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Customer interaction – Additional formal guidance for remote operators during COVID-19 outbreak

Social responsibility code provision 3.4.1 (From 31 October 2019) Customer interaction

All licences, except non-remote lottery, gaming machine technical, gambling software and host licences.

1. Licensees must interact with customers in a way which minimises the risk of customers experiencing harms associated with gambling. This must include:

  • identifying customers who may be at risk of or experiencing harms associated with gambling.
  • interacting with customers who may be at risk of or experiencing harms associated with gambling.
  • understanding the impact of the interaction on the customer, and the effectiveness of the Licensee’s actions and approach.

2. Licensees must take into account the Commission’s guidance on customer interaction. This guidance is issued further to the formal customer interaction guidance for remote operators of July 2019.

Due to the ongoing COVID-19 pandemic and associated lockdown, licensees should ensure they have the following measures implemented into their customer interaction framework for the purposes of preventing gambling related harm:

a)       Reviews of all thresholds and triggers used to track vulnerability to ensure that they reflect  changed financial circumstances that many consumers will be experiencing. An emphasis should be placed on those thresholds and triggers being proactively reset on a precautionary basis to ensure customers with emerging vulnerability, such as increased time spent at play or increased spend can be identified

b)      Specifically, review your time indicators to capture play in excess of 1 hour as this is a proxy for potential harm.

c)       Set additional or modify existing thresholds and triggers which are specific to new customers reflecting an operator’s lack of knowledge of that individual’s play and spend patterns.

d)      Implement processes that ensure the continual monitoring of your customer base, identifying customers whose patterns of play, spend or behaviours have changed in the last few weeks.

e)      Conduct affordability assessments for individuals picked up by existing or new thresholds and triggers which indicate consumers experiencing harm. Consider limiting or blocking further play until the checks have been concluded and supporting evidence obtained.

f)        Prevent reverse withdrawal options for customers until further notice.

g)       Stop bonus offers or promotions to customers displaying indicators of harm[1]

Knowing and identifying your customers at risk of or experiencing harm and acting early and quickly could help stop or prevent the harm worsening.

These measures will be kept under periodic review by the Commission and may be revised in response to changes in circumstance. 

[1] Part 2 of customer interaction guidance to remote operators July 2019