Why the UKGC's SCV update is a golden opportunity for our industry
23.11.21Back To News
Originally published in EGR intel: https://egr.global/intel/opinion/why-the-ukgcs-scv-update-is-a-golden-opportunity-for-our-industry/
The single customer view is an opportunity to strengthen protection and prove the industry can be trusted to protect its at-risk customers. It should be embraced for its ambition, not dismissed for its complexity, explain Will Mace and Lyndsay Wright
19 November 2021
The single customer view (SCV) – a data sharing mechanism to protect at-risk customers – has been one of the industry’s ‘safer gambling commitments’ for some time, quite simply because it is recognised as one of the most powerful tools our industry could use to strengthen the range of protections it already provides to and for at-risk customers.
For that reason alone, we should welcome the UKGC’s most recent SCV update and the accompanying ICO report, which, although caveated, makes clear the sharing of behavioural data between gambling operators to identify individuals who may be ‘at-risk’ of gambling-related harms, via an SCV, may be lawful – depending on exactly how it is done. The industry should welcome this and embrace it as an opportunity to go further than ever before with the agenda to make gambling free from harm.
Inevitably there have been attempts to generate controversy but there is real reason for optimism and confidence they will not derail this important initiative.
The industry is right to highlight the significant progress it has made in the last five years to make gambling safer and the resulting reduction in the number of gamblers considered at-risk of harm. They are equally right, however, not to rest on their laurels, and to continue to work to strengthen protection and to drive up standards, and acknowledge there is more to do, as Michael Dugher, CEO of the Betting and Gaming Council, regularly underlines. The SCV is a clear opportunity to do exactly that – strengthen protection and drive up standards.
Why we need to agree on the need for the SCV
The rationale for the SCV is simple; however capable or well-intentioned a single operator may be at identifying at-risk players, if such a player can simply ‘go next door’ and open an account with a new operator, then the efforts of even the best intentioned and most capable brands will too often be in vain – as customers can continue to play without any of the intended protections or support. A £500 deposit limit imposed by one operator quickly becomes irrelevant if a player goes on to open dozens of new accounts.
Today, from the very moment a customer opens a new account, an operator tracks their spend and patterns of play, but what if they are already at risk, or at very high risk, and that site just can’t see it yet? How can we best help that player? Having a mechanism to know if that customer is at risk from day one has to be the answer.
Everything tells us that customers who have suffered harm have used multiple accounts, from gambling usage research to helpline operators, to those who powerfully share their lived experience stories with us. Shaan, an ex-Gordon Moody resident and reformed problem gambler, explained: “I had two operators that I was a VIP with, but when they started asking questions about where the money’s coming from, I stopped using those brands and opened up new accounts. It was easy and I probably had an account with every single operator going.”
[Shaan’s story: https://vimeo.com/468112119]
The industry’s reputation has been on the decline for a decade, and globally, it’s facing more restrictions than ever. Protecting, and being seen to protect, at-risk customers is fundamental to a licence to operate. If we don’t, then the restrictions will inevitably continue to increase. A shared-data platform is one of the most effective tools we can put in place, with the potential to be a clear message to the world that at-risk gambling is being addressed proactively by an industry that really does not want to see anybody harmed.
Although the UK industry is made up of a diverse group of operators, with different views, appetites and capabilities, they all suffer as a result of a declining reputation and increasing restrictions, so it is clearly in the interests of all operators to come together to address the situation through initiatives such as the SCV.
Although some have questioned the ability of the industry to work together effectively, there is every cause for optimism, with the BGC providing a platform for cross-operator collaboration and both the UKGC and the gambling minister reinforcing the importance of a data-sharing mechanism. The necessary ingredients appear to be coming together to create the foundations for a successful SCV initiative.
Perhaps understandably there has been a broad range of responses from commentators to the GC update and ICO report. Most cautiously applaud the apparent aims of the SCV, but inevitably some seek to generate controversy out of the relatively sparse level of information provided by the UKGC and the caveats included within the ICO report. This is a shame, for while there are certainly some important questions for the industry to work through, it is unhelpful, creating the mistaken perception that the SCV is something to fear and oppose.
Time to bust SCV myths
Some of the supposed controversies spring from the lack of definition of the SCV, with one highly qualified observer calling it “a dangerous bureaucratic shorthand, that can mean different things to different people”. The UKGC acknowledges SCV could take many forms and suggest it is up to the industry to choose their preferred model. This has led to the ICO needing to heavily caveat their guidance, which was necessarily based on a particular conceptual model, which they note may be some way from the industry’s desired approach.
It has also led to speculation about scope, particularly the inclusion (or not) of land-based businesses. Such questions also spill over to unfounded assumptions being made about cost (huge!), time (years!), and complexity (also huge!), which, in turn, lead to those mistaken perceptions that the SCV is something to fear and oppose.
Another supposed controversy suggests the SCV is yet another ratcheting up of intrusion levels and that customers may not want their risk level to be aggregated from across the operators they play with, even if it provides enhanced protection. It’s an understandable challenge and we all resent a Big Brother approach when it comes to spending our own money, no matter what or where or how we choose to spend it. But we’re not talking about that with the SCV: we’re talking about customers who need help, customers who are either suffering or at significant risk of harm. The SCV can, and should, be designed to help them, and not to try to ‘catch all’.
Perhaps the most bizarre, alleged controversy appeared on Twitter shortly after the UKGC update was published suggesting operators would abuse an SCV, using it to ensure winning customers were blocked from all operators. Bizarre because operators would be perfectly happy if their winning customers chose to go and win at competitor operators instead. You can always rely on Twitter!
Lastly, it has also been said that an SCV would make every operator beholden to the risk appetite and player monitoring capability of the most cautious and least technically capable operator; rendering the multi-million-pound investment in sophisticated capabilities many operators have made effectively useless.
This is perhaps the most worrying mistaken perception as it could lead to opposition from operators who lead the way in pioneering safer gambling and without whose support an SCV could really suffer. It assumes that if the least technically capable operator, one without much in the way of monitoring or player interaction capability, flags a player as ‘very high risk’, then all others would have to blindly accept that assessment and interact with the player accordingly.
That might be true of the most basic form of SCV, but certainly not true of the type of model discussed by the ICO, which takes patterns of play data from individual operators about a player once certain triggers are hit and creates an aggregated risk score. This creates a risk view of the player based on their actual data, not on the assessment of any individual operator. With this approach no operator is beholden to the blunt assessment of another, and operators can use the score to inform and enhance their interaction approach, according to their own appetites and technical capabilities.
The SCV does have great potential to strengthen the safeguards and protections the industry offers its at risk players, and the ICO report should be considered a pivotal step along the road to achieving it. Despite the many as yet unanswered questions there need be nothing to fear in the development of an SCV, rather it should be seen as an opportunity for us all to embrace.
Lyndsay Wright is an expert in investor relations and strategic communications. During 11 years in the gambling industry, she led William Hill’s sustainability strategy, including collaborating with other industry leaders on developing the safer gambling commitments.
Wil Mace is the CEO and co-founder of EQ-Connect. He was previously head of Kindred Futures (strategic innovation at Kindred Group). During seven years in the gambling industry, he developed and led Kindred’s open innovation department, working with some of the industry’s most innovative start-ups, before going on to co-found EQ-Connect.