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PLAY MANAGEMENT SYSTEMS. OUTLINE OF PRESENTATION. INTRODUCTION HYPOTHESIS IMPORTANT DEFINITIONS LANDCSAPE AND PLAY MANAGEMENT SYSTEM IN NOVA SCOTIA LANDSCAPE AND PLAY MANAGEMENT SYSTEM IN NORWAY THE WAY FORWARD. 1. Introduction.
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OUTLINE OF PRESENTATION • INTRODUCTION • HYPOTHESIS • IMPORTANT DEFINITIONS • LANDCSAPE AND PLAY MANAGEMENT SYSTEM IN NOVA SCOTIA • LANDSCAPE AND PLAY MANAGEMENT SYSTEM IN NORWAY • THE WAY FORWARD
1. Introduction • Social impact of problem gambling of concern to Regulators, industry, patrons government and community/ broader public • Currently treatment and education on problem gambling funded by industry on voluntary basis • Against backdrop wanted to explore evolution of Norway’s system and found Nova Scotia had some lessons to be learnt too
2. Hypothesis • Research moved form the premise that converse relationship: responsible gambling tools Responsible gambling • Particular use for excluded persons and problem gamblers ito limiting advertising and access to gamble • Unintended consequences • Inherent limitations ito SA landscape and legal considerations
3. Important definitions • Problem Gambling • “Problem gambling is characterized by…difficulties in limiting money and/or time spent on gambling which leads to adverse consequences for the gambler, others, or for the community” (Ministerial Council on Gambling(2005), • The University of Maryland Medical Center defines pathological gambling as "being unable to resist impulses to gamble, which can lead to severe personal or social consequences” (Vorvick, Linda, Merrill, Michelle (2010). • SA problem gambling statistics (Canadian Problem Gambling Index) as at April 2015: of the South African Population: • 1.5% are high risk / problem gamblers; • 2.7% are moderate risk; • 2.8% are low risk; and • 93.0% are at no risk
3. Important definitions cont’d • Responsible Gambling • At the centre of the notion of responsible gambling is the question of informed choice. To denote that patrons are able to make informed choices concerning their gambling, means that Operators place a variety of information at patrons’ disposal pertaining inter alia the chances of winning a particular gambling activity, pay-out ratios, their gambling spend, both in monetary terms as well as time spent, etc. • Patrons access Data concerning play – responsible gambling tools
3. Important definitions cont’d • Play Management / Pre-commitment Systems • Dr Williams defines pre-commitment as a “harm minimization strategy whereby pre-set limits on time, frequency, or money spent gambling are registered prior to the start of play.” Pre-commitment usually refers to player-initiated limits, to distinguish it from limits that may be imposed by the Operator, a Regulator or government agency. To date pre-commitment has been used on Electronic Gambling Machines (“EGMs”), internet gambling, betting sites and Casino self-exclusions. • Models of Play Management Systems • These may be full or partial, mandatory or voluntary or a hybrid system.
4. Landscape and Play Management System in Nova Scotia • Stakeholder and Licensing Regime • The regulated gaming industry in Nova Scotia is managed by the Nova Scotia Provincial Lotteries and Casino Corporation (NSPLCC). • The Operators of the NSPLCC are the Atlantic Lottery Corporation (ALC) and Casino Nova Scotia (CNS). These Operators are responsible for the day-to-day operations of NSPLCC's businesses. • The gaming industry in Nova Scotia is regulated by the Alcohol Gaming Fuel and Tobacco Division (AGFTD) of. The AGFTD is a separate entity, independent from NSPLCC. • Ito 2013 data, 0,7% of adult population considered problem gamblers, 1,3% at moderate risk.
4. Landscape and Play Management System in Nova Scotia cont’d • Play Management Systems • Around 2005, studies commenced on use of a smart card linked to all video lottery terminals (VLTs) in the Province. Referred to as the Informed Player Choice Card RGD Device. • Voluntary system- elect whether to use card or whether to use responsible gambling features • The IPCS stored and tracked player data.
4. Landscape and Play Management System in Nova Scotia cont’d • Three pre-trials done on the use use and effectiveness of the system • The Fourth study (2010) reviewed the data received from the live field tests of earlier trials of the RGD was analyzed. It found over a third of all gamblers used the responsible gambling features. It also showed the use of responsible gambling features resulted in a lower spend per session and that use of the features may increase enjoyment of the gambling experience. • Three research panels recommended rollout of a RGD device. Which may be either mandatory or voluntary. • It reported positive findings and participants in the trials were keen to have a mandatory system in place. • A majority of participants supported a mandatory system with mandatory use of RG features, and inability to swop/share cards. • Hence the My-Play System (“MPS”) was rolled out in 2010.
4. Landscape and Play Management System in Nova Scotia cont’d • The MPS rolled out as a voluntary system, was mandatory since April 2012, however use of the responsible gambling tools and accessing of play data was optional. • Due to patrons’ concerns around privacy and the use of their personal data, MPS permitted two types of enrolment: • Light enrolment; and • Full enrolment • The MPS was assessed over a 5-year period, with three evaluations of the system : • Baseline evaluation, completed in 2011 • Interim report completed in 2012; • Final Report completed in August 2016.
4. Landscape and Play Management System in Nova Scotia cont’d • The MPS had the following functionality tools: • My Live Action; • My Account; • My Money Limit; • My Play Limit; and • 48-hour Quick stop
4. Landscape and Play Management System in Nova Scotia cont’d • Findings when the system was mandatory: • Players could still bypass the system. • Impossible to track player data and spend because of light enrolment features • Players felt intimidated / embarrassed during the registration process • Difficulty understanding the system • Privacy concerns • Venues had community cards • Poor utilization of the system features • Moderate risk and problem gamblers reduced gambling while no or low risk players spent more on gambling;
4. Landscape and Play Management System in Nova Scotia cont’d • Over-all findings: • Significant percentage of problem gamblers that sought help/ treatment or intended to do so. • Reduction in problem gambling scores of participants • Less spend on gambling per session and GGR dropped • Players that viewed account summary, spend more in that session on average, may be chasing losses? But ties in with similar findings in in research generally. • However viewing live session on current play, resulted in a reduction in spending
4. Landscape and Play Management System in Nova Scotia cont’d • Lessons learnt • A full, mandatory system with binding limits is most useful to patrons, regulators and licensees. • There has to be some enforcement mechanism to avoid bypassing the system or limits set • Identifying data to ensure continuous tracking is crucial • Buy-in and co-operation of all stakeholders is important and extensive training to all role-players on use and purpose of the system • Clear strategy once a decision is made to roll-out • Pre-trails and in-depth research, with dialogue amongst stakeholders is crucial • Privacy, confidentiality and protection user data
5. Landscape and Player Management System in Norway • Stakeholder & Licensing Regime • The Norwegian Gaming and Foundation Authority, established in 2001, operates within the Ministry of Culture and oversees the gambling industry. The gaming authority is in charge of ensuring compliance with the Lottery Act, the Gaming Schemes and the Totalisator Act. • The regulated gambling market is dominated by Norsk Tipping (“NT”) and Norsk Rikstoto Tipping (“NR”) , which hold exclusive rights to offer gambling and horse race betting respectively in Norway. • Norway has traditionally taken a restrictive approach to gambling regulation and the offering, intermediation or marketing of gambling activities without a Norwegian licence is prohibited. • Norway became one of the first countries to introduce payment blocking measures in an attempt to restrict foreign online operators’ access to the Norwegian market. Under Norwegian law that came into force in June 2010, it is an offence for financial institutions to process payments associated with unlicensed operators. • Licensing and Costs: As Norway has a monopoly system in place, there is no licensing procedure as such. However, NR’s current license was granted for a period of five years ending on December 31, 2021. It is not an exclusive statutory right, although the government has chosen to grant just one licence.
5. Landscape and Player Management System in Norway • Modes of Gambling • State monopoly NT operates land-based gaming machines, betting and a number of lottery games. NT also has a monopoly for online betting and lottery games and also offers casino, bingo, scratch cards and poker-style games online. Land based casinos are prohibited in Norway. • Poker: Under the single available licence, an annual Norwegian Poker Championship and regional tournaments can be organised. Participation in the tournament is limited to 5 000 and participation in the tournament should be authorised with only deposit per player. A maximum once-off deposit of NOK10,000 per player is allowed, or a once-off deposit of NOK2,000 per regional qualifying tournament. • NR has a monopoly over totalisator betting and can also offer its bets online. • Bingo is regulated in Norway and is operated by private operators. • Licences for lotteries with NOK300m annual turnover cap are available to private operators partnering up with charities. Smaller scale charitable lotteries can be organised by local voluntary groups and charitable organisations upon notification to the Gaming Authority but must not give out cash prizes. • Taxation: NT and NR are exempt from gambling taxes, however, proceeds from NT are distributed to good causes as follow: 64% to sports, 18% to culture and 18% to social causes.
5. Landscape and Player Management System in Norway • Modes of Gambling (continued) • Gambling Machines: • Technical Standards: Norway has introduced a smart-card system or its gaming machines. This means that machines cannot be played using coins or banknotes but must be played using a pre-paid electronic card which can contain up to NOK10,000. Players can top up these cards from their bank accounts and any winnings over NOK10,000 are automatically transferred back to the player’s account. • The Norwegian Gaming Authority must approve all games offered on gaming machines. All gaming machines used in Norway, or on ships making scheduled stops in Norway and in foreign ports, must be licensed by the Gaming Authority. • Lottery Games: Land-based lotteries are regulated as well as online lottery games. The Lottery Act currently regulates pre-dawn money games, including scratch cards and tear and win games, as well as traditional draw lotteries at national or regional level.
5. Landscape and Player Management System in Norway • Player Protection • 18 years of age is the minimum age requirement applicable to all forms of gambling regulated in Norway • Operating hours: NT’s gaming machines are inaccessible from midnight until 7am. • Self-Exclusion Programmes: NT offers players the possibility to self-exclude for certain periods, up to 180 days, or permanently. Players can also opt to choose a number of hours to play on gaming machines, which can be based on day, week or month limits. • Wager and Time Limits: NT’s player cards have significant in-built player protection measures, most notably imposing a limit on the amount a player can lose. Under the current limits, a player can lose no more than NOK650 within 24 hours and no more than NOK2,700 over a month in gaming machines, whereas the limits are raised to NOK900 within 24 hours and NOK4,400 per month on bingo machines. • For internet and mobile gaming products, loss limits of no more than NOK4,000 per day and NOK10,000 per month apply. • Players can also set their own limits within the maximum limits set by NT, determining a lower spending limit
5. Landscape and Player Management System in Norway • Play Management Systems: Introduction of the player card • In 1992 Norway’s state owned gambling operator, Norsk Tipping, introduced a magnetic strip player card allowing lottery purchases to be directly made from a person’s bank account and any winnings directly deposited • On 24 October 2005, Norsk Tipping introduced a new multifunction player card with increased security. The most important changes to the player card were: • The player card is valid for three years compared to only one previously • Improved security through the use of chip technology instead of a magnetic stripe • Increased security against financial crime through the requirement of Norwegian national identification number and personal ID • Increased functionality because the card can be used to register games, pay for them and receive prizes • A permanent player number that the customer can transfer to his or her next player card • A separate player account linked to the customer’s own bank account”
5. Landscape and Player Management System in Norway • Play Management Systems: Introduction of the player card (cont..) • Since February 2009 the use of these smart cards became mandatory for all forms of gambling (online gambling, sports betting, EGMs), except lotteries and instant win tickets • Introduction of the player card served essentially a three-fold purpose, viz: • For gaming security and integrity of the games; • To ensure strict legislative compliance and eliminate criminal elements; and • For player protection, both resulting from their own conduct or harm caused by others through misuse of a player card or stealing a patron’s identity.
5. Landscape and Player Management System in Norway • Playscan • Playscan is a behavioural analysis tool that detects and communicates risky gambling. It helps players keep track of their gambling habits by evaluating potential risks associated with their gambling. Playscan will alert players to a change in their risk level. If their gambling behaviour starts to become risky, Playscan will register this and provide the player with tips and recommendations on how to adjust their gambling habits. • The data analysis are also fed back to the gaming operator, allowing the operator to work proactive against problem gambling and to integrate responsible gambling in the overall business strategy. • Playscan offer players better protection, better overview of consumption and increased understanding of a gambler’s own gaming behaviour.
AT-RISK BEHAVIOURAL SEGMENTATION • Playscan, using a risk prediction model, analyses player data to detect signs of problematic gambling. The model uses parameters such as total expenditure in time and money, intensity of game play, patterns of deposits into a gambling account or gambling during specific risky periods. • The data analysis for every player serves two primary purposes: personalising responsible gambling initiatives and communication and measuring the risk levels of the player population.
PERSONALISED COMMUNICATION • Playscan includes a ready-to-use web interface for player directed communication. In the interface, the tool asks for the player’s own thoughts about their gambling. The player’s self-assessment is analysed together with the data analysis. Personalised tips and recommendations are then presented. Each player can also find information about different aspects of responsible gambling.
BEHAVIOURAL INSIGHTS • Playscan is supplied with a dashboard, a web interface in which players can be tracked and split into different segments in tailored reports in order to gain insights. • The Playscan Dashboard allows you to explore in detail your at-risk segment and is of great value for tracking how well your overall responsible gambling strategy and responsible gambling communication works.
5. Landscape and Player Management System in Norway • Research data reported A Norwegian study, conducted in 2014, measured the prevalence rates of persons aged between 16 and 74 years of age. The main findings were: • 0.6 per cent of the Norwegian population are problem gamblers, amounting to around 22,000 people • 2.4 per cent of the Norwegian population are moderate risk players, approximately 89,000 people • 22.6 per cent of the participants had played games on social media • 26.7 per cent of gamblers had used the internet to gamble during the last 12 months A follow up survey was carried out and a final report was published in October 2016. The follow up report found that the prevalence of gambling problems remained stable between 2013 and 2015
5. Landscape and Player Management System in Norway • Shortfalls of the system • Misuse of player identities: Player card contains a digital electronic ID, which means that a lost or stolen card can be used by criminals to take up loans, establish credit and buy goods over the internet. • Theft: Because prizes larger than NOK10,000 are paid to the player’s bank account, the size of such thefts were limited to amounts below NOK10,000. In practice, players often forgot their cards in the reader at a retailer or in the machines. NT therefore embarked on an awareness and information campaign to sensitize patrons to the dangers and importance of blocking smartcards immediately when it gets lost. The card readers were also modified to signal a sound when cards are left in there when a transaction is concluded.
6. Conclusion • There is some debate on who would benefit from the compulsory or voluntary roll-out of pre-commitment systems. Some opine that it would assist both problem gamblers and non-problem gamblers by providing them the tools to avoid them becoming problem gamblers. Others are of the view that responsible gamblers already set limits for themselves subconsciously and generally stays within the bounds of those pre-set limits. Hence they do not progress to becoming problem gamblers and therefore it would prove unnecessary to roll-out pre-commitment systems • The research further shows that, collaboration and buy-in from the industry is critical for the successful roll-out of trials on any pre-commitment system • Some elements of a player registration process is already in place in the gambling industry. Mostly at Casinos having a loyalty card, which for purposes of this subject-matter is referred to as a player card. It may be a bold deduction, but we move from the assumption that certain Operators, such as the Casinos, Bookmakers and Totalisator may be able to participate in trials that the Board may in due course conduct, and have their devices calibrated for this purpose • Another note-worthy consideration is that, for patrons to embrace and confidently use any pre-commitment system, the privacy and the security of their information must be guaranteed to ensure utmost trust. The roll-out of a pre-commitment system also has unintended negative consequences that must be carefully considered in the pre-planning processes, i.e. that it deters occasional gamblers, it bombards foreign visitors with strict registration processes, thus requiring a more stream-lined process. In addition, the costs and practical implications on licence holders’ operations can be vast
6. Conclusion • In terms of the legal considerations, the process of engagement with interested and affected parties will inevitably entail the balancing of competing interests and rights. I.e whether the Board is legally empowered to compel the industry to calibrate their machines and other devices to participate in trials. All these matters will be carefully considered through open discourse and exploration of all workable proposals. • We conclude by indicating that this is an exciting project and opportunity to fundamentally and profoundly direct the future forms and tools of responsible gambling not only in the Western Cape, but in South Africa as a whole and be the interface between patrons, the industry and Regulators. • Way forward: Consultation with government, the industry and broader public to test the desirability of conducting trials on some form of pre-commitment system for the Western Cape.
