Q&A: Entain on building the next generation of player protection measures

Not everyone who gambles is a problem gambler. This is a simple truth that sometimes gets lost in the debate surrounding gambling regulation. For every player experiencing gambling-related harm, there are 10 players who may never come close to it. However, legislation and indeed regulation has to be applicable at the widest level to all, even if this penalises the many that may never be affected by it, but who may look to more unscrupulous operators to gamble.

So, what does an operator do? Lose market share and customer base to unlicensed operators due to factors outside of its control, or treat every customer differently, especially when it comes to identifying problem gamblers? This is the approach taken by Entain and its customer journey, which will soon be able to draw on the enhanced tracking resources of the Advanced Responsibility Care initiative, which is explained below by Entain’s head of corporate affairs, Grainne Hurst.

EGR Compliance: What does Entain mean by hyper-personalisation of responsible gambling?

Grainne Hurst (GH): It’s the individualised approach that we’re taking. So, by having a system of early identification of individual players, we’re basically able to protect each customer from the very start of their journey with us all the way through, and obviously tailoring that as and when we spot potential signs. Those signs might then wane, then again we might spot future potential signs, and then they wane again, it’s that kind of real-time individualised approach to player protection that is at the heart of our new ARC system.

EGR Compliance: How do these tailored checks interact with things like an affordability cap, which has been muted by the UKGC and is expected to be included in the gambling act review?

GH: Our position is that what we think needs to be avoided is a blanket approach or blanket threshold to player protection. What we’ve seen from other international markets is basically where you have onerous restrictions on either particular products or particular thresholds, or you see customers moving from the regulated sector to the black market, where there are less frictions and less checks and balances, and sadly, no player protection. For example, I’m sure you know this but in Sweden the government has recently launched an inquiry into the black market, because their channelisation rates for the regulated sector are so far below what they wanted them to be as a result of onerous restrictions, and that they’re now looking into the scale and size of the black market and also what can be done to try and stop it. What we’re obviously trying to avoid doing is getting to that position in other markets, and we think the best way to do that is using our technology to keep the majority of players playing safely with us but obviously target and interact, identify and intervene with those that need it.

EGR Compliance: In your opinion, what do these more tailored checks rather than blanket measures add to Entain’s ability to spot problem gamblers and to the whole player journey?

GH: The really important thing is that we are providing targeted interventions for those who are most at risk and the thing that blanket checks or blanket regulations don’t do is specifically target those who most need it. All blanket checks do is effectively annoy the 99% of players who are gambling safely and recreationally as part of their leisure time and don’t get to the nub of the problem of those who actually need it most. What we’re doing is actually on a customer-by-customer basis, looking at a completely personalised player protection system because we know that each player plays differently, and those who might be at risk have different potential risk factors. A staking limit is probably not the route for some of those players and equally nor is a time limit or particular product limits. It has to be targeted in order to be effective.

EGR Compliance: What are the new markers of harm that are being trialled?

GH: There are a lot that are still in the process of testing and trialling. Those are the three main ones that we’re going with at the moment but it builds on a number of ones like frequency of play, the time of day or night at which you’re playing, the number of deposits, the number of cards that you might be depositing with, any fluctuations in those sorts of markers of protection, as well as these additional ones are part of the new ARC system.

EGR Compliance: Can you provide more information on the development process to determine these markers?

GH: We had several workshops with the Harvard Medical School, they have a division on addiction, who we’ve been collaborating with now for the last two years, as part of a five-year partnership with them so the academics were part of that workshop. We’ve recently taken on Professor Mark Griffiths, who is a distinguished professor of behavioural addiction. He’s been working in this field for about 30 years, looking at all types of addiction in gambling, but also gaming more broadly. We also have some lived experienced specialists in the form of Epic Risk Management. We brought all of these individuals together with our own data scientists at Entain holding a couple of sessions. The first was very much a brainstorming process where everybody kind of put their cards on the table about the sorts of marks of protection they thought should be included in the second wave. What we did then was to go away and basically look at the academic evidence to stack up usage of those markers before we decided on which ones would be the most useful and effective to take forward.

EGR Compliance: Can you provide any information on the identification rates of problem gamblers from this initial trial? Are you seeing an increase?

GH: We’ve only started modelling and trialling the markers so it’s too early to tell any outcomes from them. However, what I would say is we have an existing system of markers of protection, which are quite static, compared to this new kind of preventative approach that we’re taking in real time. What the existing marks of harm have shown is that when a customer comes in, they play with us, if they are at potential risk of harm they will spike and then as a result of our interventions at the moment, we’re able to reduce that spike and reduce their spending by over half at the minute based on our current system. What we’re able to do with the new ARC system is basically get to those players before they reach the spike, so we identify them at an earlier stage and are able to keep them playing safely with us online.

EGR Compliance: How will the international rollout be handled?

GH: It will be tested in the UK first and then rolled out internationally, on a market-by-market basis. Obviously, there may be some cultural tweaks that need to be made internationally in respect of particular markets, for example. One of the things that we found in some of our European markets is that late-night play may be more normal because they have a slightly different culture to us in the UK, of working later or staying up later, or socialising later. So, there may be some cultural tweaks to it as we roll this out internationally.

EGR Compliance: Are you planning to share this system with other operators to create a broad base consensus and aid the sector?

GH: We would obviously love that to happen and it’s our aim that we work as an industry to tackle problem gambling. We’ve been making real strides with that in the UK via the Betting and Gaming Council in recent months, and we’ve had a number of additional codes that have been implemented on an industry-wide basis. We also have a markers of protection system already across operators, which was set up a couple of years ago via our trade association at the time. It was PwC who helped us with those behavioural triggers. We’d be more than willing to share these learnings with the industry.

EGR Compliance: Kindred has published its revenue mix taken from at-risk gamblers, could Entain potentially follow suit? What are your thoughts on this?

GH: For us we know that a very small number of our customers are at risk of problem gambling harm, so we have done a similar exercise to Kindred internally and that’s very much fuelling our ARC system. We know that we want to target those who are at highest risk, but also make sure that those who are at kind of medium and low risk are actually caught by our programme before they actually get to the point at which we should be intervening with them.