All UK gambling operators will be required to implement customer interaction processes in a way which minimises the risk of customers experiencing harms associated with gambling. Adam Doyle, Head of Gaming, explains how this can be done.
New regulation (released as Social Responsibility Code 3.4.3) is being brought into effect as of 12th September, providing operators with guidance on how to help identify and protect potentially vulnerable players and those gambling outside of their means. The guidance has been developed to support effective delivery of customer interaction systems and processes in order to identify and reduce harm.
The new code will be looking for operators to identify when there are:
- Indicators that a customer may be experiencing harm
- Acting early and quickly could help stop or prevent the harm worsening
- Spotting signs of harm and taking early action can be a preventative measure
- Designed to enable a customer to gamble safely
Alongside putting processes in place to identify signs of harm early, operators are required to be reactive. Providing support to a customer when harm is being experienced to reduce or stop gambling. To implement this effectively it is essential that harm is identified early and responded to quickly. As an operator, here’s what you need to know.
To meet out the overall aim of the Customer Interaction requirements, operators must have effective controls in place to minimise the risk of customers experiencing harms associated with gambling and create a safer customer experience.
This means that licensees must build processes to identify risk, take appropriate action and evaluate the impact of that action. This is not a one-off process but requires constant monitoring and evaluation throughout the customer’s relationship with the licensee.
How RiskNarrative™ can help
To summarise, operators will be required to ensure that there are effective systems and processes in place to monitor all customer activity and identify harm throughout the customer journey. They must maintain an oversight of customers gambling activity and provide assurance that the processes are effective.
When done manually, looking for a pattern of behaviour to emerge is timely and ultimately guesswork. TruNarrative is in a unique position to not only provide a single view of onboarding and affordability checks at account opening, but also continuous transaction and behavioural monitoring of a player.
Our single API platform has the ability to help you create and define rule sets to focus on and identify (as indicated in the guidance):
- Customer spend
- Patterns of spend
- Time spent gambling
- Gambling behaviour indicators
- Customer-led contact
- Use of gambling management tools, and
- Account indicators
All of the above core indicators can be built within the RiskNarrative™ platform to provide insight into potentially vulnerable players at all stages in the customer lifecycle. Helping operators identify customers who could require manual intervention and further support.
As this is the guidance that comes into force from 12th September, operators will need to act quick, and start integrating changes to their tech stack over the next 4 to weeks to be ready.
Get in touch or book a demo below to find out how we can help you comply with the new guidance.
Social Responsibility Code 3.4.31.
Licensees must implement effective customer interaction systems and processes in a way which minimises the risk of customers experiencing harms associated with gambling. These systems and processes must embed the three elements of customer interaction – identify, act and evaluate – and which reflect that customer interaction is an ongoing process as explained in the Commission’s guidance.2. Licensees must take into account the Commission’s guidance on customer interaction for remote licensees as published and revised from time to time (‘the Guidance’).
3. Licensees must consider the factors that might make a customer more vulnerable to experiencing gambling harms and implement systems and processes to take appropriate and timely action where indicators of vulnerability are identified. Licensees must take account of the Commission’s approach to vulnerability as set out in the Commission’s Guidance.
4. Licensees must have in place effective systems and processes to monitor customer activity to identify harm or potential harm associated with gambling, from the point when an account is opened.
5. Licensees must use a range of indicators relevant to their customer and the nature of the gambling facilities provided in order to identify harm or potential harm associated with gambling. These must include:
a. customer spend
b. patterns of spend
c. time spent gambling
d. gambling behaviour indicators
e. customer-led contact
f. use of gambling management tools, and
g. account indicators.
6. In accordance with SR Code Provision 1.1.2, licensees are responsible for ensuring compliance with the requirements. In particular, if the licensee contracts with third party business-to-business providers to offer any aspect of the licensee’s business related to the licensed activities, the licensee is responsible for ensuring that systems and processes are in place to monitor the activity on the account for each of the indicators in paragraph 5 (a-g) and in a timely way as set out in paragraphs 7 and 8.
7. A licensee’s systems and processes for customer interaction must flag indicators of risk of harm in a timely manner for manual intervention, and feed into automated processes as required by paragraph 11
8. Licensees must take appropriate action in a timely manner when they have identified the risk of harm.
9. Licensees must tailor the type of action they take based on the number and level of indicators of harm exhibited. This must include, but not be limited to, systems and processes which deliver:
a. tailored action at lower levels of indicators of harm which seeks to minimise future harm
b. increasing action where earlier stages have not had the impact required
c. strong or stronger action as the immediate next step in cases where that is appropriate, rather than increasing action gradually
d. reducing or preventing marketing or the take-up of new bonus offers where appropriate, and
e. ending the business relationship where necessary.
10. Licensees must prevent marketing and the take up of new bonus offers where strong indicators of harm, as defined within the licensee’s processes, have been identified.
11. Licensees must ensure that strong indicators of harm, as defined within the licensee’s processes, are acted on in a timely manner by implementing automated processes. Where such automated processes are applied, the licensee must manually review their operation in each individual customer’s case and the licensee must allow the customer the opportunity to contest any automated decision which affects them.
12. Licensees must implement processes to understand the impact of individual interactions and actions on a customer’s behaviour, the continued risk of harm and therefore whether and, if so, what further action is needed.
13. Licensees must take all reasonable steps to evaluate the effectiveness of their overall approach, for example by trialling and measuring impact, and be able to demonstrate to the Commission the outcomes of their evaluation.
14. Licensees must 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. For the avoidance of doubt, this provision is not intended to mandate the outcome of those customer interactions.