This will be the first in a series of articles focusing on the reforms being sought in UK Gambling and through the Gambling Review. Much has been said and submitted (over 10k submissions) by all sides of the debate on what they want to see, or indeed what they don’t want to see come out of the review. However, it is imperative for people to understand that there are significant changes being implemented now, long before any new legislation comes into force. There are changes afoot that will affect how or indeed if you can bet, should that be recreationally or professionally. The two main areas for concern currently are Single Customer View (SCV) and Affordability. I will focus this article on SCV and would ask you the reader to do likewise, for a moment set aside all your other concerns and let’s deal with this particular issue in isolation – let us determine what it is, will it work, who (if anybody) will it help and what are the downsides.
WHO CAME UP WITH SINGLE CUSTOMER VIEW?
It’s been bandied around for quite a while so it’s hard to determine whose initial idea it was, but the Gambling Commission (UKGC) seem to be behind it as they’ve instructed Gambling Operators via the Betting and Gaming Council (BGC) to come up with a working solution which is set to “go live” at the end of March this year. Campaigners for Gambling Reform have advocated for it, but they don’t like the BGC driving it. Though they seem to have done little proactively to stop that occurring.
WHAT IS SINGLE CUSTOMER VIEW?
It is an attempt to create a holistic view of an individual’s gambling activity across all UKGC licenced Gambling sites with the main objective of protecting consumers from Gambling Harm. While the details are not fully clear as to how exactly this will be done what is clear is that SCV is rooted in data sharing. That is enough for me to be wary as data has been used for years now to profile and then, restrict winning punters, identify losers and rinse addicts. Anyone who doubts that should review the Cracked Labs report published last week.
HOW WILL IT OPERATE AND WILL IT WORK?
The finite details have not yet been disclosed but there are two sides both with their own ideas of how they would like to see it be managed/operate.
THE BGC/OPERATOR SYSTEM
Initially there was much uproar that Operators would be disclosing sensitive data directly between themselves. A recent announcement by the BGC say the system and all data will be managed by GAMSTOP.
For those not aware of what GAMSTOP is, it is the online self-exclusion system, that took years and millions of pounds to develop. Where those who wish to curtail their online gambling (for whatever reason) enter their personal details and choose an exclusion period of up to 5 years. That then registers them on the database and no licenced UK operator will let them operate or open an online account. Unfortunately, this is all dependent on the gambler keeping their details up to date. Those that wish to return to betting before their time is up seem able to do so by simply changing a few variables when opening new accounts (a different email, telephone number or address seem to be enough to circumvent).
Problems then occur if the gambler wins or lose big, and more invasive checks are carried out. These checks would identify them as being excluded and payment by the Operator is denied, or in the case of big losses, the punter cries foul for not being properly protected.
There is no doubt the Operators like the system, as the worst-case scenario is having to refund net deposits, if they have somehow been seen to fail. This will rarely happen as, in the majority of cases the onus is put on the customer to have managed their details and those who have circumvented the system will be playing a heads you lose, tails we win game in favour of the operator. I am taking no stance on the rights or wrongs of any behaviour by either side – the point being made is that in today’s technological world a system like this should not be so easily circumvented as that is relevant to the current topic SCV.
The information available in the public domain so far, is that instead of Operators supplying reams of sensitive data they will assign a “risk rating” to individual customers and then make that available to GAMSTOP who will share the rating with all the other Operators. So, if one company see’s a customer acting “irresponsibly” they alert GAMSTOP to that behaviour with a high-risk rating and GAMSTOP will presumably, depending on how “irresponsible” one operator determines that customer to be, will either advise “a caution” or an outright ban across the board with your gambling activity.
The big question here is, Who is determining what is irresponsible and what is not, at what level and over what period of time? Those that bet regularly and with different operators may have winning accounts with some and losing ones with others. Will a customer’s losing account create a “false positive” which assigns them a high-risk rating and possible expulsion from online gambling? Even if that same customer is in net profit across the board.
On the flip side of those acting responsibly, you will have the addicts who to feed their addiction “need to play”. For someone in that position (and I have empathy regarding the addiction) they will quickly learn how to fly under the radar. It would be reasonable to assume that someone depositing and losing say £50 a week with an Operator probably won’t be seen as risky or irresponsible to that individual Operator and therefore will get reported as “low risk”. But what is to stop them using 10,20,30… accounts? Nobody will see or report a problem, but that customer could be causing themselves and their family massive harm.
Neither of the above scenarios are mentioned for anyone to a) feel sorry for someone that they can’t get a bet on or b) feel sorry for someone who you may view as not having control over their own actions/personal responsibility. They are to show how an ill-thought-out idea can result in creating issues for those that don’t have a problem in the first place and not protecting those that do.
Of course, for me there is another other and probably more worrying scenario, which is this system could be used to get rid of professional punters. If your face doesn’t fit and they don’t want you, it will in essence only take one operator to deem you “high risk” and you’re done. There is currently no detail as to what right of appeal you would have, no criteria published as to what is deemed responsible and what is not – so what would be your grounds for appeal and to who? Does the harm of not being able to gamble to make a living or a second income apply here? For me If I were red flagged this would be devastating and result in myself being ‘jobless’ or having to navigate around the system. Or worse, join the black market, which is bound to become ‘bloated’ with this scheme.
THE GAMBLING REFORM CAMPAIGNERS SYSTEM
Now this side want SCV but they want an Ombudsman to oversee it. They haven’t given any details as far as I can see as to how it would work except that they want affordability integrated into it. Presumably the Ombudsman checks you out if you want net deposits in excess of £100 a month (The Social Market Foundation Think Tanks recommendation) and if they determine (again no detail) that your good for say £250 a month that becomes your net deposit limit across all UK licenced operators. There are so many loopholes in this proposal that I could write forever, and we still couldn’t cover them. We will just go with a few simple ones for now:
Having talked to many on all sides of this debate, the conclusion I have come to is unless this Ombudsman system was plugged in, in real time to every operators back office and payment system it would be doomed to failure from the outset. As without real time “instant” updating of a customer’s net position over the month across all Operators, what will stop the following occurring:
Anyone for whatever reason simultaneously depositing their full monthly allowance (let’s call it £250) into say 6 accounts with various operators leaving them with an exposure of £1500 instead of £250?
The “normal” punter who sees that loophole and just wants to play with extra money as he feels aggrieved at being limited on his spend will probably punt away. God help him if he wins big as he’ll no doubt receive an email that “after further checks” he shouldn’t have been allowed the deposit in the first place and there’s his initial deposit back, winnings denied (heads you lose tails we win – see GAMSTOP above)
Then there’s the addict who can’t help themselves, they will see how to get more funds in to feed their addiction and when the music stops and their accounts are empty, they will be complaining to the Ombudsman, the GC and anybody else that will listen that the system has failed them, and they need refunded? Who will deal with this because there is no point in SCV in the first place if there is no accountability? In this scenario the Ombudsman may as well just send an email at the outset saying “Please don’t spend any more than £250 a month on gambling, if you do, you’re on your own”
And finally, the fraudsters who will see this as manna from heaven – They will open 20 banking/funding accounts deposit 5k instead of £250 sit down at a live game like roulette/baccarat and bet the lot from each individual account on the same even money chance on the same round. If they get it right the money will be out and gone and if it goes against them, they’ll be on claiming addiction, no protection and 19 of the 20 deposits back. Who is going to deal with that mess and make the determination if it was fraud or addiction, who could?
It is all very well coming up with these headline grabbing ideas, but the devil is in the detail. And when you look at what can occur with SCV (I have kept this brief, the loopholes and potential for disaster are many) I hope you agree with me that this issue is ill-thought-out, we can do better in finding a solution to help those, where gambling is a problem. I believe SCV would be at best a tick box exercise for operators/GC to feign doing something or if campaigners got their way to shout success. But for the likes of you and me, the 99% of the 30,000,000 customers who enjoy a bet each week without issue, we shouldn’t be subjected to red tape and arbitrary decisions being made on how and where we spend our money.
I am somewhat receptive to measures that protect those people who genuinely have a problem and would accept a small amount of friction for the “greater good” but SCV is not and can never be it. I’ll touch on something in part two that I feel might work – thanks for reading