E is for ethics

Lisa Buchan discusses the social cost of the egaming boom as the industry faces charges it is not doing enough to control the access of young people and problem gamblers.

One main objective of the UK’s Online Gambling Act is to combat the growth in problem gambling and “for the first time,” warns the newly-established Gambling Commission, “we have the power to do something about it ”.

      Many UK operators are already tackling responsibility issues in their online activities. But the internet knows no geographic boundaries; children can try out any site regardless of jurisdiction and a browse around the web reveals little consistency in approaches to under-aged and problem gamblers.
      UK firms may need to go beyond some of the proposed licensing provisions on social responsibility and current practices in the remote environment to ensure traditional marketing, customer-care procedures and web design do not run counter to social responsibility objectives.

Too much variety

The UK long had a strict regime to prevent young people from accessing physical gambling premises. But   in the absence of specific regulation of online activities, some operators have either applied the terms of their UK betting license to remote platforms or have had their online sites licensed outside the UK, where codes and conditions vary.

      The sites have varying approaches to posting age limits. Typically UK betting sites have ‘not under 18’ icons at the bottom of the home page. But occasionally there is no warning at all on the home page, and the restriction is only explained at the point of account registration.
      On many UK sites, even when there is an 18+sign, it is not clear exactly what it means; passing the counter over the 18+ icon doesn’t necessarily trigger a link. Furthermore, terms and conditions differ considerably in the warnings to minors about not using any part of the site, about forfeiting any winnings and possibly being reported to the police.

      The Gambling Commission will require operators to provide evidence that they are trying to prevent underage gambling and to “monitor the effectiveness of their systems ”. The consultation document doesn’t say anything precise about age labeling, but judging by the current state of affairs, some norms need to be established so that age restrictions appear on every part of a site and warnings for young people are ‘in your face’.
      A few years ago gambling sites were badly embarrassed when a report by the UK children’s charity NCH demonstrated how easily an underage user could register a Solo debit   card  on 30 out of 37 gambling sites surveyed.

“The internet knows no geographic boundaries; children
can try out any site regardless of jurisdiction

      One answer to controlling access is age verification (AV). It involves a third-party check on some of the account details against public records to make sure that the account holder is a real person.
      AV already figures in voluntary codes of conduct for membership in UK organizations such as the Remote Gambling Association (RGA). GamCare certification (GamCareCert kite mark) and Citizen Card, the non-profit organization promoting age ID schemes offline and online. Their conditions require AV to be routinely run on high-risk types of payment such as a Solo, Visa Electron or Maestro debit card which can be issued to children as young as 11.
      Currently there is no way of knowing how routinely age checks are actually being carried out since AV is at the discretion of the operator. Ladbrokes and the National Lottery (Gamelot) are the only UK remote operators who openly promote the interactive age-check system developed by Citizen Card.

      The Commission will make AV on high-risk cards one of the licensing conditions for all operators but will not require routine AV on credit card registration. Banks do not issue these cards to under 18-year-olds and it is said to be too costly to verify all credit cards registered for betting accounts. To increase transparency and to provide consistent AV assurance, the Commission could also require egaming sites to post the logo of the AV system in use just as they post acceptable payment systems on their home and account registrations page.

Getting help

The provisions of information on where to get help is more or less a UK industry norm both online and offline. Many egaming sites have a link on the bottom of the page that leads to a message about sensible or responsible gaming where they can promote help organizations such as GamCare, GAmAid, Gamblers Anonymous or Gordon House. Others also post the logos of these organizations on the home page.

      The authorities and the industry are aware they could do more to step in directly to help problem gamblers. Most online operators already have the means to exclude fraudsters and gamblers who run up serious debts, and they know a lot about problem gamers through their online transactions. At the moment, however, online operators primarily rely on systems of self-exclusion.
      The best companies are serious about promoting the self-exclusion schemes. Some sites contain an online registration form, but most provide customer care contact details. Some operators put the information in a prominent place on sites so that players keep seeing this message.

Tacking self-exclusion

The real question is whether operators should be required to co-operate more on self-exclusion. For people brave enough to admit they have a problem, and to fill out the forms to self-exclude, it seems absurd that they can then easily click on a competitor site. US-based software firm Gamblock provides a download that problem gamers can install on their computer to help restrict access to all gambling sites. Few gambling sites actually provide a link to Gamblock, but it is the sort of programme which the Gambling UK Commission should encourage UK operators to provide for free.
      The Commission says it is open to suggestions on how operators can notify each other about self-excluding players but does not want to establish a database because it would be expensive. But given the profit margins on turnover for egaming, it’s hard to believe cost is the issue. Others in the industry play the data privacy card as a reason for not sharing information on self-excluded players. However, operators share data on fraudsters and are required to provide information where money laundering suspected or credit ratings are called into question.

      It should be possible to use the data of people who confess to having a problem to work out exactly what patterns should ring alarm bells. Given the anonymity of the egaming relationship with the customer, it should be possible to discreetly approach the customer online and check they do not want help to self-exclude or reduce the time and amount of play. A self-exclusion network is feasible, and may not be as costly as the Commission implies. There could also be a significant first-mover advantage for the company in the sector which genuinely tries to build a cross-industry self-exclusion scheme.

Insufficient training

For the online operators to go beyond self-exclusion and become more interventionist, there would have to be a different approach to online customer care. Our assessments of egaming practices suggest that in the remote environment, employee training for detecting and dealing with problem gamers is patchy.

      Although a few key supervisors may be able to handle tricky cases in the customer-care centre, staff in call centres and in other areas of operations have received little basic information about the help and training organizations such as GameCare, can provide in recognizing the basic signs of problem gaming.
      Although there are exceptions such as Ladbrokes, the online industry recognize there is a steep learning curve ahead to develop effective training, software and procedures for helping problem gamers.
      The Gambling commission’s approach to legitimate marketing is to make a distinction between unfair or potentially harmful inducements to gambling, and ordinary marketing or publicity, which offers innocuous inducements. It admits “We have not yet found a satisfactory formulation to distinguish the innocuous form of inducement form the potentially harmful”  but current practice shows the pitfalls of both ordinary and extraordinary marketing.

Constant vigilance

The Advertising Standards Authority (ASA) and the Commission need to be vigilant regarding marketing tactics that could be seen as grooming young people with subliminal or explicit messages. But there is another aspect to ordinary marketing the Commission will also need to tackle.
      When it comes to gambling and betting marketing, the emphasis is always on the chances of winning, not the odds of losing. It isn’t only vulnerable groups that would benefit enormously if there were greater transparency about the risks of gambling, especially in the remote environment which is experiencing the greatest growth in young and problem gamblers.
      The Commission will devise a code of conduct to do with fair and open gambling, meaning “that games or bets are delivered consistently in the line with the published rules and stated odds ”. The problem has been that the odds are not clearly stated in terms of loss. Camelot is exceptional in having a rating system for the odds on its lotteries and games. The languages is easily understandable and could be a model for the rest of the industry.

      Being transparent about the odds of losing is the most potent way for online operators to educate young people. As gambling becomes more sophisticated and moves to remote platforms, labeling can also help protect the industry against charges of ‘mis-marketing’ their games. This is comparable to what is happening in financial services where full information on risks is necessary as a protection for both the purchaser and the provider against charges of ‘mis-selling’. With labeling, online operators can continue to use ordinary marketing which presents gambling as a chance to win, but with a fair and clear user-beware warning.

      The industry need not be afraid that frankness on the risks of gambling and measures to protect the vulnerable will have an impact on the bottom line. Research suggests it is the functionality of the site and speed of the software that makes a site more attractive. It is to the advantage of the entire sector that the most profitable companies should also have the strongest reputation for the responsible practice. That means doing everything possible to ward off those who do not have the discipline or the understanding to gamble sensibly.

The importance of age verification
Free play provides a spectrum for different social responsibility approaches. At the stricter end of the scale are William Hill and Ladbrokes, both of which require full account registration and login in order to play-for-frees as well as for real money. By contrast, at Tote Casino you can download and play the game by simply creating a log –in with a name and password, while at Blue Square poker you can play for free without providing any ID.
      In its consultation paper, the Commission takes the view that it would be excessive to prohibit any access to free games without prior age verification “bearing in mind that no gambling takes place and that games of the type seen for free on gambling sites are also widely available to children and young people in retail game outlets. ”
      It flies in the face of common sense, however, to treat free or demo play as simply a sort of video game. Learning how to gamble with play money is a powerful marketing tool to introduce, if not to induce, people to gamble. It would be bad regulation if children could ignore the 18+ warnings on websites and so easily experiment with the trial games.

      If underage players are allowed to practice  gambling on UK-licensed  sites, then operators should be required to register the age and other personal details of all free-play users.
      From both a marketing and responsibility stand-point, knowing the age of all users on every part of a gambling site is important. Regulators should want to knows how many young people are testing out gambling sites, while operators would be able to track how many young people are testing our gambling sites, while operators would be able to track how many free-play visitors go on to become account holders. Gathering data on all age groups would reveal behavior patterns that, if properly analyzed, could help to develop software and customer-care procedures for detecting young problem gamers before they emerge as serious liabilities.

Model behaviour: Ladbrokes

Ladbrokes regards social responsibility as a key aspect of customer care and has been in the forefront of the industry in raising awareness and support for problem gamblers. Ladbrokes prominently displays its ‘stay in control’ message in all its shops and on its website. Players can put a cap on deposits and set time limits regardless of the platform they use.
      Both offline and online, employees are trained to inform customers with gambling problems how to seek help from associations such as GamCare and how to self-exclude or set limits for themselves. Working with GamCare, Ladbrokes was the first firm to design self-exclusion programmes, which have been adopted by others in the industry. It informs customers about how they can self-exclude from different parts of its operations. Details of customers who have opted out are logged at shops and in the online business news.
      All employees receive training on how to keep minors from gambling. The company conducts spot audits on its shops and call centres to make sure these procedures are working as intended.

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