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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 evaluation of effectiveness

We have concluded that the requirement to evaluate the impact of the individual actions on a customer’s behaviour remains appropriate and is indeed a fundamental part of customer interaction. It is necessary to assess whether there is continued risk of harm and if so, what further action is needed.

We have also concluded that the requirement to assess the overall effectiveness should be strengthened in line with the consultation. In order to be able to assess compliance, we have concluded that it must be a requirement on operators to maintain records of their evaluation and be able to provide evidence of such evaluation to the Commission.

Therefore, the proposed strengthening of these requirements to assess both the individual impact and the overall impact of the approach have been included in the LCCP requirements following the consultation. We have strengthened the requirement in both cases and expect operators to be able to demonstrate compliance.

Operators will be required to take account of problem gambling rates for the relevant gambling activity as published by the Commission, in order to check whether the number of customer interactions is, at a minimum, in line with this level. As the purpose of customer interaction is to identify customers at risk of harm, it is manifestly a failure if the numbers of customers being identified is lower than the problem gambling rates for the products. We recognise that some guidance will be helpful for operators to understand how to apply this requirement where there is more than one product and this will be addressed further in the accompanying guidance for operators. However, the requirement is clear - this is an absolute minimum requirement.

We have made clear, for the avoidance of doubt, that this provision is not intended to mandate the outcome of those customer interactions. The operator must tailor the action they apply to the nature and scale of the indicators of harm identified and/or the need to address continued risk with further action.

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Respondents’ views on evaluation of effectiveness
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