Advice to the Gambling Commission on actions to reduce online harms

This document includes discussions that the gambling committee is obliged to regulate online games more harmlessly. These hints are based on past instructions to reduce the harm of online games.

The table on the right contains the most important advice:

Summary of key recommendations

The Gambling Committee is obliged to see:

• Take a statement on the guarantee of a business in a public documen t-with the official circuit bond from the Gambling Committee.
• Space} Create a data lipfish.
• Space} Review Review Updat e-We have an interest in resources and adjustments so that a wider range of reviews works.

• Space｝ Requires the business operator to be more transparent for the layout used to identify the damage of the customer base.
• Space｝ Improve interest and resources to judge modern skills that apply data to identify damage.
• Space} Create the smallest stereotype based on advanced experiments.

• Use the intent of implementing a national strategy to ensure governance management and coordination, and evaluate a wider range of effective measures to prevent damage.
• Space｝ Include in a trial basis and evaluating measures not only in the hope that those who are actually damaged to restrict their gambling.
• Space} Create work devices by experienced experts to create effective events to prevent damage.
• Use the evaluation results that became available to improve the sel f-exclusion scheme of online moderation, and examine the possibility of providing additional type of support to those who are autonomously excluded.
• Considering the question of how the Gambling Committee has the ability to guarantee that the operator process and interactions are quite reliable for buyers who have returned their sel f-inquiries.
• Expansion of partnership with the cash provision department.
• Research with the government to get the opportunity to block ICHAH to suppress illegal online gambling.

• Space｝ Improve the recognition of these products, games and harm.
• Prohibit the introduction of credit cards to online gambling, monitor the results carefully, understand and alleviate unexpected results.
• Space} We will investigate customers more effectively and investigate the necessary information on products and risks.
• Prohibit the drawer of working funds.
• Implement subsequent tough enforcement measures and measures to increase operators' responsibility towards their customers in order to change the industry's culture towards greater responsibility in order to make gambling safer.

• Schemes such as limits on bets, winnings and game speeds may be introduced for online gambling.
• If operators do not show significant progress in protecting players, work with the government to introduce limits on bets, prices and the speed of online play.

• Exploring possible technological solutions to reduce the impact on children and vulnerable groups.
• Advocates of prudent regulation: there is sufficient evidence to justify it, particularly in relation to children and vulnerable groups.

Introduction: Advice to the Gambling Commission on actions to reduce online harms

We recently advised the Gambling Commission on the government's White Paper on reducing harms on the Internet. The advice gives reasons in support of the fact that, as part of the work carried out following the publication of "Snow White", gambling-related harms should be explicitly recognised, in particular issues relating to:

• Online marketing and advertising - the nature and extent of their impact, particularly on children and young people
• Loot, skins and gambling in public casinos
• On the general link with gambling in e-sports culture.

These councils dealt with issues that were not typically the responsibility of the Gaming Commission. In drafting the published opinion, we outlined some next steps that the Gambling Commission could take within its own sphere of responsibility to make online gambling more harmless.

Recommendations

Our best tips are grouped in the upcoming sections:

• Transparency and Evaluation
• Harm Identification
• Effective Interventions
• Game Design and Product Features
• Marketing and Advertising
• Bet, Winnings and Game Speed ​​Limits.

Transparency and evaluation

Fundamental to all our agreements is the need:

• Improved transparency is required from all operators, both remote and land-based.
• To more effectively evaluate all possible mitigation scenarios.

This data should be used to focus future regulator requests on those that will actually work.

Achieving this goal could lead to increased accountability and awareness, and even more effective harm reduction.

The Gambling Committee is currently calling a business operator to submit a warranty card 1. 1 These documents describe efforts for businesses to ensure consumer safety. Currently, these documents are confidential documents, and businesses are usually gambling or verbal feedback. ABSG recommends publishing these documents to ensure higher transparency and accountability. In addition, in order to increase the accountability of business operators for each year's improvement and create more clear audit trails, we recommend feedback in writing. We are aware that this change is difficult, but we are convinced that the following steps needed to increase operator's transparency and accountability and as a result.

We support the development of obligatory data lies to make more widespread and more independent researchers on online gambling. This encourages more independent research, reduces the number of advanced data demands from businesses, and increases the number of pools for gamblin g-related research.

As mentioned in the proposal 2 to the National Strategy, it is necessary to update the existing evaluation protocol 3.

Detection of harms

We have previously improved how business operators use data to identify harmful play, and how to use them as the basis of intervening to reduce damage to players. I have been looking for. 4 While many businesses claim that they use sophisticated data analysis technology, we are the core of many businesses, the core of many businesses, and themselves. We are concerned that it does not reflect the fact that not only the excluded player but also the much more harmful player is harmful. < SPAN> The Gambling Committee is currently calling a business operator to submit a warranty card 1. 1 These documents include initiatives to ensure consumer safety. Currently, these documents are confidential documents, and businesses are usually gambling or verbal feedback. ABSG recommends publishing these documents to ensure higher transparency and accountability. In addition, in order to increase the accountability of business operators for each year's improvement and create more clear audit trails, we recommend providing writing feedback. We are aware that this change is difficult, but we are convinced that the following steps needed to increase operator's transparency and accountability and as a result.

We support the development of obligatory data lies to make more widespread and more independent researchers on online gambling. This encourages more independent research, reduces the number of advanced data demands from businesses, and increases the number of pools for gamblin g-related research.

As mentioned in the proposal 2 to the National Strategy, it is necessary to update the existing evaluation protocol 3.

We have previously improved how business operators use data to identify harmful play, and how to use them as the basis of intervening to reduce damage to players. I have been looking for. 4 While many businesses claim that they use sophisticated data analysis technology, we are the core of many businesses, the core of many businesses, and themselves. We are concerned that it does not reflect the fact that not only the excluded player but also the much more harmful player is harmful. The Gambling Committee is currently calling a business operator to submit a warranty card 1. 1 These documents describe efforts for businesses to ensure consumer safety. Currently, these documents are confidential documents, and businesses are usually gambling or verbal feedback. ABSG recommends publishing these documents to ensure higher transparency and accountability. In addition, in order to increase the accountability of business operators for each year's improvement and create more clear audit trails, we recommend feedback in writing. We are aware that this change is difficult, but we are convinced that the following steps needed to increase operator's transparency and accountability and as a result.

Effective interventions

We support the development of obligatory data lies to make more widespread and more independent researchers on online gambling. This encourages more independent research, reduces the number of advanced data demands from businesses, and increases the number of pools for gamblin g-related research.

As mentioned in the proposal 2 to the National Strategy, it is necessary to update the existing evaluation protocol 3.

We have previously improved how business operators use data to identify harmful play, and how to use them as the basis of intervening to reduce damage to players. I have been looking for. 4 While many businesses claim that they use sophisticated data analysis technology, we are the core of many businesses, the core of many businesses, and themselves. We are concerned that it does not reflect the fact that not only the excluded player but also the much more harmful player is harmful.

Operators should use their own data to target interventions to a broader range of players who may be harmed. The first testing process should be considered only as a starting point for subsequent interactions. Buyers are likely to be vulnerable to a variety of moments and events. The threshold meaning or trigger does not need to be so high, otherwise almost all players likely to be harmed will not notice early enough. The second testing period, with more intensive interactions with buyers, should aim to understand players better than any other period and take appropriate action. The Gaming Commission's work on affordability is important to ensure that it focuses on those who will be harmed and to reach those who spend amounts that may not be immediately apparent, but are at least likely to be harmful to many players.

We recommend that operators be required to publish their own rules and procedures for identifying harmful play. They should also be required to publish their own protocols for how subsequent customer interactions and interventions will be conducted in response to these triggers. The scientific data and methods that operators create are generally treated as paid mental property. This situation needs to change. Greater transparency would undoubtedly help operators learn from each other and develop a broader data set on what constitutes high skill and what methods for detecting bad gaming are considered effective and legitimate.

The Gambling Commission has a responsibility to take a leading role in how data is used to determine damages. As data availability is considered to be the main argument for not using restrictions on bets, winnings and speed of play, 5 we recommend that the Gambling Commission take a closer look at how this data is used with a view to identifying the least stereotypes based on avant-garde practices. This may require the recruitment of personnel with special abilities and skills.

Game design and product characteristics

We are still excited that the measures used in practice after operators have found buyers who may be at risk of harm are low-intensity and low-rated, and do not provide confidence in their performance. We welcome the work carried out under the Gambling Commission's research program and commissioned by Gambleauare to test and evaluate measures to prevent online harm. This includes a randomized controlled trial conducted by Behavioral Research (Bit) with three major online operators. 66 In the IT field, cooperation plans between realites, bit and another eight operators (including online and offline gambling) are emerging. 7 These are positive steps forward, especially due to the fact that they fully link deliberate interventions with reliable scores for evaluation. However, we would like to note that in these events the focus is still on buyers themselves changing their behavior. Harm can manifest at different levels of role in gambling, 8 and at the very difficult end of this spectrum, there is every possibility of being compulsive, such as causing loans. In such a life environment, relying on the fact that the person himself will change his behavior is unlikely to work. Therefore, we advise the Gaming Commission to encourage operators to participate in the test and evaluate a wider range of intervention events. In that number, the layout-out is necessary to enter, not relying on such that the buyer experiencing harm will be responsible for limiting his own behavior. Coordination is important. In our instructions on the national strategy, it is emphasized that the main lesson learned from the previous strategy was that in fact a very large number wanted for "Let a thousand flowers bloom", and in the future it will be more coordinated and managed. 9 The layout-out of operators in the reduction of harm has still been placed on a one-off disposal and literally not evaluated. The project placed a while ago to implement the national strategy to reduce gambling harm provides a perfect basis for coordinating actions to develop and evaluate more effective measures to increase gambling safety. 10 However, strong instructions and motivated personnel are needed to move this forward quickly.

Developing effective interventions requires the input of experts with lived experience. The Gambling Commission and its partners in the National Strategy to Reduce Gambling Harm should explore how expertise is used in other areas of public health and take steps to apply this to gambling. We are pleased to be working with the Scottish Health and Social Care Alliance. We look forward to participating in the development of a wider network that will include experienced experts from across England and Wales.

Online operator self-exclusion schemes have been available as multi-vendor schemes since April 2018, but the Gamstop scheme has been delayed and the Gambling Commission has not yet provided sufficient assurances to make participation mandatory for all online operators. 11 More encouragingly, an evaluation is currently underway, including a survey of service users, to understand the experiences and impacts of the scheme after its introduction. This will provide a useful scientific basis for future improvements. We recognise that self-exclusion tools alone will not be sufficient for many users and welcome suggestions from practitioners suggesting additional support that could be provided in parallel. We encourage these ideas to be explored and tested to better understand their potential for harm reduction. Customers who return after self-exclusion should already be considered a high-risk group for operators. The Gaming Commission should consider how to ensure that operators' processes and interactions with customers are sufficiently robust in these circumstances. Ideally, operators should be able to offer longer self-exclusion periods. For some people, this may include lifelong self-exclusion. However, we acknowledge that there are practical and legal challenges to achieving this goal. Naarmat

The cash offer section is considered a necessary part of the gambling ecosystem. We encourage the Gambling Commission to explore the possibility of expanding partnerships with cash offer providers to strengthen defenses and reduce harm. Further work is needed to develop the promising initial opportunities created by banks proposing to block gambling transactions. 12 For example, with the introduction of debit cards to current accounts, gambling restrictions may still well help reduce harm for people in difficult economic situations. The economic section has the opportunity to offer other conclusions and innovations to reduce gambling harm.

We also note that the Gambling Commission often takes steps to prevent unlicensed gambling websites from operating with customers in the UK. Blocking IPs could freeze valuable additional facilities. We advise the Gambling Commission to work with the government to explore the possibility of giving such powers to the Commission with the ability to effectively request updates to the law.

Marketing and advertising

Further work needs to be done to understand how game design and game mechanics have the potential to promote or reduce harmful gambling. We understand that remote gambling networks are working in real time on things that no one else can understand. We encourage the Gambling Commission to closely monitor this work and ensure that it provides truthful and accurate information about measures taken to reduce harmful gambling.

Gambling products are becoming increasingly complex. 13 As a result, for example, when placing bets with "live odds", which generally focus on high-difficulty actions and have high upsides for operators, it is likely that purchasers have difficulty understanding the product they are using and the chances of winning or losing. 14 The Gambling Commission should take steps to ensure that consumers have better and more accessible information. To do so, it may be necessary to change the alignment. There is a groundbreaking initiative at the US Food and Drug Administration, which instead uses "consumer misunderstanding audits" to test how consumers know important facts about the products they buy, and then disparages what information they should be provided with. 15 More than any other scheme, this scheme is designed to harness the creative capacity of the industry to communicate important ideas to players, rather than imposing what regulators think should be included.

In addition to games design and mechanism, there are a number of effective means to change the method of providing products to consumers. Welcome the gambling committee consultation on the ban on the use of credit cards in online gambling. As mentioned in the previous recommendations, gambling with the borrowed funds is a risk of gambling harmful effects, so the use of credit cards can cause concerns. We understand the need to carefully monitor the implementation, taking into account unexpected situations, such as making loans for Sarah gold and illegal credit companies. However, if you can gamble with a credit card, you will be able to easily spend expenses beyond your tolerance. Some consumers may be able to avoid such prohibited measures, but it is beneficial for many consumers to have extra friction.

We welcome the commitment of the Gambling Committee's business plan on the 2019/2 0-year Gambling Committee's business plan to consider the problem of funding (canceling funds and continuing the game). In a previous proposal on online adventure games, it established a view that consumers should be as easy as withdrawing funds from the game account and depositing. 17 If withdrawal is too long, or a marketing offer that consumers encourages withdrawal can prevent consumers from deciding to end the game. Despite the change in the personality test process, you can make more money to make it easier for consumers to withdraw. This service is only needed for consumers for a long period of time to access funds, and we believe that reversal of funds is the best solution for consumers. Not. We recommend that this service is prohibited. By doing so, competition pressure is born, you have to speed up the process of withdrawing funds, eliminating one of the moment when consumers may suffer. In addition to the

In fact, the civilization of the online gambling industry needs to change in terms of layout of the provided product. As an example, two online operators have recently announced a new "innovation" that allows customers to play two online gambling products at the same time by supporting the screen split function. 18 This possibility cannot be justified from a cautious approach to ensure gambling safety and protect players from harm. We recommend that the gaming committee will investigate this issue, but we recommend that businesses will consider how to change the culture that considers the introduction of similar proposals to be appropriate. The subsequent crackdown on crackdowns and the regulation of "attention" have the potential for business operators to take customer welfare more seriously.

Stake, prize, and speed of play limits

In our opinion, gambling advertisements do not need to be seen in places that many people see. Recent studies have confirmed that gambling marketing has increased and expanded to children. 19 In addition, during the avatar test, ASA confirmed some evidence that children would be more likely to browse gambling ads on children's websites. 20

Businesses, governments, and regulatory authorities are in a suitable position to provide support work to explore the potential of technical knowledge to reduce the effects of gambling ads under the age of 18. For example, it may be accompanied by a marketing technology that actively excludes a specific online profile from a gambling ad. 21 In addition, it may indicate a precedent for households using shared devices such as laptops and tablets. For this reason, operators need to pay more attention when displaying gambling ads.

Conclusions

The issues related to online marketing and advertising encourage not only children, but also to strengthen support for adults who are vulnerable to gambling harm. The technical conclusion is that online marketing has previously found these definitions as "Where can we receive gambling dilemma support?" Or "How can we exclude yourself?" It may also include the operator more aggressively to what to not touch. These definitions or similar definitions must be shown during searching that they are not suitable for advertising purposes.

The actual gambling at midnight is recognized as associated with harmful gambling. 22 In consideration of this, we advise the operator to support the online marketing at this stage and lay out the buyers. Apart from this, gambling is worried about something like learning to participate, or marketing that fuels a sense of crisis. Not paying attention to the fact that specific measures have been taken to limit these reports, 23 are still associated with the marketing of gambling online games. twenty four

We are just one of some of the departments in charge of adaptation and legislation in the field of marketing and advertising, and we have no ability to work alone to provide advice we proposed. I claim. At least, marketing and advertising will have an influence and functional role in spreading cautious policies about the impact of children and vulnerable people. However, research has not yet established a direct causal relationship between marketing and harm, which can actually speak about the attitude and behavior of the people, which is actually harmful. It has the potential to cause. We advise gaming commissions to look more cautious and aggressive layout approval methods to reduce harm in this field.

Footnotes

Internet gambling is more likely to increase the risk of harm than offline gambling games. In online games, there is no limit to the limit rate, price, and play speed. This situation is clearly different from such products in land facilities. The difficulty of accessing the restrictions can be explained by the fact that online operators predict their games using data on their customers and take important measures. 25 < Span> The actual gambling at midnight is recognized as associated with harmful gambling. 22 In consideration of this, we advise the operator to support the online marketing at this stage and lay out the buyers. Apart from this, gambling is worried about something like learning to participate, or marketing that fuels a sense of crisis. Not paying attention to the fact that specific measures have been taken to limit these reports, 23 are still associated with the marketing of gambling online games. twenty four

We are just one of some of the departments in charge of adaptation and legislation in the field of marketing and advertising, and we have no ability to work alone to provide advice we proposed. I claim. At least, marketing and advertising will have an influence and functional role in spreading cautious policies about the impact of children and vulnerable people. However, research has not yet established a direct causal relationship between marketing and harm, which can actually speak about the attitude and behavior of the people, which is actually harmful. It has the potential to cause. We advise gaming commissions to look more cautious and aggressive layout approval methods to reduce harm in this field.

Internet gambling is more likely to increase the risk of harm than offline gambling games. In online games, there is no limit to the limit rate, price, and play speed. This situation is clearly different from such products in land facilities. The difficulty of accessing the restrictions can be explained by the fact that online operators predict their games using data on their customers and take important measures. 25 The actual gambling at midnight is recognized as associated with harmful gambling. 22 In consideration of this, we advise the operator to support the online marketing at this stage and lay out the buyers. Apart from this, gambling is worried about something like learning to participate, or marketing that fuels a sense of crisis. Not paying attention to the fact that specific measures have been taken to limit these reports, 23 are still associated with the marketing of gambling online games. twenty four

We are just one of some of the departments in charge of adaptation and legislation in the field of marketing and advertising, and we have no ability to work alone to provide advice we proposed. I claim. At least, marketing and advertising will have an influence and functional role in spreading cautious policies about the impact of children and vulnerable people. However, research has not yet established a direct causal relationship between marketing and harm, which can actually speak about the attitude and behavior of the people, which is actually harmful. It has the potential to cause. We advise gaming commissions to look more cautious and aggressive layout approval methods to reduce harm in this field.

Internet gambling is more likely to increase the risk of harm than offline gambling games. In online games, there is no limit to the limit rate, price, and play speed. This situation is clearly different from such products in land facilities. The difficulty of accessing the restrictions can be explained by the fact that online operators predict their games using data on their customers and take important measures. twenty five

With the use of data, operators can control and track the game. At least in the logic, this is a certain guarantee, but we don't know what is being done to reduce the risk of damage. I think this is a question that questions the current mechanism stability. We recommend to the Gambling Committee to plan to introduce a system for gambling restrictions, prices, and play speeds to online gambling. If a significant improvement of player protection has not been achieved while implementing a national strategy to reduce gambling harm, the Gambling Committee will introduce these changes along with the Digital Technology, Culture, Media and Sports (DCMS). Recommended.

We made many proposals to reduce the harm of online gambling. Many of them require gambling operators to improve transparency and change the culture at all levels to protect consumers from harm from harm. The next beneficial step is to consider the expected effects of (a) data on (a) the size and nature of the harm to eliminate (a) by collaborating with the gambling committee. I think it is to prioritize these proposals. This is to consider our proposals, along with other stakeholders, mainly experienced experts.

We acknowledge that the field of online gambling is changing rapidly. Effective Horse scanning is important to identify and eliminate new risks. The possibility of cooperation with the Gambling Committee with the digital technology consultation group is a welcome that offers valuable opportunities to contribute to the identification of new risks.

Advisory committee on safe gambling

Gambling committee's website, one statement about guarantee. Currently, it is applied only to about 40 major "hig h-level operators".

2 Responsible Gambling Strategy of Harm from Harms for 2019-2022 ON Responsive Gambling's Responsive Gambling Strategy On the Internet on the Internet, RGSB, APRIL 2018.

3 Evaluation protocol (open on a new tab), Responsive Gambling Strategy Committee, April 2016

4 Responsible Gambling Strategy Board Opinion on the National Gambling Harm Reduction Strategy 2019-2022 (RGSB, February 2019) and Responsible Gambling Strategy Board Opinion on Online Gaming (RGSB, April 2018).

5 See below.

7 Remote Gambling Inquiry, Phase 2 Interim Report, Revealing Reality, August 2017.

8 Measuring gambling-related harm, a framework for action, Wardle et al, July 2018.

9 Responsible Gambling Strategy Council Recommendations on the National Gambling Harm Reduction Strategy 2019-2022, RGSB, February 2019.

10 The Gambling Commission has published a National Gambling Harm Reduction Strategy Action Map, a microsite National Strategy.

11 We acknowledge that the Gambling Commission continues to monitor this situation closely and provide feedback to shape this framework.

12 Blocking gambling transactions from Monzo accounts, Monzo website, July 2018. Barclays allows customers to block gambling transactions, Money Saving Experts website, December 2018.

13 The complexities of UK gambling advertising behaviour, Newall, February 2017.

14 Live-odds Gambling Advertising and Consumer Protection, Newall, Thobhani, Walasek, Meyer, PLOS One, June 2019.

15 Time for mandatory disclosure?, Insight, FCA, March 2019.

16 Responsible Gambling Strategy Committee opinion on online gaming, RGSB, April 2018.