Selection of Standards
A comprehensive search of relevant databases yielded a large number of standards, best practices, guidelines, codes and regulations – the term standard is used here to encompass all of these terms. A sample of 15 key Standards were selected representing those that were up-to-date, rooted in scientific knowledge and expert opinion, drawn from new to mature internet gambling markets, and geographically diverse (Canada, Denmark, U.S.A., European Union, U.K., Jersey (Channel Islands), Alderney, and Gibraltar). These include:
- World Lottery Association’s “Code of Conduct concerning the use of electronic commerce for the distribution of gaming services"
- Responsible Gambling Council’s “Responsible Gambling Standards – Internet”
- International Association of Gaming Regulators’ “eGambling Guidelines”
- National Council on Problem Gambling’s “Internet Responsible Gaming Standards”
- “GamCare Player Protection, Code of Practice, Responsible Gambling; Remote”
- Global Gambling Guidance Group’s “Responsible e-Gambling Code of Practice”
- eCommerce and Online Gaming Regulation and Assurance’s “eCOGRA Generally Accepted Practices”
- British Columbia Gaming Policy and Enforcement Branch’s “Technical Gaming Standards for Internet Gaming Systems”
- Jersey Gambling Commission’s “Responsible Gambling Code of Practice Applicable to eGaming Operators”
- Alderney Gambling Control Commission’s “Technical Standards Extract Document”
- Gibraltar Gambling Commissioner’s “Code of Practice for the Gambling Industry”
- United Kingdom Gambling Commission’s “Gambling Codes of Practice”
- Spillemyndigheden’s “Guidelines for Betting and Online Casino”
- U.S. State of New Jersey’s “New Jersey Casino Control Commission Regulation Chapter 69O Internet and Mobile Gaming”
Voluntary with Potential to become Mandatory Standards
- European Commission’s “Commission Recommendation on common principles for the protection of consumers and players of online gambling services and the protection of minors from gambling” combined with “Commission Recommendation on common principles for responsible commercial communication of online gambling services”. The two Standards, intended to complement one another, were therefore combined for analysis .
Three independent reviewers identified 45 responsible gambling themes from the literature addressing some or all of the Standards. The comprehensiveness of the regulatory requirement related to each theme was evaluated on a three-point scale based on concordance of inter-rater coding; 1 = low, 2 = moderate, and 3 = high. Higher comprehensive ratings indicated a standard with more rigorous requirements and clearer direction for implementation.
Themes addressed with a high level of consensus across the majority of Standards were considered representative of current practice. For themes less commonly addressed, the researchers considered the quality of supporting evidence found in the literature. A number of less common but newer themes that were still in the early stages of evaluation but appear to be supported by extant data or have very strong face validity were considered to meet criteria as emerging practices.
The following social responsibility themes are addressed in two or more Standards.
Of the Standards, all required age verification procedures. Three quarters included requirements for the display of warning messages and restriction of adverting/promotions targeting minors, with more than half requiring the provision of filtering software for parents to block access to sites.
Player imposed limits
Two-thirds to three quarters required options to allow players to voluntarily set deposit and time limits, respectively. Setting loss and bet limits were required by approximately a third of the Standards.
Operator Imposed limits
Although around half limited account registrations, only 10% limited the number of debit/credit card registrations. Half the Standards required cooling-off periods and a third, built-in delays restricting continuous play. Relatively (a fifth or less) few imposed the requirement to set maximums for time, loss, deposit, and bet limits.
Half the Standards required player information feedback on session duration, and three-quarters, current and historical expenditure. Slightly less than half required the provision of a self-assessment test for players to determine their risk or gambling status.
All Standards recognised the need to include a voluntary self-exclusion policy with about three quarters specifying conditions regarding the visibility of the program for venue patrons. Around half referred to the length of exclusions and slightly less than half, reinstatement guidelines, a third temporary self-exclusion options, but less than a fifth, the option for renewal of self-exclusion agreements.
Third Party Exclusion
In regards to involuntary exclusion options, approximately a third recognised the need for a policy related to operator-initiated exclusion for players at risk, and third party exclusion orders.
Restrictions on Site Features that may Increase Risk
The majority of Standards did not address site features that could be interpreted as increasing risk for harm. Slightly over a third included policies to restrict features that encouraged players to maintain continued play, with less than a fifth and one in ten, respectively, addressed the risks of inferring that skill influenced outcomes, or encouraging play beyond affordable limits.
Slightly less than a third of Standards required operators to use data analytics to identify at-risk players, and fewer still, less than a fifth, required operators to use data analytics as the basis to intervene in some manner to address risk.
The majority of Standards acknowledged the need to include policies that encourage informed choice in decision-making and transparency of game operations. This extended to requiring policies related to the access to help-related information, rules of games, and warning messages. However, less than a third required operators to clearly display odds, and one in ten required the avoidance of myths that may act to reinforce risk.
Two thirds require responsible gambling training. Some require that staff training be evaluated by a third party (NCPG), and others, that it be updated annually (G4, JGC).
Responsible Advertising and Promotion
All but one Standard required an advertising policy that must protect vulnerable groups such as minors and at-risk and problem gamblers.
Complaint and Inquiry
Close to three quarters require operators to provide a clear complaint and inquiry submission process. For example, Procedures must exist and be easily accessible and clearly communicated to players (GamCare).
Free Play Guidelines
More than half of Standards address Free Play sections, requiring that operators prohibit minors, clearly communicate odds of winning and game rules, use similar payout percentages, and provide responsible gambling information (IAGR, G4, eCOGRA).
Evaluating new games
Less than a quarter of Standards require a responsible gambling evaluation process prior to the introduction of new games.
Standards vary widely in their social responsibility requirements. Across all codes, strong emphasis is placed on protection of minors, ensuring informed consent/transparency, enabling self-exclusion, giving players information to maintain self-awareness while playing, and providing tools for players to self-manage limits on time and money. Staff training, free play guidelines and clear complaint and inquiry processes, are also addressed by the large majority of Standards.
While almost all Standards require responsible advertising and promotion, few provide clear guidance on how to protect vulnerable groups such as minors and at-risk and problem gamblers. For example, in Canada there are detailed guidelines governing advertising and promotion of beverage alcohol but none exist for gambling.
Emerging practices include restricting site features that may increase risk, offering third party exclusion, and a social responsibility process to evaluate new games. Advances in behavioural analysis tools have demonstrated potential for identifying risk and mitigating harm in ways that exceed what is currently possible in the land-based environment. Yet a minority of Standards address this promising practice. As with all areas of regulation, and in particular those relating to technology, a framework for socially responsible practices in internet gambling should be continually refined as new knowledge and tools become available.
Judith Glynn and Dr. Karen Choi are Co-Principals, Strategic Science, offering social responsibility consulting in gambling, alcohol, tobacco and obesity. Contact: firstname.lastname@example.org
Dr. Alex Blaszczynski is Professor, Clinical Psychology, and Director, University of Sydney Gambling Treatment Clinic and Chair, Responsible Gambling Research Group.
Knut Walters founded Scientific Affairs, offering professional support in using high-quality scientific research for corporate affairs, public affairs and business development purposes.
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11 NOTE: Although not legally binding, Member States are encouraged to implement the Standards to ensure consumers and minors are protected at a similar high level in the EU. The Commission will review implementation by Member States 24 months after publication.