What Is A Singular Customer View In Gambling?
In simple terms, a Single Customer View, also referred to by the acronym SCV, is an aggregated and consistent representation of the data that an organisation holds about its customers. It can all be viewed in one place, such as on a single page, with the idea being that it allows companies to analyse their customers in a simple manner. In the world of betting, the benefit of using a Single Customer View is that it will allow gambling companies to stop people that have self-excluded from signing up with a different company.
Though the current system is supposed to stop punters from being able to just switch to a new bookmaker after excluding, the difficulty in knowing that a bettor has chosen to self-exclude stops this from happening on a consistent basis. The hope is that using a SCV system will ensure that people can’t just sign up with a different bookie or online casino after excluding themselves. It follows in the footsteps of rules imposed on financial institutions since the introduction of the Financial Services Compensation Scheme at the end of 2010, with the hope being that it will have a similar effect.
A Challenge Issued By The UKGC
In February of 2020, the United Kingdom Gambling Commission issued a challenge to the online gambling industry to explore and develop the use of a Single Customer View solution. The hope was that this could present members of the Betting & Gaming Council with a ‘holistic view’ of the online gambling behaviour of gamblers. This, in turn, would present the industry with the ability to reduce gambling harm. The cross-operator view of the gambling activities of customers would allow companies to ‘identify and prevent potential gambling harms’ in those that hold accounts with several different firms.
The organisation referred to the SCV project as an ‘ambitious and complex undertaking’, saying that it was critical that it was ‘properly considered’ and that it was ‘tested through the lens of data protection law’. The meeting took place on the 11th and 12th of February in order to try to make progress on the idea, with support offered by both the BGC and the Information Commissioners Office. The Chief Executive of the Gambling Commission, Neil McArthur, acknowledged that trying to keep a customer safe with only a partial view of their behaviour was ‘a challenge’.
“I’m really looking forward to seeing what is possible. We are constantly looking for opportunities to reduce gambling-related harm and there is always more to be done. Using technology to facilitate a single view of consumer activity is one of a range of actions we are pursuing to make gambling safer.”
In addition to the SCV challenge, the UKGC was also looking to raise standards and reduce harm in areas like ethical game design, as well as the use of advertising technology and the incentives that were offered to high value customers, with deadlines set by March of 2020.
How Does SCV Fit In With GDPR?
One question asked of the Single Customer View project proposed by the UKGC was how, exactly, this would fit in with the rules around General Data Protection Regulation. This was introduced in 2016 and was designed to allow people to have more control and rights over their own personal data. It became enforceable in 2018 and was retained as an identical law even after the United Kingdom left the European Union in 2021. In November of 2020, the Gambling Commission was accepted into the Information Commissioner’s Office’s Regulatory Sandbox.
The aim of the Sandbox for the SCV was to find out whether it was possible to use a lawful basis to share customers’ information under Article 6 of the UK General Data Protection Regulation. Could this allow the sharing of behavioural data between operators via an SCV? The key findings of the Sandbox were that it was ok to share data in order to identify customers that were ‘at-risk’ of gambling related harms. It was felt that there were two parts of law that offered a ‘discretionary gateway’ to the processing of information for the purposes of protecting customers.
There was, however, a note of caution that emerged from the Sandbox. It said,
“For any processing to be lawful, all data protection principles outlined in Article 5 of the UK GDPR need to be complied with alongside other aspects of the UK GDPR, such as Article 25 data protection by design and by default. As explained in its guidance, lawfulness also means that you don’t do anything unlawful in a more general which includes non-compliance with statute and common law obligations whether criminal or civil.”
Regardless, the publication of the report provided a ‘helpful steer’ on how a SCV could be implemented lawfully.
GAMSTOP Given Permission To Lead A Trial
At the start of February 2022, it emerged that the Betting and Gaming Council had given GAMSTOP permission to run a cross-industry data-sharing project. The aim of the trial is to identify people that had been identified as being at risk of gambling related harm in order to ensure that they would be protected by all regulated betting companies. The hope is that the scheme will stop customers from moving between operators without any sort of appropriate intervention being carried out, in instances when they’ve been identified as being at high risk.
The BGC said that the Single Customer View project would lead to ‘some customers’ receiving ‘additional safeguards’. For others, though, it would mean that they would be ‘prevented from betting entirely with other operators. In many ways, it was essentially looking to give GAMSTOP the power to carry out the objective that it was initially given when it was set up. As an independent not-for-profit organisation, it has operated the UK’s self-exclusion scheme since it launched. That, though, has been beset by numerous problems over the years that this will hopefully stop.
The Government Department for Digital, Culture, Media & Sport has given the development its full backing, believing that a Single Customer View approach will allow companies to stop people from suffering gambling related game. The Executive Director for Standards and Innovation at the BGC, Wes Himes, said that he was delighted’ with the commitment of the organisation’s members, who had invested half a million pounds in the trial. He said,
“Whilst many companies put forward proposals for this system, it was clear that GAMSTOP stood out from the rest. They are uniquely placed as they currently operate the online gambling self-exclusion scheme which has helped more than two hundred and fifty thousand people over the last five years.”
Is This All Good As An Idea?
There is little doubt that most people would say that limiting the ability of the most vulnerable to suffer from gambling related harm is a good thing. As a result, the initial reaction from the majority would be to say that the gambling industry is the perfect one to take advantage of the Single Customer View approach. For some, though, it comes with problems that can’t be ignored. For many years customers have complained that they are limited in the bets that they can place when they’ve been successful with their wagers.
The fear of some is that the SCV will allow companies to share data on customers that are successful, thereby stopping them from placing bets across the industry or, at the very least, limiting how much they are able to stake. Using a Single Customer View to ‘accurately assess customer risk’ is a good thing, but using it in order to stop customers from placing successful bets or to limit the ability of punters to take advantage of a disparity in stakes, known as ‘arbing’, is definitely not a positive thing in the eyes of most.
There are also some that point out that the ICO’s initial thoughts on the legality of data sharing under UK GDPR laws was ‘heavily caveated’. It was repeatedly emphasised that whether it will be compliant or not will depend on a number of factors ‘that are not yet known’. It also neglected to mention the incorporation of ‘affordability data’, which would almost certainly need to be included in the information shared by companies on customers if it were to be able to seriously consider whether the punters were at risk or not.
What Might Happen Next
It is all well and good introducing something such as the Single Customer View in order to stop people from suffering gambling related harm. The problem with it is, though, that the customers would need to limit their betting to licensed bookmakers and casinos. That is to say, it is entirely possible to place a wager with a non-licensed company, which those that are desperate to bet might be more inclined to do. In other words, it is entirely possible that by introducing the SCV to the gambling industry, the UKGC will simply push people towards black market bookmakers.
Of course, just because a small percentage of customers might choose to look to illegal gambling firms in order to place their bets doesn’t mean that the idea should be abandoned. There is little doubt that using this Single Customer View approach with stop some bettors from suffering harm and there is not much that can be done about those that would move away from the regulated market. Indeed, there is an argument that they might do that anyway. Even so, there will likely be some pushback from punters worried about their data being shared between betting companies in this way.
