Given the increasing rates of problem gambling and possible UK ban on daytime advertising for gambling operators, responsible gambling is a current topic in the news at the moment. Following their workshop on the topic at the annual Isle of Man eGaming Summit in September, KPMG discusses how operators and providers to the sector are working to manage this.
Over 7 years of staging eGaming summits in the Isle of Man and Gibraltar, I have seen the social responsibility agenda emerge and gradually move to centre stage; with the Senet Group being established by key UK operators in 2014 to promote responsible gambling standards in the UK and to ensure that the marketing of gambling is socially responsible; and the Responsible Gambling Trust playing an increasingly important role.
Recent headlines might drive the casual onlooker to think that the social responsibility focus of the industry is in response to a massive increase in the incidence of problem gambling, but if you look at the data for a mature market like the UK, where we’ve had widespread online gaming for over a decade and in-depth studies throughout that time: the truth is that data doesn’t indicate any higher incidence in problem gambling today than there was 10 or 15 years ago. Large-scale nationally representative surveys of participation in gambling and the prevalence of problem gambling in Great Britain were carried out in 1999, 2007 and 2010 and the most recent of those, the "British Gambling Prevalence Survey 2010", conducted by the United Kingdom Gambling Commission, found approximately 0.6 percent of the adult population had problem gambling issues—the same percentage as in 1999. Since then, the Commission have relied on the health surveys for England and Scotland and the latest statistics from those surveys on the UKGC website show prevalence unchanged at 0.6%.
One might also be excused for concluding that the increasing focus of gaming boards on the social responsibility agenda is being driven by the actions of the UK Gambling Commission. If we look just at 2016;
There is also an increasing and very public focus on advertising; firstly by the UKGC whose new LCCP`s that come into effect 31 October 2016 state that “All advertising of gambling products and services should be undertaken in a socially responsible manner’ and also by the media who have made calls over the past month for a complete ban on pre-watershed gambling advertising.
There was a good deal of debate on the social responsibility agenda at the KPMG Isle of Man eGaming Summit last month, with a general sense that if you look at any of the social responsibility changes brought in, and at any of the LCCP provisions which are designed to support the licensing any of them. The difficulty is in the speed and the volume of new rules and being able to keep on top of them. It was felt to be a key driver of consolidation in the higher ranges of the industry, but also the reason why so many of the smaller operators are not really able to compete in a market like the UK. There was a clear sense that operators were “pro” social responsibility regulation, but were questioning whether it is balanced and commercially viable, with some commentators questioning at what point the industry turn round and say to the public, to the Government, to the Commission and even to the newspapers, ‘This is excessive, we’re a fundamentally well run industry and you are lumping us with more and more costs, and more and more social responsibility provision, which is not justified by hard evidence’
So yes, one could assume social responsibility is simply being imposed upon the gaming sector. However my work with the Boards of the gaming operators indicates that, in fact, the predominant driver of their social responsibility agendas is that this is an entertainment industry and no-one wants harm or crime to be a side-product of that entertainment. As an example, the members of the Senet Group voluntarily committed back in 2014 to a self-imposed TV advertising ban on sign-up offers (free bets and free money) before 9pm; the withdrawal of all advertising of gaming machines from betting shop windows; and the dedication of 20% of shop window advertising to responsible gambling messages. These are not the actions of an industry that does not wish to protect its customers, and of course the online industry is particularly well placed to offer that protection; online gaming is far more able to identify problem gamblers ahead of time, not through self-identification but because of the use of big data – the operators have the analytic capability to see the trends and red flags that give them greater insights, and they use them.
I have seen this commitment for myself through KPMG’s involvement in the scoping study for the establishment of a National Online Self-Exclusion Scheme (NOSES). The ability of gamblers to exclude themselves from gambling activity for a set period has been shown to be one of the most effective harm minimisation tools available, and in a recent study in New Jersey (1), was shown to be the method chosen by nearly 60% of gamblers seeking responsible gambling support. But in the UK presently self-exclusion is only available to gamblers at individual operator level – and relapses are hard to prevent whilst there are a swathe of new operators a gambler can turn to if tempted. So the industry have come together to set up NOSES to enable online gamblers to self –exclude from all British remote licensed gambling operators via a single interface.
In every other country which runs a national self-exclusion scheme, that scheme has been set up and operated by the national gambling regulator. This will be the first time that the industry has designed and set up its own scheme – and I believe that UK consumers will reap the benefits of that approach when the scheme launches.
So NOSES is a very good example of the industry driving its own change, and I think we will see more of it…
(1. Rutgers Centre for Gambling Studies: 2015 Report to the Division of Gaming Enforcement, New Jersey)