Crucial Compliance: Roadmap to Responsible Gambling 2021

As the focus on player protection in the iGaming industry continues to intensify, how best can we as an industry respond to this?

Recent regulatory proposals have polarised the industry as some iGaming stakeholders believe they are not practical and aspects such as affordability need to be taken into greater account.

Andy Masters, Chief Operating Officer at Crucial Compliance spoke with us to give his perspective on how the Pandemic has impacted our focus on the issue of responsible gambling and what this means for future growth in the iGaming industry.

The pandemic and subsequent lockdown have caused the issue of player protection to be more prominent than ever before. Why do you think some operators struggle in creating the most efficient responsible gaming models? How can this be improved in the future?

“This can be put down to two key areas, size and complexity against capability and resource. Large operators have lots of systems from lots of suppliers which all provide varying levels of player data depending on if they are retail, online or multi-channel.

Although the operator is under license pressure to match players, which ultimately does happen, the complexities mean that it is a systemically difficult task and often not carried out in real-time, even with substantial resources and capabilities in place.

Applying responsible gambling principles to this environment and building an efficient model which can be optimised is therefore a complex and time-consuming job. It also requires a strong responsible gambling product owner to drive implementation and optimisation.

For smaller operators with single brands and single platforms, they are dependent on the platform supplier or manual processes because they do not have the same resources or capabilities internally as larger companies have.

One size does not fit all, and a major part of this journey is increasing the quality of data capture to ensure the elements used to provide a full 360-degree view and support and player concerns are included.”

Responsible gaming tech such as the Crucial Player Protection (CPP) system sounds great but how easy is it to integrate into an operator’s system?

“Gaming tech can often be difficult to implement, especially if it was initially built for a different industry such as banking or for a different purpose such as KYC/CRM.

CPP is, however, built solely for the purpose of gaming player protection. Given our industry knowledge and experience across multi-national operators, multiple verticals and different platforms, we have ensured there are several ways to implement our solution.

This can be done either as a partnership, where there is virtual hand-holding while internal business intelligence accrues the data, to a full-service delivery and handover.

In the case of full service, it is up and running in 12 weeks, including the bespoke calibration of advanced markers and integration of any existing in-house or external models. We have a dedicated delivery team to make sure this is the case.

Without giving too much away, the underlying schema is designed to fit in with 90% of an operator’s standard regulatory metrics already held in an SCV and the transformation of that data takes place within the toolset but bringing in richer data from other sources is all part of the delivery, too.”

The CPP uses Markers of Harm to judge player behaviour. What are some of the most common markers of harm that operators should be looking out for?

“The markers of harm are based around the PWC work carried out in 2017/2018 which include speed of spend, session times, late-night play and deposit activity. This is all modelled to each company’s player profile and regulatory requirements.

These markers are descriptive and can be linked to potential harm, which is crucial for when you want to talk to a player about why a change in behaviour has taken place over a short period of time.

They are also great when looking at how similar player activity deviates from the norm; after all, we are all uniquely the same when put into groups.

One of the stranger markers we have seen and modelled is that the number of inbound customer service contacts, regardless of reason, is a contributing factor to identifying potential harm. It is clearly not the highest factor but significant, nevertheless.

Moving forward and as we see the impact of better responsible gambling processes and the changing behaviours that will bring, we will see the dilution of the models created over time so they become less descriptive and accurate.

Tools and models will need to respond to the ever-changing velocity and value of key markers and changes in regulation while keeping a “like for like” calibrated algorithm for player comparison purposes.

In basic terms, the markers need to be dynamic with a robust mathematical and behavioural framework and not run off with unchecked, unreasoned AI.

We cannot fly by flapping our arms up and down and anyone who uses Amazon knows sometimes that its AI model creates amusing outputs –  not something we can have when it comes to  player protection.”

Some industry commentators believe that data orientated player protection technology is limited in its capabilities because of regulatory constraints. Do you agree and what can be done going forward to improve this?

“We must use what we are given in terms of data and that is often driven by regulation. When it comes to online, we have more data than most companies can currently utilise. But that is not the case for retail; currently, third party data is used to support basic customer matching to multi-channel players but still leaves a gap for retail only players.

However, most companies have a huge amount of data not currently used for player protection which may sit in CRM systems or just be a file in a database. This is where an experienced partner and a system like CPP really adds value by analysing what is there and using that in an optimised way.

Going forward, the use of third-party data is crucial. The industry is aware of issues in getting this data, especially in areas around affordability because, unlike credit agencies, gambling companies are excluded from most of the data feeds available.

This means that innovation is needed, and this takes time and resources for the third-parties tasked with finding solutions. It should also be pointed out that when companies do invest resources to find solutions for operators to improve player protection, the industry needs to embrace them and support these vendors.

These vendors will only continue to invest if this occurs as the relationship needs to be collaborative.”

Editor’s note: From speaking with Andy it’s clear that in order to stay compliant and competitive in the market, effective utilisation of third-party data is crucial.

The gaming industry is unique in regard to the sheer volume of data points held on players, giving us, as an industry, an advantage in being able to best protect a player, while ensuring they still have a fun experience.

Understanding this balance will be the key to sustainable growth and company’s like CPP offer a fantastic solution to operators who understand the benefits of a data-focused responsible gambling strategy.


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