Why the UKGC's SCV update is a golden opportunity for our industry

23.11.21

Back 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.

 

x
  1. Terms

By accessing the website at http://eq-connect.com, you are agreeing to be bound by these terms of service, all applicable laws and regulations, and agree that you are responsible for compliance with any applicable local laws. If you do not agree with any of these terms, you are prohibited from using or accessing this site. The materials contained in this website are protected by applicable copyright and trademark law. 

  1. Use Licence

Permission is granted to temporarily download one copy of the materials (information or software) on EQ-connect’s website for personal, non-commercial transitory viewing only. This is the grant of a licence, not a transfer of title, and under this licence you may not: 

This licence shall automatically terminate if you violate any of these restrictions and may be terminated by EQ-connect at any time. Upon terminating your viewing of these materials or upon the termination of this licence, you must destroy any downloaded materials in your possession whether in electronic or printed format. 

  1. Disclaimer

The materials on EQ-connect’s website are provided on an ‘as is’ basis. EQ-connect makes no warranties, expressed or implied, and hereby disclaims and negates all other warranties including, without limitation, implied warranties or conditions of merchantability, fitness for a particular purpose, or non-infringement of intellectual property or other violation of rights. 

Further, EQ-connect does not warrant or make any representations concerning the accuracy, likely results, or reliability of the use of the materials on its website or otherwise relating to such materials or on any sites linked to this site. 

  1. Limitations

In no event shall EQ-connect or its suppliers be liable for any damages (including, without limitation, damages for loss of data or profit, or due to business interruption) arising out of the use or inability to use the materials on EQ-connect’s website, even if EQ-connect or a EQ-connect authorised representative has been notified orally or in writing of the possibility of such damage. Because some jurisdictions do not allow limitations on implied warranties, or limitations of liability for consequential or incidental damages, these limitations may not apply to you. 

  1. Accuracy of materials

The materials appearing on EQ-connect’s website could include technical, typographical, or photographic errors. EQ-connect does not warrant that any of the materials on its website are accurate, complete or current. EQ-connect may make changes to the materials contained on its website at any time without notice. However EQ-connect does not make any commitment to update the materials. 

  1. Links

EQ-connect has not reviewed all of the sites linked to its website and is not responsible for the contents of any such linked site. The inclusion of any link does not imply endorsement by EQ-connect of the site. Use of any such linked website is at the user’s own risk. 

  1. Modifications

EQ-connect may revise these terms of service for its website at any time without notice. By using this website you are agreeing to be bound by the then current version of these terms of service. 

  1. Governing Law

These terms and conditions are governed by and construed in accordance with the laws of UK and you irrevocably submit to the exclusive jurisdiction of the courts in that State or location. 

 

 

x

1. Privacy Policy 

EQ-Connect (EQ) have developed this Policy to describe how we handle personal information collected from persons who use the EQ website, or who, following an invitation from EQ during any marketing and /or event communication processes, such as in –person, email, telephone, text messaging direct mail and online, provide personal information to EQ. 

Personal information means any information relating to an identified or identifiable natural person; an identifiable person is one who can be directly or indirectly identified by reference to an identifier such as name, an identification number, location data, online identifier or to one or more factors specific to the physical physiological, genetic, mental, economic, cultural, or social identity of that person. 

Sensitive personal information is a subset of personal information and is generally defined as any information related to racial /ethnic origin, political opinions, religious beliefs, trade union membership, physical or mental health, or other medical information including biometric and genetic data, or sexual life preferences. In some instances, sensitive personal information may also include criminal allegations or convictions, precise geolocation information, financial and bank account numbers and unique identifiers such as government issued security numbers, driver’s licence, and passport numbers. 

When you visit the EQ website we collect personal information about your visit. Our web server automatically records details about your visit (for example, your IP address, the type of browser used, the EQ website pages that you visit and the duration of your visit). 

In addition, we collect the personal details which you provide online, for example, when you enter personal details (e.g. name, gender, address, email address, phone number) on a website registration page. 

We also collect personal information directly from you during sales or purchasing activities and/or in connection with marketing events, for instance: business cards; personal contact details; emails and other social media. 

In some circumstances we may also collect personal information about you from third parties, such as your employer, or professional organisations to which you belong, or personal information that you have placed in the public domain, such as from Facebook or LinkedIn. 

By providing your personal information as described above, or by proceeding with your visit to EQ’s websites, you are accepting and consenting to the practices described in this Privacy Policy, and you agree to the transfer, storing or processing of your personal information in the manner described in this Policy. 

If you subsequently wish to withdraw your consent to the collection and handling of your personal information, then you may follow the instructions on any communications you receive from us or contact info@eq-connect.com 

Other websites, which are not operated by EQ, reached by links from these sites are not covered by this Policy. We encourage our users to be aware when they leave our site and to read the privacy statements of each website that collects personal information. Please note that we do not accept any responsibility or liability for policies or the use and/or reliance of data appearing on other websites. 

1.1. Information we collect 

We collect and process the following personal information (which may in certain circumstances include sensitive personal information) about you: 

Information you give us: This is information about you that you give us by filling in forms on our site or by corresponding with us by phone, e-mail, text messaging, direct mail, online or otherwise. It also includes information you provide us through electronic or hard copy business cards, for instance, when you fill out: contact forms; content download requests; event registration forms; information request forms and/or when you report a problem with our site. 

If you are a job applicant we collect, store and use information you provide on your application form(s) for the purposes of recruitment. The information you give us may include your contact details, job application, curriculum vitae, covering letter and any references provided. It may also include sensitive personal information, for instance, on a disability that is relevant to your interview, for which we will require your explicit consent to collect and retain your personal information. 

Regarding each of your visits to our website we will automatically collect the following information: 

We, by using a tracking code from a third-party provider, also collect information on the public IP address of the requesting computer. This tool provides us with information as to the company that has visited our website(s), but individuals cannot be identified by this tool. 

 

1.2. Cookies 

Cookies are small files of letters and numbers. These files are either stored in the memory of your computer or other device such as mobile phones or are placed on the hard drive of your device. 

Our website uses cookies to provide you with an effective browsing experience. You can read more about this in our cookie policy. 

1.3. Uses made of the information 

Regarding information you give us, we will use this information for: 

Regarding collected information, we will use this information: 

Regarding information we receive from other sources, we will only collect and handle your personal information in accordance with your contact preferences. 

You can also subsequently inform us of your contact preferences, including any request to withdraw your consent to the collection and handling of your personal information by contacting: Data Protection Officer, EQ-Connect, Parsonage Farmhouse, Marlborough, SN8 3SD, UNITED KINGDOM 

Info@eq-connect.com 

1.4. Sharing Information 

Although we make every effort to preserve user privacy, we may need to disclose personal information when required by law, including (without limitation) to comply with applicable local laws or judicial proceedings, court orders or any other legal processes. 

Personal information is also used by companies in the EQ Group. When we share personal information, we do so in accordance with data privacy and security requirements. All our employees and contractors are required to follow a group data privacy policy when handling personal information. 

It may be shared under contractual control with other companies who collect and handle personal information on our behalf. For these purposes information may be transferred to other companies located outside the European Economic Area. Any personal information that is transferred will be protected accordance with applicable laws. When we transfer personal information from the European Economic Area to other countries in which applicable laws do not offer the same level of data privacy protection as GDPR, we take measures to provide an appropriate level of data privacy protection. 

In some circumstances personal information may be shared with third parties for legal reasons, such as: 

1.5. Storing Information 

EQ is a UK based organisation, but personal information may be stored and processed outside of the European Economic Area. We take steps to ensure that information we collect is processed according to this Privacy Notice, the requirements of GDPR and other applicable laws. 

1.6. Retaining Information 

EQ may be required to use and retain information for legal and compliance reasons, such as the prevention, detection, or investigation of a crime; loss prevention or fraud. We may also use personal information to meet our internal and external audit requirements, information security purposes, and as we otherwise believe to be necessary or appropriate: 

  1. a) under applicable law;
  2. b) to respond to requests from courts, law enforcement agencies, regulatory agencies and other public and government authorities;
  3. c) to enforce a contract; or
  4. d) to protect our rights, privacy, safety or property or those of other persons

1.7. Data Security 

We have physical, electronic and administrative security processes in place in our facilities to protect against the loss, misuse, unauthorised access, or alteration of information. Our company uses secure encryption technology for all sensitive and financial personal information transmitted. 

Despite this, the transmission of information via the Internet is not completely secure and we cannot guarantee the security of your personal information transmitted to our site; any transmission is at your own risk. We do not accept liability for any interception of your personal information that may occur. 

1.8. Your Rights Correcting/Updating/Deleting/Deactivating/Accessing Personal Information 

If you wish to correct/delete/edit/deactivate and/or update information or you no longer require our service, you can notify us of this change by contacting us (see below). 

You may, where permitted by GDPR, submit a Subject Access Request (“SAR”) to the Data Protection Officer to check whether we hold your personal information; and/or, require us to provide you with a copy of your personal information; and/or, require us to correct or delete or restrict the processing of any of your personal information that is inaccurate or that you don’t want us to hold. This request should be made in writing to our contact address (below). 

1.9. Contacting Us 

Data Protection Officer, EQ-Connect, Parsonage Farmhouse, Marlborough, SN8 3SD, UNITED KINGDOM 

Info@eq-connect.com 

1.10. Other 

Emails and other electronic communication with us and/or any EQ company may be monitored. Calls to us and/or any EQ company may be recorded for business continuity, quality control, regulatory and/or monitoring purposes. 

1.11. Changes to our Privacy Notice 

We may, from time to time, make changes to our Privacy Notice. Please check back frequently to see any updates or changes to our Privacy Notice. 

GDPR definition 

As from 25 May 2018 onwards, Regulation (EU) 2016/679 (the “General Data Protection Regulation” or “GDPR”) and the Privacy and Electronic Communications (EC Directive) Regulations and any guidance or codes of practice issued by the European Data Protection Board or Information Commissioner (the UK’s independent authority established to uphold information rights) from time to time (all as amended, updated or re-enacted from time to time); and with effect from the date the United Kingdom exits the European Union (“Brexit”) such applicable law of the United Kingdom as has been enacted to provide for Brexit and the transposition into domestic law of the GDPR and/or replacement by new legislation achieving similar or equivalent effects to the GDPR.