Lessons in applied technology – responsible gambling
This year’s ICE Totally Gaming expo (held at ExCeL in London earlier this month) saw an increased focus on responsible gambling, and in particular how… Read more
This year’s ICE Totally Gaming expo (held at ExCeL in London earlier this month) saw an increased focus on responsible gambling, and in particular how technology can be used throughout the industry to protect those at risk of harm. While some regulatory issues are bespoke to the gambling sector, the critical importance of “knowing your customer” (KYC), and the need to deal with ever-increasing volumes of data, are things which the industry has in common with many other sectors, and the technologies used by the gambling industry may have wider application.
With the British gambling industry reaching £14.4bn gross gambling yield in 2018 (a 4.5% increase from the previous year) and over 100,000 individuals employed within the gambling industry in Great Britain, this is big business, and the online and mobile sectors are continuing to grow with a market share of 37.3% of the remote sector (a 3% increase from the previous year) and gross gambling yield of £5.4bn (a 13.7% increase on the previous year). Technology has a pivotal role both in the continued growth of this industry, and in compliance including customer identification and protecting vulnerable individuals who are at risk of harm from gambling.
It is reported that 1.2% of gamblers in England identify as problem gamblers, with 6.6% of gamblers in England said to be at low or moderate risk of developing problems with gambling. The GB Gambling Commission has been clear that it expects the industry to identify customers at risk of harm, including not just problem gamblers but also those who may be at risk of developing an addiction, and to use all available technology to do so.
Technology has a role to play at all levels of the gambling industry, from operators to suppliers, and from customers to advertisers. We look at some of these industries applications of technology, and their potential relevance to other sectors, below.
Gambling operators and technology
Technology and data
Online gambling companies collect a vast amount of data from their customers – from data used to inform KYC checks (including identify verification and source of funds), to analytics on an individual’s gambling habits (preferred products, average spend, average length of time gambling, etc.) This data is often used to personalise the experience of that individual, but the Commission has been clear for some years that operators cannot keep data in silos but must use all available information for regulatory compliance purposes including customer identification and reduction of gambling harm.
In its current consultation on its strategy to reduce gambling harms, the Gambling Commission defines gambling harms as ‘the adverse impacts from gambling on the health and wellbeing of individuals, families, communities and society’, and proposes to focus on five priority areas: research to inform action, measurement of gambling related harm, evaluation of treatment options and assessment of treatment needs, use of an evaluation protocol, and targeted collaboration of gambling businesses. Clearly technology can help to deliver all these eg by facilitating the more efficient collection and collation of data, secure sharing of that data (anonymised or pseudonymised as appropriate), and analysis of that data using machine learning to identify patterns across ever larger data sets.
Using technology to verify customer identity
The importance of technology in this area was emphasised when the Gambling Commission stressed in its Autumn 2018 consultation on strengthening age and identify verification that it was keen to hear from identity verification solution providers about what was possible. Technology is moving on from verification of ID documents and comparison with a selfie of the customer, to include checks including movement and the selfie is a photo of the actual customer and not just a photo of a photo.
So far, the GB gambling industry has not adopted facial recognition technology as part of its self-exclusion arrangements, reportedly because of concerns over accuracy and cost (installation costs per site can mount up rapidly given the number of outlets operated by the major operators). It is however being trialled in several pubs, clubs and casinos in New Zealand where software checks visitors’ faces against a photo database of self-identified problem gamblers and alerts the casino if there is a match. If accuracy and cost challenges can be overcome, it may be a useful addition to the armoury of any industry or business offering self-exclusion.
Age verification techniques are relevant to any retailer of age-restricted products or services, whether this is alcohol, tobacco, knives or adult content. In October 2018 the British Board of Film Classification (BBFC) issued its guidance on age-verification for those involved in provision of adult content online, and like the Gambling Commission stressed the need for providers to take account of developments in technology.
Identity verification may have wider use than simply age verification in other sectors – for example, retailers of high value products and services may find it useful to confirm identity at the point of sale (or at least before delivery) to reduce the risk of later credit card chargebacks.
Using technology to identify customer trends
Customer data is increasingly being used by gambling operators to categorise players into levels of risk of problem gambling (green, amber, red), based on use of that operator’s products. By developing algorithms to assess which players should be classed as ‘red’, and therefore most likely to be a problem gambler or at risk of becoming one, operators can discover trends and identify warning signs for development of a future gambling problem. Automating this process, using machine learning to compare large volumes of data and other AI to discover potential trends, should enable the operator not only to make quicker and more efficient use of larger volumes of data, but also to identify trends which may not be obvious from a manual review.
The same techniques may be used by other industries to analyse the customer base for commercial as well as regulatory reasons – subject always to compliance with the Data Protection Act which may be more restrictive where the purpose is not protection from harm.
Using technology to shape the products
Having identified customers who may be at risk of developing a problem, operators can adapt the player’s experience and encourage them to stay within the ‘green’ gambler zone. For example, operators can personalise a player’s ‘lobby’ (homepage of an app/website) so that notices about self-exclusion and reality checks are (even) more prominent for “amber” than “green” players. If the analytics suggest a player is at high risk of becoming a problem gambler, the lobby could be edited so that it is not possible for a player to continue playing without completing some form of reality check test, or acknowledging the suggestion of self-excluding from that operator for 24 hours.
Suppliers and technology
There was increased focus at ICE this year on the importance of building responsible gambling into products from the start. Games designers know – from the data and experience built up over years and across operators – what encourages players to continue playing and to return to a product or site. The same expertise and technology which is used in developing commercially successful products needs to be used in designing products to appeal to the “green” gamblers, and not to exploit the vulnerability of the “red” or amber ones, and to encourage all gamblers to play responsibly.
Customer verification is usually outsourced to third party providers, and as outlined above, technology has a key part to play in their services.
Advertisers and technology
In the gambling sector, technology also plays a vital role in blocking marketing material from those who have self-excluded, and in ensuring that marketing material is always age-appropriate.
But the red/amber/green customer categories can also be used to focus marketing materials in a more nuanced way, by ensuring they are appropriate for a certain player or sub-group. For example, the messages sent to red players (who may be at risk of developing a problem with gambling) can receive more information about self-exclusion or services which can help them to manage their gambling, rather than encouragement to try new games.
Banks and technology
Several banks now offer gambling block functionality as part of their debit card offerings to customers. For example, the challenger bank Monzo provides blocking services for gambling sites and shops: once the block is activated, a Monzo user cannot complete a transaction on a gambling site or in a gambling shop, and must telephone Monzo to de-activate the block which will in any case continue for a further 48 hours. Over 60,000 users have signed up to the Monzo feature, with other online-only banks, such as Starling Bank, following suit.
The relevance of this technology to other industries is clear. In December 2018 Barclays introduced a more general blocking functionality, enabling its customers to block payments to various categories of retailers, including premium rate websites and phone lines, restaurants, pubs, bars and take-aways as well as gambling websites and betting shops. By increasing the ‘friction’ for a customer to complete a transaction, this gives the customer time to stop and consider – which is key when dealing with impulse purchases.
Other banks are likely to follow suit, and future restrictions may be extended to other areas.
Customers and technology
It is important to strike the balance between allowing people to gamble if they can do so safely, while prompting those who are in danger of developing a problem to manage their gambling or if appropriate to self-exclude. Mobile technology may have made gambling omni-present, but it also offers customers ways to control their gambling.
As well as GamStop, the national online self-exclusion scheme, there are an increasing number of apps which can assist a customer by increasing the ‘friction’ of placing a bet on a website. Services such as GamBan provide software which block access to gambling websites across an individual’s devices, making it much more difficult for them to access such sites. As discussed above, the banks offer apps to help players control their spending.
Other apps, such as that offered by GambleWise, offer customers the ability to control the time they spend gambling, by sending them alerts when they enter a gambling facility or setting up a system for intervention by a friend or by the manager of the gambling facility.
And the future?
With continuing whispers that cryptocurrencies could start to be accepted by more operators, and suggestions that biometrics could be used as a form of ID, technology will definitely continue to be an integral part of development for all elements of the gambling industry.
And other industries, from retail to other regulated sectors, may find it useful to keep a close eye on how the gambling industry uses these and other technologies and the potential for their wider application.
 Gambling Commission: Key Facts and Figures (https://www.gamblingcommission.gov.uk/news-action-and-statistics/Statistics-and-research/Statistics/Gambling-key-facts.aspx)
 Gambling Commission Industry Statistics April 2015 – March 2018 https://www.gamblingcommission.gov.uk/PDF/survey-data/Gambling-industry-statistics.pdf
 Health Survey England 2016 (reported April 2018) (https://www.gamblingcommission.gov.uk/news-action-and-statistics/Statistics-and-research/Levels-of-participation-and-problem-gambling/Levels-of-problem-gambling-in-England.aspx)
 Consultation on National strategy to reduce gambling harms (4 Dec 2018 – 15 Feb 2019).