Following Neil McArthur’s breakfast briefing in October 2019, the Gambling Commission established three industry working groups, each focusing on a different challenge identified by the Commission with the aim of making gambling safer.
The working groups, which include over 30 operators, looked at VIP incentives, advertising technology and safer game design, and have now agreed to a set of actions in respect of each group. On 1 April, the Commission published details of these actions, as summarised below.
Use of VIP incentives
Considering the treatment and incentivisation of high value and high spending customers, known as VIPs, the industry agreed to:
- restrict customers who are under 25 from being recruited to high value customer schemes;
- ensure that, before becoming VIPs, customers pass full checks relating to spend, safer gambling and enhanced due diligence; and
- maintain full audit trails for high value customer schemes, including detailing decision making with senior oversight and accountability.
To reflect these changes, the Commission will now consult on making permanent changes to the Licence Conditions and Codes of Practice. In the meantime, and at the request of the Commission, the working group’s industry code around VIPs will be implemented by operators within three months.
Safer advertising online
The group which was looking at advertising technology agreed on a set of actions which will be adopted as soon as possible, and enshrined in the Industry Group for Responsible Gambling’s ‘Gambling Industry Code for Socially Responsible Advertising’ and effective by July 2020. These actions include:
- creating a common list of negative search terms (e.g. how do I self-exclude from gambling?), which will help shield vulnerable groups from online gambling ads;
- using customer data more consistently to ensure paid-for-ads are targeted away from vulnerable groups across social media platforms;
- only advertising to over 25s, in respect of social media and “Pay Per Click” advertising, where platforms cater for such targeting;
- age-gating YouTube channels and content; and
- implementing a code of conduct aimed at affiliates to ensure the agreed measures are similarly adopted by affiliates.
In addition, the group will establish a permanent cross-industry Adtech Forum which will aim to make further progress in this area.
The third working group was tasked with creating an industry code focusing on game design, which will be published in September 2020. So far, the industry has committed to:
- implementing a minimum spin speed of 2.5 seconds on all slots; and
- removing (i) game features that may encourage intensive play, such as turbo buttons, and (ii) split screens, which have been associated with a loss of control.
The group also plans to consider in-game messaging and the creation of a Betting and Gaming Council Testing Lab to look into other game features.
The Commission acknowledged that whilst some progress had been made in this area, further work was needed.
In respect of the working groups generally, Neil McArthur stressed the importance of implementing these commitments as soon as possible, making the point that it shouldn’t take months to enact safeguards that should already be in place. Finally, he warned that operators that do not put consumer safety first will be targets for enforcement action.
This is a swift and commendable first output from these working groups and validates the Commission’s initiative to collaborate with the industry.