Comments by David Clifton are included in an EGR article entitled “Technology, the regulators and the player journey”, in which the author of the article, Scott Longley addresses the question “With operators under increasing pressure from regulators over how they monitor and police customer journeys, could the adoption of new technological tools such as machine learning and AI be the answer?”
To expand on David’s comments quoted in the article (that can be downloaded below), UK licensed gambling operators are experiencing ever-increasing pressure from the Gambling Commission “to use the resources and technology available to you to make improvements and prove that you are a socially responsible operator” – to use the words of its CEO Neil McArthur at the Safer Gambling Collaboration Day in May 2018.
Although this pressure began more than three years ago when the industry was urged by its regulator to accelerate the pace of change through increased use of technology, it has gained even greater momentum since the Commission took on board recommendations it received in September 2019 from its Digital Advisory Panel and the Advisory Board for Safer Gambling. Those recommendations have been the direct source for Neil McArthur’s repeated calls in speeches since last October for the use of ad-tech and exploration of technology to facilitate a single customer view in terms of affordability.
The Commission’s insistence that the same effort put into adtech solutions should be put into safer gambling reflects its announcement in April 2019 of a shift in focus from “responsible gambling” on the part of customers to “safer gambling”, emphasising instead the onus on gambling operators to protect their customers.
“Safer gambling” is a much wider “catch-all” banner, enabling the Commission to include beneath it a call for implementation by operators – large or small – of all of the technology-related recommendations the regulator receives from its advisory bodies. In the future, we can expect the Digital Advisory Panel to play an even greater role, particularly given its recommendation last September that the regulator considers “appointing commissioners with digital awareness and background that are comfortable with the topics” referred to within its recommendations.
It may be that some operators’ compliance departments will see technology as providing a complete solution to the increasing complexity of their area of work, but technology should be regarded as an aid, not an absolute answer, to addressing the increasing challenge of ensuring regulatory compliance. It is vital that human interaction and analysis continue to play their crucial part in the safer gambling process, with continued investment in properly trained personnel throughout all departments of a company, not just in the compliance department.
In its annual Business Plan for 2020-21 (published on 1 April 2020), the Gambling Commission repeated its mantra that “gambling related harm must be drastically reduced”. That’s what it wants to see, but what does it mean? Although the Commission refers to problem gambling rates as “static”, those rates have been reducing – albeit slightly – over the last ten years.
Use of the word “drastically” clearly implies that the Commission has in mind a very considerably lower problem gambling rate than the current 0.5%, but what level of reduction will it consider a “success”? That is an extremely valid question that the Commission should surely now be addressing, given that the very same question was posed by the National Audit Office at the end of February, when it called on the Commission to articulate (a) what level of reduction it wants to see in the numbers of people affected by problem gambling, (b) over what period of time this should occur and (c) what would indicate good progress.
The basic problem at the moment is that whilst the industry has clearly upped its game, it has been set no clear benchmarks against which to evaluate its performance in achieving whatever it is that the Gambling Commission will judge to be a success. Perhaps that is little surprise in view of the National Audit Office’s finding that the Commission itself does not have a full understanding of the impact of its work or whether it is achieving its overall objectives to protect consumers – a subject that was strongly pursued by the House of Commons Public Accounts Committee when taking oral evidence from Neil McArthur on 27 April 2020. In this respect, the ball rests firmly in the Commission’s court as matters stand.