Marketing to Self-Excluded Consumers Through VIP
There has been some interesting debate on social media around the role of targeted marketing and advertising to self-excluded players by gambling firms recently. News articles have also appeared in the press over the weekend in The Sunday Times and Daily Mail on gambling marketing to the self-excluded. Much like many topics in relation to making gambling safer, there are somewhat polarised views from those in the industry relative to those that have been impacted by harm as to whether this happens. What should be made clear is that based on personal experience, individuals can still be marketed to whilst self-excluded. This blog will focus on the roles of social media marketing and then VIP schemes as a form of marketing when self-excluded.
Social Media Marketing
Marketing on social channels is becoming very effective. Targeting can be done via social media into specifics interests, prior posts, demographics and user locations. There seems a slight flaw in the current UK self-exclusion model where an individual who uses a Twitter ID for example to regularly contact customer support can still be marketed to via the gambling company using promoted posts even when self-excluded. The companies know the social media IDs of those who have self-excluded based and used chat/support via social media, so presumably these lists can be merged and provided to ad partners to stop this form of marketing? Although maybe not that simple, this is something the industry and GamStop should consider. Email marketing after all is just one channel and promoted social posts be it via Twitter or Facebook have a much higher acquisition rate.
Marketing Through VIP Schemes
It has also been claimed that “no regulated company wants to advertise to excluded customers from a moral, legal and commercial point of view.” This appears to be a view of senior industry executives, based on social media likes and comments, that such marketing is something that would not occur. From a personal experience, I can provide an evidence-based view as to how the most extreme form of gambling marketing, namely VIP schemes are used to market to self-excluded individuals. I shall reference what I have been informed from operator legal departments as to how VIP programs are indeed a form of marketing. I shall also reference extracts of my DSAR as to how self-exclusion and obvious markers of harm are in my view ignored. Anything quoted comes direct from a major operator.
My faith in the gambling industry stopping predatory marketing to individuals who have self-excluded is based on my own experiences, where having the exact same email, username, forename, surname, DOB and known prior address went without concern despite being self-excluded. Not providing any ID, nor indeed being asked for source of funds when you have deposited over £110,000 via an eWallet seems against due diligence when you have not checked affordability, nor have a bank account registered for an individual. For context, these examples are from late December 2018 and although DSAR evidence in Feb 2019 confirms: “this would not be permitted in today’s environment” the VIP offers, and bonuses continued even though self-excluded.
The legal department view on VIP
When you are going through the cycle of unaccountability and confusion that is the complaints process, as I have for 16 months and have exhausted the internal customer comms teams, data protection, ICO, IBAS, ADR and the UKGC – you also receive letters from operator legal departments to make you give up. I have had what I believe to be concerning evidence around VIP schemes and marketing to the self-excluded in many parts of my DSAR information. When I repeatedly asked about being given VIP status, in a legal department letter, I was given the answer that VIP schemes are actually a form of marketing:
“our VIP program is designed to offer enhanced support, reward and offers to loyal customers. The service is available on an invitation only basis.”
Where the legal department confirms VIP schemes as marketing is further confirmed when it is stated:
“The offers you received were standard communications. If a VIP member does not want to receive marketing communications, they can advise us of this and will not receive marketing promotions and offers. The facility to change marketing preferences is available.”
The fact that the word marketing is used x3 times in the above, leaves us in no doubt that VIP schemes are indeed marketing, and these are being used to target the vulnerable. I have a multitude of evidence with regards to ‘responsible gambling’ concerns on my account. Spiking 656% of RG reports, VIP and RG teams emailing each other and RG alerts at the exact same time as gold, silver and platinum status being allocated with no checks on the same day. At the time of being engulfed by addiction I was given no idea as to how to exclude from these promotions. The above clearly provides evidence that marketing to self-excluded customers does happen.
Responsible gambling seems ignored by those in VIP operations presumably on the basis that profits, and incentives are more important than consumer protection. Even when questioning the criteria for the VIP schemes and if these marketing schemes are based on bookmaker profitability and how VIP does not help when £50,000 down, I was oddly ignored. If the industry is serious about marketing, responsible gambling and VIP status then these three functions need to be much more transparent as to their intentions going forward.