Single Customer View: A Major Achievement in Gaming Regulation

Long established as one of the most influential gambling regulators in the world, the UK Gambling Commission is a vocal proponent of the power of collaboration.

“We see greater collaboration amongst all of us, gambling regulators across the world, as the essential next step in tackling the challenges that the morphing of the gambling market into a global tech industry poses for all of us.”

Andrew Rhodes, CEO, UK Gambling Commission 

From the above statement, excerpted from a speech given to the International Association of Gaming Regulators (IAGR) in 2022, to the Commission’s Advice to Government regarding the Review of the 2005 Gambling Act: the importance of collaboration is a consistent theme in the output of a government regulator at the forefront of compliance innovation. This is especially true in the Commission’s efforts to achieve what was once thought impossible in gaming regulatory circles—the creation of a Single Customer View (SCV) across multiple gaming operators.

“A problem we will all face is that a very responsible operator may exclude someone from gambling, or force a pause in their gambling as they are showing signs of harm. However, this may simply result in a person who may be in distress simply moving to another operator, and then another, and another.

“The single customer view will allow operators to be alerted to customers who have been excluded by another operator due to concerns about their level of gambling, thus breaking this circuit.”  

Andrew Rhodes, CEO, UK Gambling Commission 

Long viewed as a veritable ‘magic bullet’ for government gaming regulators seeking a truly robust tool to reduce gambling harms for those bettors most at risk, the Single Customer View was nevertheless viewed as a utopian objective by many global gaming pundits concerned by the legality, manageability, and/or long-term ramifications of SCV.  That all began to change in February of 2020 when the UK Gambling Commission challenged the online gambling industry, represented by the Betting & Gaming Council (BGC), to explore and develop a SCV solution capable of enabling a holistic view of a customer’s online gaming behaviour.

From that initial industry collaboration, progress ensued at a rapid pace:

• In November 2020, the Gambling Commission was accepted into the Regulatory Sandbox, a service provided by the Information Commissioner’s Office (ICO) to support organizations developing products or services which use personal data in innovative and safe ways to deliver a potential public benefit. Within this environment, ideal for exploring the practical and potential ramifications of SCV, ICO provided guidance to the Commission pertinent to the lawful basis of personal information sharing, and the implications of potential processing of special category data, controllership, automated decision-making, and individuals’ rights.
  
  
• Following Phase 1, representatives of the Betting & Gaming Council entered the Sandbox in in February 2022, to explore the trial SCV solution’s capabilities to enable swift and proactive intervention by gambling operators to reduce incidents of problem gambling. The proposed mechanism sought to ensure that in cases where customers owned multiple accounts across a number of operators, operators were permitted to share personal data with each other in line with data protection legislation, allowing for a more effective identification of problem gamblers. Critical to this process was the participation of the gambling operators, Entain, William Hill, 888, Gamesys, Bet365 and Flutter, who agreed to co-design and trial the SCV solution to provide an ‘operator perspective’ to the effort.
  
  
• A key component of the Sandbox project was to identify the appropriate lawful basis under Article 6 UK GDPR for the Operators to rely on when they shared customers’ personal data for the purposes of the SCV. In an ICO report outlining the Sandbox engagement with the Gambling Commission, both Articles 6(e) ‘Public Task’ and (f) ‘Legitimate Interests’ were identified to provide discretionary gateways for gambling operators to share personal data between them for the purposes of the SCV. The Operators jointly decided that ‘Legitimate Interests’ would be the most appropriate lawful basis to carry out the intended processing with the ICO advising Operators that they would need to demonstrate that:

• • they are pursuing a legitimate interest;
  • the processing they intend is necessary to fulfil that purpose; and
  • they have balanced the identified legitimate interests against the individual’s interests, rights, and freedoms.
    
    
• With the Sandbox quickly proving the validity of the SCV model from both a practical execution and GDPR compliance perspective, project stakeholders agreed to focus their collaborative efforts on potential Account Closure scenarios. In this Use Case scenario, customers who had their account closed by one operator due to the customer disclosing a gambling problem, would also be excluded from all other participating operators.
  
  
• Following the successful completion of the Sandbox pilot, the data-sharing single customer view SCV project, now branded GAMPROTECT, was approved by the ICO in July 2023 for launch across the UK gambling industry with the support of the BGC and its member operators. The GamProtect launch followed a prior announcement in 2020 mandating the participation of all online gambling operators in the multi-operator self-exclusion scheme, GAMSTOP.
  
  
• In conjunction with the launch, the ICO backed proposals for the financial sector to share data with gambling companies to protect customers from unaffordable losses. The ICO has also lent its support to plans for gambling companies to share information about customers identified as high risk who are gambling across multiple sites whilst simultaneously advising the BGC on the necessary safeguards required to share personal data between different operators.

For full details on this project, refer to the Betting & Gaming Council’s Regulatory Sandbox Final Report.

In short, once considered a virtual impossibility, the Single Customer View, a collaborative data-sharing process across multiple gambling operators has now been proven as a theoretically sound and actionable framework to improve bettor safety and enhance regulatory oversight in the United Kingdom.

SCV Applications for the North American Gaming Sector

This should be welcome news indeed for North American gaming regulators where comparable innovation is critical to address emerging regulatory issues impacting the recently legalized and rapidly growing online gaming industry. Much like their UK counterparts, North American gaming agencies are confronted with the reality of protecting ‘at risk’ gamblers whom, despite efforts towards self-exclusion, can easily access alternate providers to continue wagering. For North American agencies, lacking a single customer view across multiple operators creates the potential for a regulatory framework where the spirit of compliance is willing but the system for enforcement is weak.

SCV could also be a boon for North American gaming regulators in the areas of athlete identification and prevention where recent scandals have heightening concerns over the ability of regulators to fully impede wagering activity prohibited by professional and collegiate sports leagues.

Moreover, while the ICO’s recommendations for the financial sector to share data with gambling operators are justified within an overarching mandate to ‘protect customers from unaffordable losses,’ it’s obvious that such data is also a critical and much coveted component of a sufficiently robust dataset to improve KYC efforts to prevent money laundering, terrorism funding, cybercrime, fraud, and corruption. For government gaming regulators striving to monitor and enforce the anti-money laundering compliance of third-party operators, the Single Customer View could potentially facilitate additional transactional transparency to ensure that operators and regulators alike have access to the same critical information in real-time.

With SCV carrying the potential to facilitate several potential use cases going forward, it’s clear that the UK Gambling Commission as an innovator, and the online gambling industry as-a-whole, is embracing a central tenet of modern technology—to empower multiple stakeholders via the seamless provision of pertinent contextual datasets. With North American agencies increasingly investing in software solutions like POSSE GCS (Gaming Control Software) that are purpose-built to equip gaming regulators with powerful off-the-shelf workflow automation leveraging best practice data availability, it is only a matter a time before North American gaming regulators are looking through the lens of a Single Customer View to achieve better compliance outcomes for citizens and operators alike.

To learn more about POSSE GCS, our streamlined regulatory and compliance solution for the government gaming enterprise, visit our POSSE Gaming Control Software page for more information OR contact us today to schedule a no-obligation demo.