Making the case for safer gambling
Kirsty Caldwell, Founder and Director of Betsmart Consulting, discusses the challenges gambling businesses face in improving their approach to compliance and safer gambling.
As everyone connected to the industry knows, there have been huge improvements to safer gambling management in recent years. Whilst a lot of these changes have been driven by regulatory change, many have also been driven by businesses who recognise there is a genuine problem which needs to be addressed in the immediate term, if they are to enjoy sustainable growth in the longer term.
Collaboration is key
One area key to driving improvement is collaboration amongst all relevant stakeholders. This includes operators, charities, regulators, technical solution providers and problem gamblers themselves. Collaboration helps to define and develop best practice and also aids dissemination of the most effective approaches. It should be remembered that the industry’s ability to effectively manage safer gambling risk is only as strong as the weakest link and so it is imperative that best practice is shared and that smaller operators are brought along for the ride.
Certainly, the Gambling Commission is driving this approach through the tools it has at its disposal. These include the consistent inclusion of collaboration related questions in the Annual Assurance Statement process, the hosting of regular cross-industry discussion forums at its Birmingham offices and not least a direct call to action by Neil McArthur in his speech at Malta’s ARQ conference in October 2019, where he closed by stating:
“I hope all of you will engage with the opportunities to collaborate that I have just outlined….For those of you who want to get involved, we stand ready to work with you and others to make progress.”
The industry has reacted positively as a huge number of businesses invest time and money into gambling charity projects. To name just a few, GVC and GamCare, Lottoland and YGAM, Leo Vegas and Gambling Therapy. For their own part, charities have really embraced collaboration and are using the data and funding being provided by businesses to drive initiatives covering behavioural research, consumer education, information portals and staff training programmes.
Moreover, on top of the big five’s pledge to increase contributions for funding problem gambling research, education and treatment to £23m per annum by 2023, companies are increasingly financing academic research into gambling behaviours independently. A good example of this is GVC’s partnership with the Harvard Medical School’s Division on Addiction which seeks to evaluate the effectiveness of algorithms used to detect at-risk behaviours, assess the effectiveness of intervention messaging and the impact of safer gambling tools.
How can technology help?
In line with the industry’s increased focus on customer risk management, there has also been an explosion of software solutions appearing on the market, which are built to support the improvement efforts. These include; tools which help to assess customer affordability using Open Banking data; tools which assist operators in customer profiling; and tools which use data from a network of companies, to help them assess total affordability across multiple gambling accounts.
Selecting the right tools for your business
One of the difficulties businesses face, is how to decide which tool is appropriate for them to invest in, if indeed they need to do so at all. Each offering has its own strengths and businesses should first establish where their biggest weaknesses lie, to help them understand how they need to improve. This process requires in-depth analysis of current controls and the technology being used to help manage them, coupled with detailed evaluation of their effectiveness.
Whilst some third-party software providers will run trials for free, others will charge a relatively significant fee and so it is important to gather as much information about the tools as possible, to aid informed decision making and keep costs down.
Cost vs. compliance
Cost in general can still be an issue, particularly for smaller businesses who don’t have the same financial fire power or exposure to regulatory process as the bigger companies. In some cases, compliance teams are still challenged with changing the mindsets of commercially focused executives, some of whom believe that improved safer gambling management will result in sustained loss of revenue. Until the back of this problem has been broken, compliance professionals are fighting a losing battle as they will struggle to secure the funding needed to invest in appropriate tools, staff training and collaboration initiatives. They will also be met with resistance when looking to implement stricter internal controls. My approach to addressing this issue is two-fold:
- Firstly, you have to win internal respect. To do that you need to demonstrate that you know your product inside out, that you understand the compliance function exists to facilitate the business (not than the other way round) and that you are commercially focused, albeit your aim is to grow revenue in a responsible and compliant manner.
- Secondly, you need to drive home the message that compliance done well simply means giving the customer the best possible experience and ultimately, if you get this right, it is possible to eek long term financial benefit. Although citing commercial motivation may raise the odd eyebrow, coming from a compliance professional, it is genuinely the best way to get the business on board and listening to you.
Some examples of compliance done well are;
- ensuring the product works correctly;
- being up front and clear about betting rules and promotion terms;
- proactively gathering and reacting to customer feedback;
- detecting and correcting problems fairly and openly; and
- (of course) protecting and supporting customers at every stage of their journey.
Making the case for ‘good compliance’
I find that highlighting successes resulting from ‘good compliance’ works well in lobbying the revenue chasers. Examples include;
- presenting data which shows an increase in responsible gambling interactions directly correlates with a decrease in self-exclusion levels;
- showcasing positive customer feedback in response to an interaction;
- presenting data which shows an increase in the lifetime of average customer engagement, following improvements in safer gambling controls.
Where do we go from here?
Whilst improvements are clearly coming through the pipeline, for me a real silver bullet moment would be the ability / requirement for operators to share customer data across the whole sector and to use this data to help better inform safer gambling management.
As surveys have shown, the majority of customers hold active accounts with more than one business. Moreover, academic research has identified that players who are experiencing gambling-related harm are likely to use several accounts at any one time. Without understanding a customer’s activity across all of their accounts, it is very difficult for operators to accurately assess behaviour and affordability and to react accordingly.
Of course, there are a plethora of difficulties associated with the concept of data sharing and this is not something which can happen quickly or easily. However, despite facing a similar raft of problems, many different sectors have worked together to achieve effective data sharing which assists them with both business and consumer protection.
Note: There are a wide range of organisations that provide safer gambling guidance and services to industry, including GamCare. Articles published on this site do not indicate endorsement by GamCare of particular organisations or services. Find other organisations who offer social responsibility training to the gambling industry or download our Industry Services Brochure.
Collaborate and share
The Safer Gambling Standard assesses the extent to which a business collaborates with others in the area of safer gambling.