Lived Experience Community Respond to Remote Customer Interaction Call for Evidence

Updated: Feb 17

A team of lived experience researchers surveyed 133 individuals from the lived experience community consisting primarily of individuals with gambling experience and a smaller contingent of affected others between 21st January 2021 and 29th January 2021.


The value of lived experience cannot be overstated, especially in a neglected public health issue where understanding and awareness is limited. Ultimately, there is no way of ensuring that only individuals with genuine lived experience fill in an online survey. Therefore, we utilised a mixed-methods approach to maximise the internal validity of any findings reported.


Contents

1. Duty of Care

2. Responsibility for Safe Gambling

3. Gambling Activity Data

4. Customer Data

5. Soft Cap

6. Hard Cap

7. Uniform Restrictions

8. Gambling as a Financial Service


Duty of Care

“Do online gambling companies have a duty of care, to interact appropriately and in a timely manner?” N = 132 survey participants. Nearly all (94%) survey participants felt that online gambling companies have a duty of care, to interact appropriately, and in a timely manner.

Based on the experiences that you have seen, why do you think gambling companies should have a duty of care to its customers? (N=125)
Both harm prevention and addiction (49/125)
I am a compulsive gambler that would make numerous attempts to load money into accounts when I had no funds…”
“Because of the power of addiction and the harm it can cause to both addicts and their loved ones.
“Throughout my addiction…I never once received an intervention from anyone…despite displaying clear levels of harm…A compulsive gambler like myself just doesn't see responsible gambling messages. My addiction doesn't compute this self-serving system..
My son took his own life due to his gambling addiction and one of the things I found after his death was his frustration with the gambling companies when he reached out to them for help.
Harm prevention (40/125)
“Prevention of problem and underage gambling”
“gambling has the ability to destroy life’s on the first interaction. Inheritance blown on choosing red over black.
“Player protection, LCCP, the right thing to do
“Because they sell a harmful product, and for moral obligations”
Addiction (31/125)
from my own experiences it's pretty obvious when someone is struggling to control gambling and I'm sure the online sites can see this but choose to ignore it”
“Because they provide a high intensity service with known addictive triggers”
“They have the data and algorithms to identify their at risk users, but have too often exploited them by rewarding them with free bets and VIP bonuses rather than intervene positively.
“When sometimes they're the only person that can see how bad someone's gambling is. They should have a duty of care to step in and make sure that person is being responsible and isn't showing the signs of addiction”
Neither (5/125)
“Because the customer has found themselves in or on one of their licenced premises”
Based on the experiences that you have seen, why do you think gambling companies should not have a duty of care to its customers? (N=8)
Should have a duty of care (3/8)
"They should care more"
"As I am a compulsive gambler they should stop the TV adds and also we as people are starting to expect gambling as part of normal day live as everywhere you turn its about gambling"
"They should care thats the end of it or even better they can f*** off!"
Personal responsibility (2/8)
"There is a lack of personal responsibility in the current climate with those who choose to commit crime being able to use gambling as an excuse for their actions with now many militant anti gamblers using crime as an excuse to profit in breach of the Gambling Commissions own objectives"
"A person must take responsibility for their own actions."
Unclear (2/8)
"Yes"
"I believe they take care of their customers to the extent that they are predisposed to consume and develop their spending power with them."
Inadvertently caused more harm (1/8)
"Creation of perverse incentives/ risk-free gambling. If vulnerable people can get their losses back, they are more likely to experience more gambling-related harm than less."

Responsibility for Safe Gambling

“Is it fair for safe gambling to be solely the responsibility of the customer?” N = 133 survey participants. Most (92%) survey participants believe it is unfair for safe gambling to be solely the customer's responsibility.

Could you explain where you think the responsibility for safe gambling should lie and why? (N=133)
Both the individual and the operator (50/133)
It is a joint thing for both customer and client but the overriding responsibility must be with the company providing the service. A pub would not keep serving alcohol to a customer until they died of alcohol poisoning, so a gambling company should not be allowed to facitate gambling to the point where a person has no money left for food, rent, heating etc...
“With the individual and the provider. Gambling is addictive and those who are susceptible and who become addicted need support and care that the providers, without regulation, would do nothing about because their sole motivation is profit.
“It should lie with both parties. But as a CG I couldn’t see that I was digging myself into a hole financially and had there been some safeguards in place to monitor or alert that I was gambling excessively I might not have gotten into so much trouble with it all.
The operator (44/133)
Bookies should be looking after their clients.
The Gambling Industry profit from addiction. Their bottom line is profit. Their most profitable customers are those on the addiction spectrum. If they have no responsibility, they will encourage and permit addiction. That's what people think about drug dealers… Grooming like this is closer to what is seen among paedophile rings, and human trafficking.
Broad and multiple bodies (30/133)
Gambling Regulator/Commission/Public Health/Government. As with any legal activity that is known to cause harm, safeguarding must be put in place. The Customer of course is ultimately responsible however they most be informed/protected and not coesered into harmful behaviour by gambling companies”
“responsibility ought to lie with everyone. The DCMS, The Gambling Commission; the banks, the operators; the people themselves. We all have a part to play”
Unclear (6/133)
“Amounts you’re able to stake should be some what relative to what you actually earn (money you’ve won would be treated differently) so that people don’t lose a months wage in minutes and then get into debt just to survive the rest of that month etc”
Individual (3/133)
"People have to take some responsibility"
"The 18+ consumer. A gambling company can never accurately determine   how much a person is able to spend on their leisure and entertainment   activities, so the onus is on the adult to do so."
"With the customer who makes a choice"

Customer Data

“What information should operators obtain to ensure customers are not gambling beyond their means?” N = 133 survey participants. The majority of survey participants consider income (80%), lines of credit (77%), loans (71%), payment history (68%). Just under a majority of participants felt that collections accounts (50%) should be considered and a small portion (6%) of survey participants regard that operators should obtain no further information. Additionally, 5% responded with suggestions such as "source of money" and “all and any suitable information that would be easily available”, should also be obtained.


Gambling Activity Data

“Which gambling-related factors, other than money spent, should operators have to consider?” N = 132 survey participants.

Why should an operator look at other gambling-related factors as well as the amount of money spent? (N=128)
"A gambler's behaviour and circumstances will directly influence the amount of money they spend gambling."
"Because gambling when it becomes a problem is not just about money... Money is not the only factor, spending more time playing slots rather than spending time with family and friends or working for instance."
"Because it would quite quickly become apparent to an operator that   someone who is gambling 8 hrs a day, multiple deposits and manic activity that the person was/is out of control"
"As the other factors often are an easier indication that individuals have lost all control"
"Because gambling addicts lose interest in their lives and isolate themselves spending to much time gambling, Also could be drug related"

Soft Cap

“Do you agree with a £100 per month affordability threshold?” N = 133 survey participants.

How would you have reacted if you were stopped from gambling until you passed an affordability assessment? (N=132) 
Positively (47/132)
"If it was after £100 I would accept that. If it was after £1000’s of pounds I would be annoyed. To me it says, we can take a lot off you and then decide whether you are spending within your means and if you are not you have lost that money. If it’s done at the start the responsibility returns mainly to the customer."
"I surpassed that threshold 100's possibly 1000's of times. If it was introduced early on in my gambling career then maybe I would have saved a lot of damage"
"As a gambler without a disorder, I would be happy knowing that the operator was acting responsibly.I would be satisfied that they were acting in a matter that was both appropriate and acceptable. I would be appreciative that I might not be allowed to gamble if I could not prove I could afford to lose. However, as gambler with a disorder. I would be angry that I have to wait. I would not be understanding or patient. I would be bitterly disappointed and frustrated and I would be concerned that the affordability checks would prevent me from gambling."
"Had it been done early on then it would have avoided many losses and harm and I would have engaged with that. If you don’t have a gambling disorder then why would you mind, if reasons are explained and they are fair I see no reason why a person wouldn’t want to engage."
"I've gambled 3 times. Once, I gambled £300+ on a cricket game, as I chased and chased. I wasn't doing so well mentally. If they stopped me at £100, and that was set as the maximum of normal, then I wouldn't have continued to gamble. I would have thought that £100 is enough money lost."
Both positively and negatively (39/132)
"Angry. Frustrated. Relieved. Relaxed"
"As a gambler without a disorder, I would be happy knowing that the operator was acting responsibly.I would be satisfied that they were acting in a matter that was both appropriate and acceptable. I would be appreciative that I might not be allowed to gamble if I could not prove I could afford to lose. However, as gambler with a disorder. I would be angry that I have to wait. I would not be understanding or patient. I would be bitterly disappointed and frustrated and I would be concerned that the affordability checks would prevent me from gambling."
"At the time I would of been gutted but being a compulsive gambler and recovering addict looking at it now it is a major factor to helping people out"
"I wouldn't have been happy, because I believed I was in control, but in hindsight it would have made a huge difference to my life. I would often gamble away a month's salary within minutes of waking up on payday. That's clearly not affordable. If my gambling was then limited the damage would have been limited. It seems to me to be a simple correlation."
"I would have been disappointed later on with my gambling but it would have helped me at the start to highlight there was caution to me doing this so I need to take note."
Negatively (32/132)
"At the time thinking back I would have likely attempted ways to go elsewhere. Such as another operator. I'd likely also have attempted to show wasy in was affordable when wasn't."
"I would have been angry because I only ever wanted to gamble - I would have never passed an assessment as I gambled to excess, maxed out on all forms of credit, and with stolen funds too. Whether this will have made me reach out for help sooner I really couldn't say. It would have made it tougher to gamble though. I think it's important to remember that most people in the UK won't come remotely close to spending £100 p/month on gambling. A study in March 2019 found the average disposable income in a British adult was just £276 - food for thought."
"Angry, this has happened in the past on a number of occasions in the past in live casinos (although the limit was dramatically higher) 

 I was only ever questioned whilst in a huge spiral with increasing bets, so my rage was the fact I could not instantly place a roulette bet, always felt, of course my number is going to come down now."
"This happened to me and due to being a gambling addict I was quite annoyed and tried to open other betting accounts. Someone could have 10/20 betting accounts with different companies so the £100 per account could be questionable. The company in question asked for affordability and I provided wage slips which showed I was earning £1000 a month but depositing £3000+ per month. The company then allowed me to continue which looking back is shocking."
"I wouldnt have liked it and just found somewhere else to gamble with no threshold issues
 always somewhere that will take your money"
Unclear/unsure (14/132)
"It would depend on the trigger point and the ease of completing the process."
"Can’t say but I guess it would have made a difference"
"Friction, slow down decision making, reconsider expenditure."

Hard Cap


“To prevent gambling-harm, what should be the maximum percentage of disposable income that should go towards gambling?” N = 129 survey participants. 75% of participants agree 20% or less should be the maximum disposable income going towards gambling. Half of the participants agree 10% or less of disposable income should be the maximum. The modal and median percentage reported was also 10%.


Uniform Restrictions

Should all gambling products be treated the same with the same set of limits and restrictions?”. N = 133 survey participants.

Should be treated the same (93/133)
"Because they can all get out of hand. An unmanageable for problem gamblers"
"Because gambling is so prolific in our country its like its our national sport! With the level of abject poverty we have, coupled with the high suicide rate, its not something to be encouraged at a young age. With a blanket age restriction, we are protecting young people from harm. My gambling problem started at a young age and I did so much damage, I'm still paying for it 30 years later. If it were incredibly difficult to gamble at a young age, with the support that is available now, I would hope the vast majority of young people would not have to suffer the pain I went through."
"Gambling is gambling. some people have problems with bingo some with horse racing some with slots. problem gamblers can be addicted to all types or just 1 specific type of gambling. everyone is an individual case."
"Any form of gambling can become addictive"
"Will stop people from spending above there means and getting in debt regardless of what they are gambling on"
Should not be treated the same (40/133)
"Blanket one size fits all approach wouldn't be applicable as product ranges differ drastically."
"They have different risk profiles"
"There are differences in SOME products, which have a dramatically larger amount of winning players, but thats games would be completely changed, poker for example in a live casino has an averagebuy in of £240 per game much higher on average than slots or casino games. The review would punish poker players in a much more aggressive manner"
"Gambling differs. Think of alcohol. Spirits like Vodka are poured in   measures. You can't order a pint of Vodka at the bar! Whereas lower impact alcohol (take lager), can be ordered in larger amounts. A similar approach should be taken with gambling. Gambling should be categorised. E.g. the more dangerous, rapid and most harmful products (i.e. online slots and roulette) should be limited, or at least forewarned. Less harmful products (i.e. lottery tickets) should be   categorised as lower harm. A traffic light system could be used, like on food packets with sugars/salt content. Red= dangerous. Amber= not great for you. Green= fine to use."
"Different sporting events may happen once a year for example the grand national, so someone may want to place £100 on numerous horses for that event. However, virtual horse racing is on every 30-45 seconds so placing £100 on each race every day should not be allowed. Maybe restrict a customer to so many virtual races or X amount of spins on slots and roulette"

Gambling as a Financial Service

“Should gambling operators be required to conduct as thorough checks as banks have to go through when issuing loans or credit? (N=132)
Yes (107/132)
"I believe that they should and possibly the gambling companies set the limit for each customer depending on their credit history/score. If a customer believes this should be increased then they should provide clear evidence that it is affordable to them"
"exactly correct, people are using large sums of money as a 'gamble' without any credit checks whatosever"
"It would certainly help problem gamblers"
Potentially (8/132)
"Not at first only if want to wager larger and longer amounts"
No (10/132)
"No as customer not seeking a financial product. There are other ways to review customer affordability. What about customers who play lottery or go to Grand National once a year?"
Unsure/unclear (7/132)
"I think proof of income when setting up and online account is absolutely necessary."
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