COVID: AN OPPORTUNITY?
around well-intentioned processes. If operators work with customers that do recognise that they have a problem, they have enough information from the data to spot red act accordingly with the player. That behavioural information could then even be used to spot potential problem patterns in other players to detect and act upon before things get out of hand. But if a customer signs up to limits on their account, how far should the industry go in ensuring that the person in question isn’t setting up new accounts in order to get around those self-imposed restrictions? And if this problem is addressed by one company, will the customer simply go to a competitor instead?
Like all complex problems, it needs to be broken down to establish where individual companies can do something, where co- operation between competitors for the greater good is appropriate and where the government and regulators need to step in. To start with, operators must agree at what point it is reasonable to expect an individual customer to abide by their responsibilities, and at what stage is it clear that the person in question is vulnerable and unable to make sound decisions.
INDIVIDUAL COMPANIES Key responsibilities for individual companies
should centre on ensuring you know your customer and that you have the right checks in place, including:
• Using identity checks to build a single customer view – this means that a company
is able to link different accounts that may have been created by the same person
• Establishing what the indicators of problem gambling are, including:
• Age – Determining customers’ ages means underage gambling can be prevented, and patterns between age
• Affordability – Addictive gambling can very quickly lead to unsustainable spending and debt
• User history and patterns – what behaviours point towards a problem and how to decide what is ok for one individual, but not for another Once a potential problem has been policies and procedures in place to deal with them. Setting limits and restricting activity or suspending accounts are well-established protocols for problem gamblers, and have even been turned into account settings for all players recognising their own vulnerabilities. These controls can be problematic however, as even customers that have previously
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companies need to understand the red flags that may help to expose these vulnerable customers
requested restrictions may change their mind and ask for the restrictions to be eased again – a trend that has emerged more frequently since lockdown began.
Then, there are those customers who do not want to ask for help. Gambling companies help to expose these vulnerable customers. It is important to have a holistic view, recognising that data used for one purpose however the customer must be informed of
how and why you intend to use their data, in order to receive their informed consent. A key change taking place today is that old silos are being broken down. In the past, enhanced fraud security or ‘Know Your Customer’ (KYC) checks were viewed as an operational cost – they increased friction and reduced revenue. Today, the need for consent and the importance of providing great customer experience means that barriers between data sets are beginning to be removed. The information used for marketing and sales purposes, and that used for fraud and compliance is drawing closer together – so increasingly, the power is in the hands of organisations to act. The name of the game is in making the right decisions at the right time in a responsible manner.
Successful strategies require you to know your customer and build a relationship with them in order to service their wishes. Increasingly, companies act as custodian of their customer’s data – that means protecting them, as well as yourself, from harm. In many industries this means protecting them from fraud, but in gambling the challenge is to protect customers that are vulnerable to addiction from any harm resulting from inappropriate use of your own service.
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