The ‘laser-like’ focus of the UK Gambling Commission (UKGC) on player protection, combined with the likely compliance updates from the Department for Digital, Culture, Media and Sport (DCMS) led review of the UK Gambling Act, could mean that adoption of W2’s new real-time affordability solution becomes vital for the country’s gaming operators.
We spoke to W2 Head of Sales Peter Murray about the compliant use of player data, how the urgency to implement responsible gambling (RG) protections has changed the conversation in recent years, and why the W2 solution is aligned with the expected two-fold approach to assessing what a consumer earns and then judging how the resulting disposable income translates to affordability.
Murray also discusses the importance of providing information in real-time without upsetting the user experience, before stressing that access to the data will only be left open to those operators using it for the legitimate purpose of protection, and not as a means of marketing to the player.
SBC: Why is the timing right for this real-time affordability solution?
PM: The timing could not be more critical for the sector. The laser-like focus of the Gambling commission around this area is obvious for all to see and how we ascertain a consumer’s ability to play safely is paramount.
The ability to compliantly access banking data feeds with the minimum of friction places this ahead of solutions like Open Banking simply looking for geographic data that is not specific enough for what we need. So finally finding a way to compliantly provide the information operators need, in real time, while not upsetting the user experience is a really important part of the player protection tool kit.
SBC: What new affordability-based licence conditions are you expecting to see within the revised UK Gambling Act? Is this an attempt to get out ahead of changes to regulation, or has this solution been a long time in the making?
PM: It has certainly been a long time in the making as I was looking at this over five years ago! What has changed, and this is the key part, is around compliance. The data contained in banking feeds has rightly been protected and the historic reputation of the sector has not helped with gaining access.
However, the urgency to implement RG protections has changed the conversation and maybe it’s a great example of how, by reaching out to our partners and working with them over time to allay any concerns that may exist, has resulted in eventual success and something that benefits everyone. It has taken time, but it has been a real team effort.
With regard to what I am expecting to see in the revised Gambling Act I think it will be two-fold. The starting point will be what a consumer earns and how that plays into a view of affordability. The next step is to look at disposable income and try to work out how affordability plays out across multiple accounts.
All indications are that the UKGC will use ONS statistics to work out a national average and impose weekly or monthly limits based upon that. Whatever those regulations look like after the consultation period, how we enable operators and consumers alike to engage seamlessly will define if this is a success.
SBC: Is the UK focus just based on what’s currently possible in terms of the compliant use of banking data feeds? Or might you look further afield?
PM: The way we operate at W2 is to blueprint and test a solution on a target area, and then if successful, roll it out where possible geographically.
Player protection and minimising harm is the central part of any regulatory regime so providing a solution in other regulated markets is definitely the goal. Each jurisdiction has different challenges and data privacy laws and how they are embraced will be key to this. All of our clients look for global growth so they are looking for us to support and enhance their best practice procedures. We are definitely working closely with our partners in order to broaden our reach on this.
SBC: You mention that the solution has two levels to assessing affordability; if the first of these delivers a score-based response, is that a yes/no for continued activity?
PM: Ultimately, what an operator does with the results provided is down to them and their process and overall approach to player protection.
For us Level 1 is an affordability index with indicators that provide a response based upon incomes that fall within certain bands. This will give the operator a view on how to engage further but should not on its own prevent the customer journey continuing unless it falls outside of certain parameters.
What is key is that it can be monitored for changes, yearly, quarterly, or monthly. The UKGC is certainly looking for something that can be reviewed. In times where job security is uncertain, and employees face being furloughed or made redundant, any change of circumstances needs to be picked up early.
SBC: And what is the more in-depth insight made possible by the second of these levels?
PM: The second level is very specific in that it confirms a declared income with a True or False flag. It is not really a two-part process as such. Income verification can be used in conjunction with the level 1 check, a natural next step, or as a standalone check to support enhanced due diligence (EDD) measures and enhance player safety.
As with all parts of our affordability solution, monitoring will be key. Any changes in an individual’s affordability levels will need to be identified and addressed immediately.
SBC: What safeguards are there to ensure the compliant collection of this data is used for responsible gambling and not as a means of marketing to the player?
PM: This is a business critical area that needs to be made clear. The ability to access this data is completely reliant upon using it for the legitimate purpose of player protection.
We monitor and reserve the right to audit our client base and if you add into that mix the huge financial penalties should someone misuse personally identifiable information (PII) in line with General Data Protection Regulation (GDPR) regulation, any breach could potentially be significantly harmful.
The industry needs to continue rebuilding its trust in the eyes of the public and the politicians and the eyes of the media are upon us all.
SBC: But given that you say the onus is on the operator to interpret and make correct use of the data, does this create something of a grey area? Where’s the line between responsible interaction and direct marketing with a player?
PM: Given the reputation the sector has in the eyes of some people the question is a fair one; will the industry act responsibly?
Income verification is part of a bigger picture in that the ability to afford something must be taken in conjunction with a view on what that means for a consumer’s disposable income. The results of any affordability check will be straight forward in that it responds to a request to confirm a declared income or salary threshold.
It is at this point that the onus is on the operator to use the information responsibly. As a partner we will provide what we can to aid player protection initiatives and work to ensure it is used correctly. While W2 is not an enforcement organisation and is not here to police our operator partners there are strict rules around the use of this data, particularly under GDPR.
Illegitimate use of the service, that in any way looks like a sales tactic driven by safer gambling campaigns, as a minimum runs the risk of having the service terminated and the operator having to explain themselves to the UKGC and the Information Commissioner’s Office (ICO)
Both organisations have made it very clear that any misuse of PII will be swiftly and robustly dealt with. This is not something an operator, or we as an industry, can afford to get wrong.
What is clear to me though, is that the use of these services, and other technological advances aimed at assisting operators will likely eventually need clearly defined acceptable use standards given by the UKGC.
SBC: Finally, what constitutes a successful first year for this solution in 2021?
PM: Adoption. Key to this is how we work with clients to build out the early implementations. We are currently working on enhanced advanced testing with several brands which will allow us to make sure what we have is specific to their customers and their needs. Adoption will enable us to adapt and amend the service to ensure what we have suits both companies and their customer base specifically but also benefits the wider audience and the entire stakeholder base.
With that in mind early adoption or implementation will demonstrate to the regulator and the consumer that the industry is stepping up and taking its responsibilities seriously. We all know that trust and sustainability are key and to do that we need to be working together on solutions. Hopefully, W2 affordability will play a large part in the safer gambling arena over the coming years.