June 25, 2019

The Gambling Commission recently released a video which provides an introduction to customer interaction and includes information about what an operator needs to be doing in order to comply with LCCP Code 3.4; identifying customers who may be at risk of, or experiencing, gambling harm.

In the video, the Gambling Commission explains that the identification and communication between an operator and a customer is essential for LCCP compliance.   Operators are expected to invest in systems designed to identify the types of behaviours which might indicate that a customer is gambling out of control or developing problems with their gambling (e.g. is a customer staking large amounts, gambling during unsociable hours or displaying risk flags in their gambling behaviour).  Operators must have clear interaction policies in place which provide staff with sufficient information on when interaction should occur with a customer and what is the most appropriate communication method.  Operators are expected to make sure that their policies/processes are tailored towards their offering in order to be compliant, which can prove a challenge for many licensees.

The Gambling Commission are expected to update their guidance on customer interaction following the outcomes of a recent LCCP consultation which is due to reinforce the provisions of SR Code 3.4.1.  Operators would be well advised to review customer interaction processes to account for the Commission’s latest guidance in an area which will undoubtedly be a focus of the Commission’s attention over the coming months.