Peter Hannibal, CEO of the cross industry strategic body, the Gambling Business Group, urges operators to show why applying an algorithm to tracked play data is unnecessary as well as being a very bad idea.

Whoever crafted the phrase ‘the devil is in the detail’ could well have been referencing the current outlook and mind set of our esteemed regulator.  The Gambling Commission’s oxygen demanding, even lung bursting Proposed changes to LCCP requirements for customer interaction and alternative dispute resolution, and call for evidence on gambling website blocking software, should not fool anyone. The reference to ‘website blocking software’ categorically does not mean the rest of the consultation is not relevant to land based operators.

Quite the opposite. In fact the proposals on ‘customer interaction’ and ‘alternative dispute resolution’ have important implications for ALL Operating Licence Holders – with the notable exception of lotteries.

The most significant are the additional requirements relating to player ‘interactions’. The consultation lists all of the scenarios in which operators should consider making an interaction with their customers. The suggested requirements will not only be for all operating staff to make judgement calls on when or whether an interaction is necessary, but for those interactions to be recorded (safely) and then for the interaction(s) to be evaluated for effectiveness. The interaction itself is to then have three constituent parts; Observation, Action and Outcome.

Such an escalation over a number of consultations and communications is sadly becoming the norm. It misses or chooses to ignore the fact that the industry already carries out interactions, interactions that are an everyday component of the Know Your Customer philosophy that lies at the very heart of how AGCs and bingo clubs behave and behave responsibly.

Operators should document the details of this in the responses they make to the consultations. What we don’t do well enough (because we have never needed to) is record the interactions. But times are changing and operators must prepare themselves for new practices that are coming down the line. They also need to ensure that in doing so they remain within the GDPR regulations.

What was that about red tape and making the task of business owners and job creators less burdensome?

Equally daunting is the Commission’s call for evidence on Category B gaming machines. Cynics may be excused for thinking this is  more an attempt to ‘prove’ the necessity of player tracking – a real favourite within the Commission but for many industry sages a scenario that will sound the death knell for the business – than it is a consultation in the real sense of the term.

Essentially it is asking operators how they are currently protecting their B3 machine players and as a consequence why ‘Tracked Play’ should not be imposed on the industry. If these questions are not answered effectively and convincingly, the Commission will conclude that they have an obligation to take action themselves. 


Of course an important part of the solution is for players to stay in control of their gambling activities. However in the event that they don’t, there is an increasing obligation on the operator to spot when it happens and to protect those players from harm.

The facts are that as a customer centric industry we actually do plenty of this every day, but we do it tacitly and almost as ‘second nature’. In the current climate we need to do more than just act. Our everyday actions now need to be recorded and kept as evidence of a proactive approach towards customer protection.

This has to be a far better and more effective approach than applying an algorithm to tracked play data, which I fear is exactly where the Commission would like to take us.