Ian Angus, Director of Policy at the Gambling Commission, delivered a “view from the regulator” speech at yesterday’s KnowNow ‘Responsible Marketing for Gambling Operators 2020’ conference, during which he reflected on:
- the Commission’s overarching priorities,
- the current climate regarding gambling advertising,
- the associated research and evidence base,
- regulatory and industry developments and progress, and
- key advertising issues for all associated with the gambling industry to focus on over the coming months.
His illuminating speech – in which he referred to there having been “a marked improvement in [gambling] advertising compliance standards in the past couple of years” albeit that “there is still more to do, particularly in the online space” – is now accessible on the Gambling Commission’s website and can also be downloaded below.
UPDATE: David Clifton’s subsequent Keynote Interview with Brigid Simmonds, who chairs the Betting & Gaming Council took place today (16 October 2020) on the second day of the above conference. This interview focused on the following gambling marketing and advertising topics:
- BGC’s good news in August was that the ‘whistle to whistle’ ban had reduced the amount of TV betting ads seen by children to 97%. However, this was tempered by the ASA’s announcement just days later that four UK licensed gambling operators had breached its age-restricted online advertising rules. The largest British gambling operators are members of the BGC, but what influence can the BGC bring to bear on the many smaller non-BGC member operators who may not achieve the required high standards?
- BGC members voluntarily removed all TV and radio gambling advertising between 7 May (at the latest) and 5 June because of the lockdown. Did it lose a good PR opportunity when it lifted its own self-imposed ban to coincide with live sport returning, bearing in mind that millions were still furloughed at home?
- A new commitment was given by BGC members on 5 June that at least 20% of all gambling adverts on TV and radio would become safer gambling ads. How will the BGC evaluate the effect of this
- The 6th Gambling Industry Code for Socially Responsible Advertising came into force on 1 October. This time it was published by the BGC. How has the process changed that leads to publication of a new edition of a Code that still bears the name of the Industry Group for Responsible Gambling
- Why has it taken so long for the Code to catch up with the fact that at least 80% of all gambling marketing spend is online and the young spend far more of their time on social media than watching TV?
- We are only 16 days into that but some seem to think the Code needs accompanying guidance in some respects. For example, the new Code:
- suggests that operators should take into account how active their own social media accounts are when posting frequent safer gambling related information. How would this work in practice?
- states in relation to “Promoting customer awareness” that “this list of instructions will cover the largest social media platform”. What ‘instructions’ is this referring to and how are they accessible?
- talks in terms of a “shared blacklist of negative keywords against which no gambling advertising should be served” that will be collated and regularly updated by the BGC. How does one find that blacklist?
- mentions a Code of Conduct for affiliates. Is the BGC intending to produce a template for a Code of this type?
- does not reflect the criticisms made for some time about the slogan “When the fun stops – Stop”, despite the BGC having taken over the Senet Group remit back in April. What is the official line on that now, in light of suggestions that it is ineffective and that, by the time the fun stops, a gambling problem already exists?
- What differences exist between the new Code and the EGBA Code of Conduct for Responsible Advertising for Online Gambling, published in April this year?
- Mistakes can happen. How does the BGC deal with complaints and breaches of the Industry Code (as stated at para 67 of the 6th edition of the Industry Code)?
- What can be expected now from the AdTech Working Group, so perhaps you can you tell us what to expect now from that group (including a “permanent cross-industry AdTech Forum”)?
- Many critics of gambling advertising focus on the sheer quantity of gambling ads in all forms of media. What is the BGC’s official line on this criticism? Can we expect any voluntary controls to be introduced before they are imposed upon the industry, for example a change of emphasis, for example on buying entertainment rather than winning money, as suggested earlier this year by Professor Mark Griffiths?
- Turning to gambling advertising & marketing issues likely to arise in the forthcoming government review of the Gambling Act 2005:
- The report by the House of Lords Select Committee on the Social & Economic Impact of the Gambling Industry called for independent research on the links between gambling advertising and gambling related harm. Ian Angus referred yesterday to the Ipsos MORI research commissioned by GambleAware (and published in March) concluding that “there is a clear link between gambling advertising and the attitudes, current and likely future behaviours of children, young people & vulnerable adults”. Is further research really required?
- The Gambling Related Harm APPG has called for a ban on all gambling advertising, marketing & inducements across all channels and, more recently, Peers for Reform have started lobbying for a ban on direct marketing and all inducements and an end to sports sponsorship by gambling companies. What is the BGC’s answer to these calls and what do you envisage the outcome of the review to be in these respects?
- Responsible Affiliates in Gambling has announced its support in principle for a licensing or registration regime for gambling affiliates. Ian Angus confirmed yesterday that the Gambling Commission still doesn’t necessarily see the need for a a licensing regime for affiliates. What’s the BGC’s view? Is affiliate licensing needed?
- Does the BGC welcome the increasing role being taken by Experts by Experience (with life experience of gambling related harms) in relation to formulation of gambling policy or has this upset the ‘proportionate regulation’ balance?
- Is it really the case that imposition of even more restrictive controls on online gambling operators will leave illegal black market operators the winners – something that the Gambling Commission has called an “unsubstantiated risk” (most recently in its response to the HVC consultation)?
- Brigid: When we spoke at KnowNow’s January conference, you said that the gambling industry “won’t get any changes we want unless we improve our image and work together”. So firstly, has the industry improved its image in the past nine months and, secondly, with BACTA and the Bingo Association still forging their own paths, will the industry ever truly work together?