VIP Incentives – What do UKGC proposed changes mean for the legacy of harm?
It was very interesting to read the apparent “progress” that the UK Gambling Commission have witnessed with regards industry challenges related to social responsibility and how they and firms will apparently address them going forward. Major changes to the licencing codes of practice are now proposed to be consulted on and changed. It would appear, that this recently formed industry working group into VIP schemes has on the face of it given a clear indirect admission of wrongdoing for the past in stating:
“All customers must pass through checks relating to spend, safer gambling and enhanced due diligence before becoming eligible for high value customer interactions”
Redress for those wrongly made VIP
This would appear to suggest that in the interests of better adhering to social responsibility regulations, these major betting firms have now assessed what has been happening now and in the past; made a judgement on what they have been doing wrong and how they will fix things going forward. The above statement from the UKGC is however quite concerning. Strict licencing codes of practice were apparently already in place for gambling operators around social responsibility. Given the suggested changes – it would seem that customers have been granted VIP status and inducements with insufficient checks. This may seem a bold proposal but for those consumers who can prove they meet the following criteria, then my personal view is operators should do the right thing and address legacy harm of VIP status through redress:
· Self-excluded from gambling with operator
· Registered with GamStop
· Has not gambled for over 12 months
· Attended GamCare funded counselling
· Attends GA or other NHS treatment
· Finances fully controlled by another individual
Perhaps the above proposals are worth considering, when we look at the area of redress for VIPs who have been wrongly exploited.
Profits over protection
Why a gambling firm would decide that no prior checks on spend, increasing frequency and value of betting was required in the past is very alarming. Having previously been granted VIP status when self-excluded in 2018 and not being the recipient of any prior due diligence in advance in terms of affordability or spend, this would imply this should have happened but didn’t – such was the desire for VIP management and responsible gambling departments to collude together and profile the likely addictive behaviours to ensure the maximum possible profit was taken, which in my case was almost a whopping £50,000 in less than six months. More than x10 the average disposable household income in the UK of £500 was deposited through multiple £5,000 deposits. Responsible gambling alerts were tracking at 656% but absolutely nothing was done in advance.
Also recommended as part of the discussions between the gambling firms was that:
“Reward programmes will also be required to have full audit trails detailing decision making with specified senior oversight and accountability”
An audit trail and accountability
How there can be no audit trails into such decisions currently is strange. Surely these do exist, but again are largely ignored. It cannot be that automated decisions are made, and VIP managers are then incentivised to encourage the consumer to lose more. The aspects of senior oversight and accountability becomes interesting. Just last week, for one of the first times we are now seeing the UKGC not only fine, but also remove senior employees from roles for their wrongdoing. This is the type of action that is now needed. Again, from experience it seems that when a data subject access is submitted for such an audit trail, you face continual delays in getting the data, if indeed it comes at all. It my own experience, it certainly seemed that the VIP and responsible gambling team were working together to exploit me as much as they could. An audit trail of decisions being made, account notes, emails and system reports must exist for those that suffered a legacy of harm but what we find is that gambling operators will not share this secret and most likely incriminating evidence.
The end for VIP schemes?
Gambling VIP schemes must be stopped. Restricting to under 25s is not enough. Social responsibility should not be optional for gambling operators either. There has been over a decade of profiteering over protection. People have been harmed that should not have been. Families have separated. Some have ended up in jail. Many have taken their own lives. Whilst there is a joint responsibility, it seems that gambling firms are their use of VIP schemes are immune from severe restrictions presumably because for some, they contribute up to 80% of company revenues.
Due diligence, affordability and safer gambling checks are now likely to be enforced. What these will involve, is yet unclear. For the many harmed by these VIP schemes in the past, we are watching very closely as the industry slowly but surely admits to past failings.