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CMS Gambling Conference 2020: Identifying and interacting with problem gamblers

Vanessa Whitman (Senior Associate at CMS) introduced the panel: Anna Hemmings (Chief Executive of GamCare), Lauren Hilton (Group Director of Regulatory Compliance at William Hill), Tanya Horgan (Group Chief Risk Officer of Flutter), Joanna Wilcox (Compliance Office at Spreadex), and Simo Dragicevic (Founder and CEO of BetBuddy). 

Vanessa kicked off the session by posing the question of whether identifying problem and at-risk gamblers is still a challenge, and if so whether it should be. Whilst the panel agreed that there were still difficulties in identifying harm, Anna commented that, rather than focusing on identifying problem gamblers, the industry needs to start looking at the spectrum of behaviours from the outset that are at its root. She explained that doing this – and signposting customers to the operator’s approach to harm prevention from the beginning of the customer journey - could help with customer engagement in response to interaction. The panel were also in agreement that the more specific interactions can be to a customer, the more effective they will be. 

Vanessa queried how much emphasis should be placed on non-financial indicators of harm. Simo outlined that whilst factors such as withdrawal and deposit amounts were always going to be crucial, other data – such as time on device, time of day, and types of games played – was also important in helping to build a holistic picture of how a player gambles and to add “layers of confidence” to classifications and predictions. 

The panel moved on to discuss how operators should deal with players that refuse to accept that they have a problem. Anna explained that one of the elements of any addiction is often denial, but that there is training that operators can give to staff members to help them deal with such issues. She also stressed that operators should know where their responsibility ends, with their duty being to ensure players are directed to sources for treatment, as opposed to treating addiction issues themselves. Joanna suggesting that closure of a customer account is always a last resort, but that ultimately there comes a time when the operator has to weigh up the regulatory risk of continuing a relationship with a player. Again the panel circled back to the theme of customising interactions, with Lauren commenting that it cannot be a “tick box” exercise and has to be a “true conversation and interaction with detailed signposting relevant to their behaviour and experience”. 

Vanessa then posed the question of whether there is an inherent conflict between the commercial value of VIPs and operators’ obligations to prevent harm. Describing this as an “absolute paradox”, Simo explained that it was an issue the industry needs to solve. He stressed the need for greater KYC and verification of players before they are placed on VIP schemes. Lauren meanwhile warned of the need to bear in mind that there is no one definition of a “VIP” and that has to be kept in mind, whilst Tanya commented that the industry needs to be clearer in its messaging that loyalty is being rewarded as opposed to increased gambling activity. 

The session ended with a discussion around the Gambling Commission’s view that one of the factors used in assessing operators’ approach to evaluating the effectiveness of their interactions, is the extent to which they are willing to share good practice with the industry. The panel agreed that there was appetite for the sharing of such know-how, but that it was something the industry had to date been poor at albeit not through a lack of willingness. 

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