The Gambling Commission’s Acting Joint Chief Executive Sarah Gardner has today (20 May 2021) delivered a speech entitled “Reducing risks, tackling harms” at the Shard Financial Vulnerability Summit 2021, focusing on the Commission’s work to tackle vulnerability and gambling harm. You can download her speech below.
Points of note include the following.
1. Problem gambling rates
Referring to the Commission’s latest participation and problem gambling prevalence data for the year to March 2021 (that includes the first full set of yearly data since the start of the COVID-19 pandemic), Sarah Gardner said:
…. great care needs to be taken with any analysis. The year has seen differing states of lockdown and different availability of gambling products. That said the figures still require attention:
- …. they state that the overall population problem gambling rate is 0.4%. This is however down from 0.6% the previous year.
- Further to this the figures for the moderate risk rate and low risk rate are also down. From 1.5% to 0.6% and 2.7% to 1.9% respectively.
While the drop in the problem gambling rate is not significant at the 95% level that we demand, the drop in moderate and low risk gambling is. In addition, if looking at the longer term trend over the last five years, the data shows a clear reduction in the rate of at risk gamblers and also suggests that we may be starting to see a decline in the overall rate of problem gambling. This does not mean we will take our foot off the accelerator when it comes to protecting consumers – instead it should be seen as an opportunity to continue building momentum in our efforts to make gambling safer.
Commenting on the Commission’s Remote Customer Interaction Consultation and Call for Evidence (including in relation to affordability thresholds), she:
- acknowledged the “need to strike an appropriate balance between consumer protection and concerns about privacy and consumer choice” and
- implied that the Commission’s initial focus will be on cases where customer interaction failings relate to plainly obvious unaffordable gambling activity by customers, saying:
A consultation and call for evidence that closed earlier this year on how online gambling companies identify and intervene with customers suffering or at-risk of harm will also see us take further action to reduce the risk of gambling harms, particularly for customers who are vulnerable. There was a huge response to this call for evidence, with over thirteen thousand responses. It is of course a controversial and complex area and we need to strike an appropriate balance between consumer protection and concerns about privacy and consumer choice. Such a volume of responses will take time to process. But this will not stop us dealing with levels of harm that are clearly well beyond any border line of acceptable risk.
Our live casework makes this clear. In far too many of our compliance assessments we still find failings relating to customer interaction and affordability.
You can also look at the casework examples in last year’s Compliance and Enforcement Report. Such as the online casino customer who, in one gaming session lasting over 7 hours, amassed losses of £16,500 and the only interaction during this time was to ask the customer to conﬁrm a new card to make sure the payment was theirs. Then in another 7 hour session there were no interactions made at all with that customer. No one can tell me that is a border line case.
That means we will be taking the next steps towards introducing requirements on operators to take action at more appropriate levels. Our immediate action will be focussed on preventing the types of cases we still see too much of in our casework. In particular this will tackle where operators have allowed people to gamble amounts that are clearly unaffordable, with very limited or no customer interaction until a very late stage; we will act to prevent harm to those who are financially vulnerable.
She also spoke about progress of the ‘Single Customer View’ initiative, often regarded as the ‘silver bullet’ required to solve the affordability conundrum, stating:
Currently no gambling operator has a full picture of a customer’s gambling. We recognise this increases the challenge of keeping a customer safe where operators currently only have a partial view of a customer’s behaviour. A Single Customer View would give operators a full picture of a customer’s risk of harm whilst keeping the customer’s data secure. A Single Customer View could dramatically help reduce harm and that is why we will not accept progress at the pace of the slowest on this work.
This project is also an excellent demonstration of collaboration to protect people and reduce risk. We are working closely with the Information Commissioner’s Office to make sure the project will protect consumers data. Following the ICO’s work to establish a legal basis for the project and ensure consumers’ data is protected and secure, we will look to industry to begin solution trials as soon as possible. So we are also supporting operators as they work with us to develop the technology to test and then roll out the project.
3. Reduction of gambling-related harm
In terms of a progress report on reduction of gambling-related harms generally, she concluded her speech with the following words:
Progress is being made but reducing harm and risk is not a short term project with easy fixes. It takes a collective effort with us all playing our part. Yes, that means at times we will need to scrutinise and be scrutinised. When people are suffering harm it will always be hard for everyone to agree on what to prioritise. But by keeping a clear view on who is vulnerable to gambling harms and working together we can make a difference.
We at the Gambling Commission continue to stand ready to work with and support others in this effort. That includes gambling operators. We know many gambling firms have had a tough year and tougher decisions to make to save jobs and livelihoods. We will work with those operators who step up to work with us.