Managing Responsible Gambling in Light of the New UK Customer Interaction Guidance

Mindway AI’s Solution Engineer Simon A. M. Hansen provides us with insight into the new rules and guidelines to increase player protection set by the UK Gambling Commission.

The UK Gambling Commission recently released their revised Customer interaction guidance – for remote gambling licensees, which will come into effect September 12, 2022. This guide will replace the existing version published in 2019 and will require operators to review and in many cases improve on their existing Responsible Gambling (RG) processes to stay compliant. The new guidance further specifies how operators should take appropriate action in response to observed gambling harms and how they should react to strong indicators of harm in a timely manner. Further, the guidance specifies indicators that gambling operators must consider when assessing the risk level of a customer. By now it should be clear that relying on simple deposit and loss thresholds is not sufficient for meeting the license requirements. Instead, operators will need advanced systems that can produce intelligent risk assessments and trigger appropriate actions in response to the identified risk.

As the list of requirements grows bigger, it also becomes more difficult to develop and maintain adequate RG detection solutions, and with the deadline getting close, UK gambling operators will need to make RG one of their top priorities. One solution for operators not confident that they will be able to meet the requirements before September 12, is to look for external parties, who can deliver RG solutions. At Mindway AI, we have developed a risk assessment solution called GameScanner, which makes it easier for operators to comply with the new requirements.

“A responsible gambling system is not just something anyone can build anymore because the need for domain knowledge and technical capabilities increases every time regulators across the world publish new requirements.”

The GameScanner solution can be viewed as a virtual psychologist because it combines AI with human expert assessment to provide a detailed risk evaluation of all active customers, which enables operators to be proactive and individualized in their intervention approach. This is the core of the GameScanner solution, but it does a lot more than just producing risk evaluations. The GameScanner solution comes with a user interface called GameScanner Analytics, which allows operators to efficiently work RG cases and analyse their RG effort. As an example, operators can use the powerful visualisations available in GameScanner Analytics for efficient manual review of player cases of interest. They can also log actions, decisions, and player communication in the system, which can be used by the analytics module to understand the effect of each intervention type on different player segments. Lastly, the GameScanner solution can be integrated with existing operator systems in a way that supports the specific responsible gambling workflow of the operator. The rest of the article will cover in more detail key areas of the new Customer interaction guidance and how the GameScanner solution supports operators in being compliant in the UK market after September 12.

When the new guidelines come into effect, operators will be required to incorporate a minimum of seven groups of risk indicators in their risk assessment of each individual player as well as their own indicators. Many operators will therefore need to take a critical look at their existing detection solutions to decide whether they sufficiently cover all risk indicators. Some operators will find that they need to expand their existing model, which can be a difficult and time-consuming process. This is especially true for complex behaviours such as loss chasing and erratic betting patterns, which are difficult to sufficiently capture using simple metrices. GameScanner offers a detection framework that includes all markers specified by the UK Gambling Commission as well as additional indicators derived from the scientific literature and expert knowledge. Further, operators may choose to invest in an expert-trained model, where the model is tuned to the specific customer base and data available to the operator for maximum precision.

In addition to new risk indicators, operators are also required to have automatic processes in place in order to respond to strong indicators of gambling harm in a timely manner at all times of the day. Further, all automatic decisions will need to be reviewed manually by operators’ staff, and customers should be allowed to contest any automatic intervention. Using Mindway AI’s newly developed alert system, operators can construct various rules that trigger different levels of intervention automatically and flags the player for review in the GameScanner Analytics system.

Having the opportunity to add their own rules to the system is important as operators are responsible for the protection of their customers when using third-party solutions like the GameScanner. With GameScanner, operators are offered the strength of unbiased risk assessment as well as the opportunity to add their own business rules and processes in order to create an efficient gambling harm safety net and ensure confidence in the solution.

“Operators are responsible for meeting the requirements from the UK Gambling Commission when using third-party solutions such as the GameScanner. We take this extremely seriously by including the operators in the implementation phase and by engaging in ongoing dialogue with our clients. Through expert training and implementation of operator-specific business rules we can increase confidence in the system.”

A third central aspect of the new guidance is the need to continuously monitor and evaluate the effectiveness of existing RG policies on an individual level and group level. At the individual level, operators need to evaluate whether a given action was effective while analysis on group level is used to demonstrate the effectiveness of the overall approach and identify areas for improvement. Preparing such analyses is usually a tedious process because data needs to be collected and analyses need to be carried out by skilled employees, who can work with these kinds of complex data. With the GameScanner Analytics solution, operators will be able to run analyses with a few clicks to easily understand the effect of their current actions and decide whether they need to adjust their existing approach. Furthermore, they will have a complete overview on the individual customer level and be able to combine AI risk assessment, previous player communication, existing limits, and historic gambling behaviour to make the best decision in relation to whether a specific customer requires escalation.

In sum, operators who have acquired a GameScanner license will get an all-in-one expert-trained AI system, which supports both RG operations and analysis. The GameScanner license includes continuous support and maintenance which means that the solution will not only help operators be compliant today but also next time regulators issue new guidance. At Mindway AI, we look forward to helping operators manage their RG operations today and in the future.