Effective intervention: Rethinking responsible gambling

“We should celebrate the good things in our industry,” says Sam Douglas, director of safer gambling at the Hippodrome. “When you read a lot of research or a lot of newspaper articles, you can focus very much on the harm. But we shouldn’t forget that it’s an amazing industry. People enjoy playing. They enjoy the night out.

“So, we should celebrate all the things we do really well, while having a group commitment to work on the things that need improvement.”

Working in a live casino environment gives a different perspective on responsible gambling. Douglas adds: “If people have been in for a long time, you might say, ‘How are you getting home? What are you doing tomorrow?’ That can encourage reflection.

“When people have big wins, you say, ‘Who’s the first person you will tell? What will you spend it on?’

“It gives an active point for them to come back to in the future, the next time you see them you ask ‘Still going on that holiday?’”

This care for players can be seen as part of a wider industry change, encompassing both online and land-based gambling and both sports betting and casino. “If you frame it more as customer service and less as compliance,” Douglas continues. “It really speaks to the heart of how we communicate with players.”

Richard Bayliss, Playtech’s director of product compliance and safer gambling, has been across this part of the industry for a long time. He spoke to iGB at a World Gaming Leaders’ Summit event admitting: “It has gone from a very reactive approach to much more proactive. You’re meant to know far more about your players, you’re meant to act upon what you know about them far sooner.”

From player choice to duty of care

Bayliss, who started out at the UK Gambling Commission in 2006, before eventually joining Playtech in 2018, remembers when “responsible gambling was very much player choice. You either use tools or you don’t.” And operator responsibility back then was quite limited.

He explains: “The regulations haven’t changed massively, but the way they’re interpreted has… You’ve got to intervene much sooner. If a person is depositing £10k a week, do you know why? What do you know about them?”

Falling short with the basic toolset

So, what hasn’t worked so well traditionally? As Bayliss explains: “If it becomes a tick box, you’re applying pretty blunt rules, which might help you manage your risk…[but could be seen as] risk management dressed up as safer gambling.” He posits that in those cases, operators are really just trying to “keep the regulator from [their] door” and avoid being fined.

He continues: “It manages some of the risk, but it doesn’t necessarily help people. That’s my biggest issue with that approach.”

In the Netherlands, there are mandatory monthly deposit limits (700 euros for players over 25, and 300 euros for those between 18 and 24), something which Bayliss feels is too blunt and less preferable than a tailored approach.

The former UKGC senior manager (remote gambling) says: “You can’t just give players messages once a year, saying ‘Here is your responsible gambling email. Here are our tools. They’re there if you need them.’

“That doesn’t work because it’s too late. You want it to be a bit more natural than that.”

From the land-based angle, Douglas believes “if you’re taking a one-size-fits-all approach, then you’re not dealing with the person who’s with you … if you’ve got thresholds that apply to everybody, then it’s not bespoke to the player in front of you.”

“One size fits all” clearly isn’t the answer, so how can responsible gambling measures be successfully tailored to individuals?

Learning to read the signals

Figuring out whether to intervene relies on monitoring of activity and, according to Bayliss, the key metric to keep an eye on is “either time or spend”, with others being a bit more difficult to see. He pinpoints escalating deposits as something that might indicate loss chasing, or a loss of control – but these things are nuanced and it is worth considering whether different conclusions can be drawn from the same pieces of data.

Research done for Playtech’s well-established responsible gambling tool BetBuddy showed short timeouts that players were taking in the UK. These might flag to some as a negative, but as Bayliss explains “in reality it was because people were saying, ‘I’ll do one day a week where I gamble, and I’ll block myself for the rest of the week’. So that was actually a positive. You’re limiting. Friday night after you’ve been out for a drink, you don’t want to gamble, but Saturday afternoon you’ll bet on football and play a bit of casino.”

Risk of addiction or gambling harm is much more dynamic and, while trends can be spotted, it is different for everyone.

At the Hippodrome, Douglas and his colleagues have the advantage of being able to witness the behavioural patterns of gamblers themselves. “Our best tool in terms of data points and interaction is the observation of customers,” he says. “Because we can see what somebody’s gambling looks like, rather than judging it from a set of numbers.”

While Douglas says the Hippodrome does have thresholds for when players hit a certain number of visits or turnovers, which can be a trigger, that “can neglect the nuance of who that customer is”. Therefore, data points are used for risk scoring, with occupations and age taken into account. 

Douglas explains that certain occupations are considered high-risk. “Some backgrounds can carry added vulnerability, such as professional sport or leaving the forces, where people may have sudden large payouts and lose a support structure. They often don’t have family around them. They can be relatively young and have come into a lot of money. They can be quite competitive in nature and they’re used to a high-pressure, intense environment.”

But Douglas also warns you can’t rely too much on the categorisation of occupations, citing hospitality staff as an example of an occupation many would expect to be low-paid, but in central London “can earn £100,000 a year”.

Research conducted by Playtech for BetBuddy back in 2021 looked at five different models for predicting harm, and while deposit activity and play frequency were most often key predictors, no single metric dominated across the models. This all reinforces the point that a blanket approach to harm thresholds risks misclassifying certain players.

What to say and how to say it

An effective intervention ultimately comes down to the ability to engage with a player and successfully communicate why you’re getting in touch. As Bayliss puts it: “If you can explain why you’re speaking to someone and give them indisputable evidence, say ‘we’re contacting you today because you’ve deposited more than usual’, ‘here’s your four-week average value of deposits’, and ‘in the most recent four weeks… you’ve doubled it or trebled it’, that gets hard to dispute for players.”

Douglas adds: “The important thing whenever you’re interacting with customers is that you explain the reason why. The first thing we’ll do is tell the person what we’ve seen and why we’ve come to speak to them. Do it in as gentle a way as possible.”

Making sure the at-risk players aren’t offended is key, and Bayliss adds: “You’re not saying to them ‘you’ve done something bad’, you’re just feeding back behaviour, explaining why you’ve got in touch [before pushing them towards] more effective tools.”

Of course, nobody likes being told what to do, and this is something even mentioned by the UK Gambling Commission in the 2019 edition of their formal guidance for remote gambling operators.

Douglas agrees with this sentiment and compares it to other things in life: “Nobody likes being told that they spend too much money on clothes or that they’ve had too much to drink. It quite often triggers the exact opposite behaviour that you’re trying to instil.”

The Hippodrome director of safer gambling believes it is important to concentrate on the behaviours, rather than the person, and avoid coming across as accusatory. He elaborates: “Nobody wants to talk about problem gambling. They talk about the behaviours and not the diagnosis. But we must be wary of stigmatising people for behaviour or personality.”

Neil Burge is the founder of Growth Exposed, a company that conducts iGaming player research to help figure out behavioural patterns. He says: “People don’t want to believe the label ‘problem gambler’. Nobody wants to think of themselves as a ‘problem’ anything. Even if you’re exhibiting markers of that problem – we’re all good at justifying to ourselves like ‘I’m not as bad as someone else’.”

Another expert voice on the topic is Olabimpe Akingba, the head of responsible gambling at PawaTech, that runs BetPawa, one of Africa’s biggest online sportsbook operators. Speaking to iGB at iGB L!VE, she makes the point that people with gambling problems often don’t reach out “whether for social reasons or feeling ashamed”. Instead, BetPawa partners with counsellors and asks players if they are open to being reached out to by them. Ultimately though, she admits “you cannot force people to take that route, but you can encourage them”.

When messages backfire

Burge has a great example from his player research of a safer gambling message leading to the wrong result.

“A lady explicitly rejected a message that was designed to help her,” he recounts. “It said ‘You’ve been playing too long. Do you think it’s time to take a break?’ She just thought it was like those pictures on the back of cigarette packets – aimed at everyone.

“But the next thing she did was close that site down and move to another site to continue playing. From the perspective of the operator it looks like she stopped playing that day. But she has popped up on somebody else’s radar and she’s somebody else’s problem, and she’s still got the problem herself. It’s complex.”

Burge wonders if it is possible for operators to see the world through the eyes of at-risk players and design a way of talking to them “that feels like a friend helping”.

Wording is pivotal in all of this. The Growth Exposed founder adds: “If compliance teams are left to write the copy themselves, you’re asking them to do two jobs…The copy [operators display to players] could definitely be improved to sound more like the way a person would describe things and less like the description of an operator tool.”

From Akingba’s experience, she thinks the messaging needs to remind people that “gambling is all about entertainment” rather than a way of making money, and you “shouldn’t gamble with money that you cannot afford to lose”. Those are simple messages, but clear ones that can get through to players.

But of course, it is not always as simple as sending a message or talking to a problem gambler. As Burge explains: “The thing that surprised me in safer gambling research is just how much people didn’t want to stop… You’ve got people there who are actually enjoying something, but it becomes too much. I overindulge in some things myself, and sometimes you need a hand to step back.”

Building trust through immediate feedback

Pop-up messages are one of the more effective ways of communicating to problem gamblers, according to Bayliss, because “the person is on site; it’s in the moment. If they’re in a hot state, your feedback will get to them. Whereas if you email them, they’ll look at it a day later or a week later, and they’re in a different place. [They might think] it doesn’t ring true because ‘that was last week. I had a bad day, but I’ve not done it since.’

“But reaching people while they’re on site, giving immediate feedback, ‘take a break, we’ll still be here when you get back’, [helps to] build trust among players, because it’s quite an adversarial activity, isn’t it, gambling? You’re trying to beat the house – you don’t mind that other people lose, but you want to be the winner.”

Players are real people

BetPawa and the Hippodrome might be very different businesses – one is an online-only operator spanning Africa, while the other is a land-based casino in London. But there is plenty in common when it comes to the approach to responsible gambling – people are trained to notice and offer a real route to help.

Akingba explains that at BetPawa “we work in synergy with our counselling partners, for information and escalation of certain issues… Our training is not just a tick box. Our customer support team, the first contact with customers, are well equipped to pick up on red flags, and refer to the counselling partners.”

The partners in question are clinical psychologists who work in each of the specific markets PawaTech operate in. Akingba sees this as “a good thing. That’s an organisation putting its customers’ welfare first. Not just a central helpline for everyone, but localising the help to each customer.”

However, she is also circumspect about the scale of the challenge, admitting: “We’re not unaware of the fact no one can completely eradicate gambling problems. All we can do is minimise harm. We are on the right path.”

Akingba’s department within BetPawa is training remotely with Dalhousie University to ensure they are not “just recycling old information” but are instead widening their scope.

That human touch is key for Douglas, who explains that at the Hippodrome they can “supplement information with really good observation and engagement of our 700 staff”.

He also sees the importance of humanity when it comes to training new croupiers on safer gambling. “I would honestly say of all the training they do, it’s the one that lands best,” he claims. “When you’ve got a new generation of young people coming into a business, what they want to hear is that you’ve got a social consciousness and you care about the people coming into your building. Once you start talking about neurodiversity and digital well-being – these are subjects that people care a great deal about.

“Understanding player behaviour and having a commitment to learn about ways you can affect that in a responsible manner… I think we’re a safer casino by design.”

Scaling, and the role of AI

The biggest challenge today is the scale of the industry. How can any business provide successful safer gambling measures for thousands of different players?

While many see AI as a relatively new development, Bayliss points to Playtech’s BetBuddy as an example of it being at an advanced stage. “AI is fairly well advanced,” he states. “Not Gen AI, but BetBuddy is a machine-learning AI product that’s been around for 15 years now, pattern matching, trying to predict which players will escalate, so you can intervene sooner. That’s the point of it.”

He adds: “The UKGC said that you should interact with 25%-30% of your players, because they are exhibiting some signs of risk. You cannot do phone calls for all of those. So, how do you automate?”

Bayliss points out that players don’t want to speak to operators anymore. “No one wants to speak to someone on the phone. Everything’s automated. How do you interact with someone about something really sensitive when they are going to screen your calls? They know why an operator is calling them up. Generally, it can’t be good news…

“How do you avoid that cliff edge where you should intervene much, much earlier? Where you avoid that case where you’re having to put the brakes on someone?”

This is where he thinks AI will help, with tailored messages using data such as age and demographic of players and speaking “in a language that resonates with them more… Rather than sending them the same message over and over again and being surprised that you get the same response, you can tweak the copy.” In the past, he explains: “They’ve been written by compliance people or lawyers… It’s not the type of language that will get someone’s attention.”

According to Bayliss, the goal during early interactions should be trying to merge people back “into a safer play zone”, by detecting the risk early and keeping it in check.

This is why Bayliss feels early intervention is key. He explains: “The last thing operators want to do is stop a player early to say, ‘are you sure you should be spending this much?’ But if you don’t intervene, you don’t learn about what works. Building this profile of a player is important to individualise their experience.

“Safe players get a different experience, but that also involves being a bit more circumspect at the start.”

Does intervention actually work, though?

Measuring and recording an effective intervention is not straightforward. For Douglas, who can see the Hippodrome’s players in person, it may be a bit easier. “The best data point is a change in behaviour,” he explains. “You look at whether somebody’s behaviour has changed after an interaction or an intervention.”

Conversations between players and staff members at the Hippodrome are crucial, and Douglas continues: “I really like it when people remember the conversation, and you can build on it. If I go in and read the interactions that happen with our gaming staff on the floor, if people reference previous conversations, it’s a good indication something sunk in.”

But he reinforces that at the end of the day, “you can look at overall levels of play. But we shouldn’t forget it’s about that one person that’s in front of you.”

Monitoring open banking data is one way that could work for tracking problem gamblers, but with crypto casinos, unregulated markets and the use of e-wallets, even access to that wouldn’t necessarily solve the problem.

Burge continues: “You can’t get the 100% big picture … but that doesn’t mean you should stop trying. Having a better picture at least lets you see ‘have we moved the problem or helped with the problem?’”

Douglas makes a similar point that, given there are four casinos in walking distance from the Hippodrome in London, “if somebody leaves our building, we have no oversight. Sometimes you’re working in the dark. We’d welcome more information sharing between operators.”

The importance of keeping players in a regulated environment with support available is emphasised by the alternatives. Douglas adds: “If the person leaves your business and goes straight to the black market, where there are no limits or protections, then it’s not going to be an effective intervention. It’s not allowing the person to get help at all.”

Making it stick: Culture and the commercial case

None of this works unless the business behind it means it. “There’s a business case for why better responsible gambling is important,” says Bayliss. “It cuts down costs. It’s really expensive to deal with high-risk players. As a B2C, your ambition should be to avoid getting to the stage where you have to severely restrict accounts, close accounts, spend lots of time on the phone with high-risk players. If they get to that point, you’ve missed many opportunities earlier on to interact and intervene.”

This message has got through to decision makers at operators and Bayliss adds: “The tone from the top is much more genuine and authentic now.

“They realise if they want to run a successful business – not just in the UK, but other markets as they open up – they’ve got to build trust and show this is at the heart of what their business does… I guess the proof is in the pudding with that. Do the words match the deeds?”

Speaking from her personal experience with BetPawa, Akingba thinks they do, describing responsible gambling measures as “part of our organisational culture” and adding that she has “received tremendous support” regarding improving support systems.

The industry has evolved, of course, and that means the perception of new players signing up to operators has shifted. Bayliss says: “If you’re a new operator with limited experience and you’ve seen a high spender come in, in the old days people would rub their hands with glee. [They’d think] this was a great customer. Whereas the suspected reality now is it’s a player that’s been shunted out of all the other operators they’ve played, because they eventually hit thresholds.”

From Burge’s research, he believes safer gambling measures can help with player acquisition. He explains: “I’m hearing CEOs of various operators say ‘we want to have more high-value, low-risk players, and we don’t want high-risk, high-value players’ because that’s not good for the industry.

“You’ve got to start looking at this as a system. If you change something in terms of acquisition, maybe you make a better offer or take some friction out. It might improve one metric, but what if it negatively impacts some other marker of harm further downstream? You can’t change one without another.”

He frames it as a tension between different internal teams with growth and control as their independent targets. “Who wins that argument in many industries? Not just this one. The growth team is always the loudest voice in the room and will tend to win the argument.”

However, from Growth Exposed’s research, he has seen evidence that welcome bonuses can put people off and responsible gambling measures can be more effective for acquisition and growth. He explains: “[Bonuses] feel like a trap. ‘Why are you paying me to do something that should be fun?’ Whereas when they see safer gambling messaging on the site, they can be reassured that ‘they’re not here to just rip me off. There are tools in place and safety nets I can put in.’

“So, not for everybody, but for those who are new to gambling, you can build a proposition that is better for that player but also encourages them to use these tools as early as possible, and set them up to be less at risk.”

Collaboration as a solution

“There’s collaboration with not-for-profit organisations around problem gambling,” says Akingba. “That’s a good thing, because we all are coming from very different perspectives, and when everybody has a seat at the table, throwing different ideas together, you are creating a solution that is more practical and realistic than when we are just sitting down with assumptions. I like that collaboration on responsible gaming is continuing to grow.”

Working together is part of the dream for Douglas as well, who advocates for a more collaborative approach between casinos. He says: “If I could wave the magic wand, it would be great if we could share our experiences a bit more.”

Hand in hand with collaboration is awareness. As Akingba puts it: “Nothing beats awareness, because you can put all of the help and tools within your platform and people just don’t know.

“When you build awareness, it covers every aspect of the industry, retail operations and online operations. If there’s any narrative I’d like to change, it’s that operators are doing nothing, or that they are irresponsible, because that is just not true from my experience.”

What changes will we actually see over the next few years when it comes to responsible gambling? Bayliss says: “The industry keeps asking for more certainty and more prescription about what it can and can’t do, which I think is a dangerous thing to ask for, because one size doesn’t fit all. I suspect we might go through a bit of a swing on that, that in the short term there will be more prescriptive requirements.”

Bayliss also warns of the highest-risk problem gamblers going to the black market. “There are some people that no amount of gambling is safe for,” he admits. “How do you avoid those people being left with only one option to go to, which is unlicensed operators that have no safeguards whatsoever in place?”

But there remains a place for optimism, with the good intentions palpable from all four interviewees for this article. As Bayliss puts it: “We’re doing it not because we have to tick a box, but because if you really shouldn’t be spending this much money or time, we’d rather you know that sooner than later.”

James Swann-Phillips

James moved into the gambling industry in 2020 after several years in the sports media working for the likes of Sky Sports, the Daily Mail and the Metro.

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