customers at risk of harm
- Our position on identifying customers at risk of harm
- Proposal 3 - Requirement to act
- Requirement to act
- Consultation questions on requirement to act
- Respondents’ views on requirement to act
- Our position on requirement to act
- Proposal 4 - Evaluation of effectiveness
- Evaluation of effectiveness
- Consultation questions on evaluation of effectiveness
- Respondents’ views on evaluation of effectiveness
- Our position on evaluation of effectiveness
- The LCCP provision
Respondents’ views on identifying customers at risk of harm
There was a wide range of views relating to assessments to identify unaffordable gambling. There were significant concerns about consumer privacy and freedom and calls for any such measures to therefore be targeted at the customers who are most at risk, and not general or what was often described as ‘leisure consumers’. Some stakeholders were strongly in favour of assessments to identify unaffordable gambling and called for the assessments to apply to all customers. We will explore these issues further in a future consultation which 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.
In relation to customers who may be in a vulnerable situation:
- a high proportion of respondents from the short survey agreed that operators should take action when aware of vulnerability. This was generally consistent across all respondent types - consumers, those employed in a gambling business, charities, and academics. Those who disagreed did so primarily for reasons relating to consumer privacy and freedom
- in the main consultation, views were more split on this topic. Overall, gamblers were split between agreeing and disagreeing with this proposal. Charities, affected others and academics generally agreed but were concerned that all consumers should be considered vulnerable to harm, not just one particular demographic. People who worked in a gambling business generally agreed with this proposal.
In relation to time, respondents to the consultation mainly disagreed that the Commission should set specific time indicators for different products, or that there should be a separate requirement for time as an indicator.
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Our position on identifying customers at risk of harm
Last updated: 14 April 2022
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