A 4 point plan
To harness technology and help reduce gambling harm
Read our CEO Richard Flint as he sets out a 4 point plan to harness technology and help reduce gambling harm at ICE Totally Gaming 2018.
"I want to talk today about how the online gambling sector can create a sustainable industry that is trusted by regulators, politicians, and above all, by our customers.
I want to say right at the start that there is no silver bullet to this, no one measure, no one company alone that can get us there. It will take sustained effort on a number of fronts - and commitment from all of us in the industry to work together to make that happen.
What’s more, I do not come here today to lecture you or claim that Sky Betting & Gaming is perfect. Like all companies, we do not always get everything right. But nonetheless, I believe the time has come for a mature conversation about where our industry is and where we should aim to be.
Public debate about gambling often reflects the wider themes of politics and public policy. Views on our sector have tended to fit neatly into one side or the other of the long-running argument between those who favour personal liberty and those who look to the state for protection.
And, like in the rest of our politics, the most vocal participants in the debate are usually the most extreme. So those you hear in the media either argue for heavy restrictions because they view any gambling as a bad thing, or for limited regulation because they believe people should be free to spend their money how they like.
Having spent nearly 20 years in the sector, it is clear to me that there is some truth on both sides. Many millions get great pleasure from gambling – you only need to go to a major race meeting, listen to football fans in the pub during a game, or follow the conversations around winning and losing bets on twitter on a Saturday night to see this.
But I have also met a number of people whose lives have been greatly harmed by gambling, and as an industry participant it is clear than we can and should do more to help the most vulnerable customers.
I want to propose today that the most fruitful and practical way forward lies between the two extremes – where individuals can exercise their free will subject to protections put in place to protect them from harm, and where the industry recognises, and indeed embraces, a role for good regulation and government intervention.
In order to do this the industry must first of all recognise that it has an issue. And I don’t just mean a PR or reputational issue. I mean a genuine, evidence based subject that it must play its part in addressing.
Every single operator, no matter what product or products they offer, no matter what demographic or demographic groups make up their customer base, and whatever processes or policies they have in place, have customers who experience gambling related harm.
Gambling related harm may, or may not be growing, but we know that some gamblers experience severe harm and that harm is not restricted to themselves but affects those close to them as well.
In the past our industry has also not done itself any favours, and I include Sky Betting & Gaming in this criticism, in its attitude towards harmful gambling. There have been encouraging signs recently that this is starting to change and we are finally moving away from the marginalisation of harmful gambling as an issue for a minority and the suggestion that the problem is with the individual rather than the product when in fact we know that behaviour is influenced by personal, structural and situational characteristics.
The major online players in Great Britain, including Sky Betting & Gaming, now need to build on this start and become part of the solution rather than part of that problem. And to do so we will need to work together and we need to support the work of regulators and government.
These issues and the policies that may remedy them have been complicated by the pervasiveness of technology, allowing people to gamble wherever they are, and the practicality of regulation in a connected, largely borderless world.
Technology has revolutionised the way our customers gamble. But the Gambling Commission is right to highlight how technology is yet to reach its full potential in keeping our customers safe. Online operators have a significant advantage over our land-based colleagues in this regard. Due to the account based nature of gambling with an online company we have more data about our customers than ever before. As an industry we must use this to ensure they gamble safely.
To do so I would like to suggest we adopt a four point plan to harness technology and customer data to help reduce harm:
- We must use customer data to understand player behaviour, and monitor for signs of harm;
- We have to promote safer gambling by improving the accessibility, awareness and understanding of self-help tools such as deposit limits and cool offs;
- We must interact with customers who show signs of harm, discuss their gambling behaviour with them, and present details of their behaviour clearly; and
- Finally, we will have to increase our interventions with customers to stop them harming themselves in the most extreme cases.
Yes this will lead to more difficult conversations with customers who don’t like their behaviour being challenged. And it will lead to greater lost revenues from customers who spend less than they otherwise would. We should also accept that in the fast moving world of technology, our industry won’t always get everything right, every time.
But it’s the best way to protect customers, the best way to minimise potential harm, and the best way to a sustainable industry.
Many individual operators are already trialling this type of approach in one way or another. And I believe there is a major role for the industry to play in discovering which markers of harm are most effective and in testing different models that identify potentially harmful behaviour.
In doing so we can help identify the most common signs that an individual may be gambling in a way that is out of control or beyond their means.
But I also believe that once the most effective ‘signs’ of such behaviour have been identified, the Gambling Commission should enshrine these specific markers into their licence conditions and codes of practice – not to stifle innovation or to stop progress, but to ensure that all UK licenced operators do certain things as an absolute minimum.
The most effective markers of harm that Sky Betting & Gaming currently look for in our customer data are multiple attempts at increasing deposit limits, multiple failed account deposits and a prolonged amount of time spent using a product. But if the evidence suggests that alternative factors lead to more accurate identification of harm then we will of course incorporate those into our processes.
This additional clarity and detail within the LCCP would ensure an industry-wide, consistent approach to the first two aspects of my four point action plan. But I also believe that eventually, the Gambling Commission should be much more prescriptive in its regulation of the actual interventions that follow the successful identification of a customer who may have problems with their gambling.
At the moment we use a combination of telephone calls, emails, SMS messaging, onsite and in app communication to our customers. Across all of these channels we may highlight a customer’s behaviour, nudge them towards the use of responsible gambling tools, signpost them to treatment and support, and generally check they are comfortable with their spending. In extreme cases we suspend or terminate customer accounts.
But the research regarding what a successful intervention looks like is limited. And guidance from the regulator is vague. Again, I believe the industry should play a role in helping to test different messages and interventions to customers. And this testing and research should then form the basis of additional clarity within the LCCP.
The Responsible Gambling Strategy Board and GambleAware research into markers of harm and successful interventions will form key pieces of evidence in both of these areas. And I hope that once new research is published and analysed by the industry it will lead to new and improved systems that are eventually captured within regulation.
But ultimately the only way to protect UK customers is for this to be regulated by the Gambling Commission. Once every operator is using a common, minimum set of markers of harm and has adopted a base level of approaches to intervening with customers who display potentially harmful behaviour we will have gone a long way to creating a sustainable industry that tackles problem gambling.
These measures together with the establishment and successful operation of GamStop – the one stop shop for self-exclusion – will provide a fair and consistent approach from all operators to those who may develop problems with their gambling.
The introduction of a statutory levy will provide an equally fair and consistent approach to the funding of research, education and treatment of problem and harmful gambling. Provided that this levy is based on the needs of the National Responsible Gambling Strategy and the funding is distributed to a variety of providers in a transparent and accountable manner, the industry should not fear its introduction but embrace it.
I also think we should listen to our customers and consider the establishment of an industry ombudsman, as is the case in most other regulated consumer industries. This would broaden the remit of the existing ADRs such as IBAS to deal with issues such as social responsibility, and act as a source of industry wide information on issues affecting consumers. It would ensure our customers got a fair and consistent deal if they ever do have complaints about all aspects of the service they receive from us.
Finally, we know that some people are worried about the volume of advertising on television. But any attempt to ban TV gambling ads would be self-defeating. If that were to happen, much of today’s advertising would simply move online – with non-regulated companies outside of UK jurisdiction and customer protections increasing their advertising presence and market share.
Instead we should continue with the current arrangements that ensure only regulated firms who take a responsible approach to what they are broadcasting can advertise on television.
At Sky Betting & Gaming, we are conscious of this. Last November, to coincide with our renewed sponsorship of the English Football League, we made a commitment that responsible gambling messages will appear on every club shirt. And this was accompanied by a very prominent TV and digital campaign, focusing on the Senet messaging ‘When The Fun Stops – Stop’.
We know from our own customer research that people value an operator that demonstrates a clear commitment to responsible gambling. And we also know from this research that this campaign has led to an uplift in awareness of our responsible gambling tools.
So my overall message I want people to take from today is clear: as an industry we have to listen to our opponents and to the general public, and start to own and address the issue of gambling-related harm.
We need to promote means for all customers to control their gambling behaviours; we need to interact more with our customers; we must intervene more effectively with those customers who find it difficult to control their own spend; and we will need greater regulation of the signs to look for and interventions expected of operators to ensure that this happens across the whole industry.
This can become the blueprint for global online gambling regulation, striking the balance between individual freedom, technological advancements, and the need to protect and defend the vulnerable. This is the only way we will reclaim public trust and ensure a sustainable and proud future for an industry that really does provide great pleasure and enjoyment for millions of adults in Great Britain."
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