The future of the gambling industry hangs in the balance

25.09.20

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The future of the gambling industry hangs in the balance

Bans and limits make for easy headlines, however, if the industry is to make sustainable, long-term progress and significantly reduce harm, it must adopt a collaborative, data-driven approach to addressing the protection of at-risk players, argues Will Mace, founder of EQ-Connect.

(Also published in EGR Intel – https://egr.global/intel/opinion/the-future-of-the-gambling-industry-hangs-in-the-balance/)

The gambling industry has undoubtedly become a ‘safer’ place for players in the last few years with new regulation bringing additional safeguards, clearer consumer guidelines and advice and more ways to seek help, however it unquestionably still has a long way to go. There are still far too many cases of significant harm being suffered, as any of the treatment centres, such as the Gordon Moody Association, will confirm.

Fortunately, further change is inevitable as both the industry increasingly coalesces around the need to ‘do more’, and external pressure on responsible gambling approaches boiling point. What is less sure, however, is the direction of change.

In the last six to 12 months there has been a significant escalation in public and political discourse about the state of the industry, as commentators set the tone and parameters for the forthcoming legislative review. The most vocal lobby want to make gambling safer through a series of blanket measures, universally applied to all. The language used is primarily of control, of bans and boundaries, seeking to prohibit ‘all advertising, sponsorship, marketing, and inducements’ and to impose stake, deposit and prize limits. They want to restrict gambling to the point where it is all but impossible for anyone to suffer any form of harm; and they certainly make a passionate argument, citing some of the many tragic cases to reinforce their perspective.

It is easy to see why a restrictive approach such as this might appear attractive – initially at least – bans and limits make for easy headlines and facilitate the claim that strong, effective action has been taken to protect the vulnerable.

But….

This lobby makes the assumption that anything more than the occasional flutter is some sort of sign of delinquency, that requires the patrician arm of legislation to protect against. They do not seem to allow for the fact it may be possible to enjoy more – even much more – than a bet or spin or two, without risk of delinquency or of suffering harm.

According to Health Survey figures[1] 2.7% of adults were considered low-risk gamblers, 0.8% were classed as moderate-risk gamblers, and a further 0.5% were classified as problem gamblers. Low risk is defined as gamblers who experience a low level of problems, with few or no identified negative consequences. By this data, 96% of adults are not at-risk. This is not to seek to marginalize, or to downplay the problem in any way, but rather to highlight that not every gambler is at risk of harm and so blanket measures are simply inappropriate. It is clearly possible to enjoy more than the occasional flutter without risking harm and without needing such patrician protection.

The data-driven identification approach

How then do we balance the urgent need to do more to protect those that are at risk while allowing those that are not at-risk to gamble as they wish?

A more nuanced approach than universally applied bans and limits is clearly needed, one where the priority is firmly on the identification of at-risk players followed by subsequent interaction with them to reduce risk and prevent harm.

While this requirement does currently exist in the LCCP (licence provisions) – tucked away in Social Responsibility Code Provision 3.4.1 – the House of Lords Select Committee felt it so important that they recommended making the identification and prevention of harm one of the Commission’s central statutory aims. Disappointingly, there has been little focus on this recommendation in much of the subsequent discourse.

The recommendation should go further. The UK Gambling Commission should clearly define and describe what it means by the identification and prevention of harm – and it should set a very high bar.  Currently, the UKGC offers little more than arbitrary guidance on ‘what to look for’ and makes vague and unsatisfactory statements such as ‘use a range of indicators relevant to your business’ and ‘how you monitor activity depends on your business’.

Going above and beyond

The Commission should specify a minimum standard – a machine learning based behavioural analysis model – to identify any risk of harm, requiring every operator to employ, or to exceed it, as an enforceable minimum standard as part of their licence conditions. And they should back this standard, not just with the ad hoc fines they have issued of late, but with the threat of licence terminations and even personal criminal liability.

Implementing such a data-driven approach would of course take investment, collaboration, and bold leadership – both from the Commission and from the industry – but it would deliver significantly enhanced protection to the at-risk, at the same time as allowing those not at-risk – the 96% – to gamble as they wish.

Industry voices might respond by saying “we are doing this already”, and for a handful of operators this is true, but for many, it is far from the case. The industry needs a comprehensive approach in which every operator is applying consistent minimum standards; it needs a collaborative approach in which data on at-risk players is shared between operators to achieve a common view of a players risk of harm (Neil McArthur’s ‘silver bullet’); it needs a more transparent approach in which data on at-risk players is available for real-time 3rd party inspection; and finally, it needs a much more vocal approach, if the advocates of bans and limits are not to win the day.

The future of the gambling industry is hanging in the balance…

[1]    Health Survey England 2018, conducted by NHS Digital and released in December 2019.  Republished by UKGC Gambling participation in 2019 – Annual Report.

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