The government’s publication of their response to the Culture, Media & Sport’s Select Committee inquiry on gambling and the consultation on reinstating the triennial review of gaming machine stakes and prizes, both lead me to the conclusion that DCMS may be finally realising that stakes and prizes have little to do with problem gambling and that there may be better ways of dealing that tiny percentage of people who have a problem with their gambling.
Appearing in a number of places in the documentation[i] is the concept of using technological methods to help prevent problem gambling. This is not a new idea and one which will eventually see its day in the UK. The most often quoted example is that of South Africa, where to use the slots in their casinos, customers need a player’s card. This has to be inserted into the card reader attached to the slot machine before play can commence. The idea being that the customer’s play can be analysed by algorithms in specially designed monitoring software and if they begin to show problem gambling behaviours (such as chasing losses) then casino staff can be alerted to intervene.
The example given in the documentation was of a slot machine which if it noticed problematic behaviour would bring up a ‘timeout’ screen which would show the customer how long they had been gambling and how much they had spent.
These are indeed very laudable applications. But let me take you on a journey and we soon see that if we are serious about preventing problem gambling through technical means, which this author thinks is probably the only way to do it, we may have to trample on some civil liberties in order to do so.
First let us consider that any technological system that analyses customer play for problem gambling characteristics needs a method of identifying the customer. Without this, any machine can only consider play by individual stake. A customer who stakes £5 can be recognised for the spins he plays using that £5, but when the next stake goes in, the machine is blind and doesn’t know if the person putting in the next £5 is the same player or someone completely different.
So we have to have some form of identifier. This is the first problem as the majority of gamblers, due to the social stigma poured upon them (usually by newspapers who have their own online gambling offers), like to preserve their anonymity. While it’s possible to do players clubs with anonymity, just look at Ladbroke’s Game On card, it wouldn’t be for any serious attempt to analyse problem gambling. You would need to ensure that players used the same card and didn’t swop them with their friends or have multiple ones. This doesn’t matter with a loyalty scheme, as it’s the customer who loses out, but is imperative when tracking behaviour, that you are tracking the same person all along.
We then hit the next problem, which is one that already exists when it comes to gamblers self-excluding themselves from gambling premises. At present, all UK licensed gambling venues (both on and offline) have to offer their players a means by which they can self-exclude themselves. This is a very valuable tool, not only for those with a problem, or are worried they may be getting a problem, but also for the significant proportion of self-excluders who do so purely for financial or other reasons. The issue is that these self-exclusion schemes are only venue-based. Some operators have gone further and have made their schemes cover all the venues they operate. However, there is no national scheme and as many problem gamblers have complained, if you have self-excluded yourself from one bookmaker, all you have to do is cross the road and go to a another one operated by a different chain.
There are some very good practical reasons why a national self-exclusion scheme doesn’t exist. The main one being that at present it depends on individual venues having a folder full of mug shots and details of the self-excluded. That is fine when you are self-excluding tens of people and trying to recognise who is coming through your door. But if we had a national database, each venue would need a folder full of 66,978 mug shots (the average total number of self-exclusions 2008-12[ii]) and that would be nigh on impossible to manage.
The same would apply to any player’s card system. While it may show up a problem gambler in one venue, all they would have to do to continue gambling would be to move to another venue operated by another company. This is not the end of the world – it is the system operated in South Africa, but what it does is not best serve the problem gambler. From what little we know of the condition, is that a) problem gamblers utilise a large number of types of gambling, and b) their condition emerges over time, frequency of gambling being one of the key variables in determining a problem gambler. By just having a firm-wide player’s card you would just get a snapshot of a player’s gambling behaviour. It would do some good but it wouldn’t be the optimal solution.
The optimal solution for preventing problem gambling is that everyone who wants to gamble has to have a player’s card that tracks all of their gambling behaviour, over time and over different venues. Such a card would solve a number of problems in one go;
Firstly, if customers had to prove their age (and subsequently identity) to get such a card, then we could definitively solve the issue of underaged gambling (taking it that gambling would be impossible without such a card).
Secondly, it would enable a fully functional national self-exclusion scheme. Unfortunately at the moment, the number of known breaches of self-exclusion is shockingly high, 21% for the whole industry average over the four year period (2008-2012) and in 2010-2011, the bookmaking industry had a self-breach rate of 49.3%[iii]. With a card system, like with underaged gambling, the system would be watertight.
Thirdly, such a system would provide for the first time ever, significant amounts of data about gambling behaviour (frequency, spend, gambling type) which would only go to fill the near void that is problem gambling research and so lead to more effective prevention and treatment.
And finally, such a system would pick up problem gambling behaviour more effectively as it would be able to consider player behaviour over multiple gambling episodes and venues.
A major benefit for the operators would be the player information they would get. For the first time it would be possible to see what each punter does. Where he visits, what he spends and how long does he dwell for. This is invaluable information for a traditionally cash only and therefore anonymous business. One only has to look at the success of the Harrah’s[iv] Total Rewards loyalty scheme to see how useful the data could be. And it’s not like the industry isn’t used to collaborating on jointly beneficial projects; the big bookmakers all own SIS who used to solely provide the pictures into their betting shops, while the bingo industry operates the National Bingo Game across most of the operators and casinos share information about cheats. So a pan-industry solution could be developed.
Now let’s look at the practicalities. There are 12,237 licensed gambling venues operating 134,840 gaming machines[v] (licensed by the Gambling Commission). There are also estimated to be 41,000 category D machines in local authority licensed Family Entertainment Centres, approximately 43,800 gaming machines (predominantly category C) in pubs and approximately 18,000 category B3A and B4 machines and 9,000 category C machines in members and commercial clubs[vi]. So there would have to be approximately 300,000 card readers to cover each of the gaming machines and player points (bookmaker’s window, bingo table, casino table etc.). That’s an enormous cost to implement (possibly £30M+) and a huge enterprise to run (a network five times as big as the cash machine network), but arguably if there was a small fee for the card, the capital cost could be paid off over time.
So in one foul swoop problem and underaged gambling could be solved. There would be a ‘gambling card’ which you would need to purchase before you could indulge your legitimate hobby and it would need to be utilised every time you did so. The central system would analyse your behaviour and if you showed the signs of having a problem, you would be informed and asked to seek help and even self-exclude yourself.
It sounds almost too good to be true doesn’t it?
Well first, let’s consider a couple of issues:
There is a growing trend in the USA and Australia for self-excluded gamblers who have managed to get back in to casinos, lose their money and then successfully sue the casino operators on the grounds that they shouldn’t have let them gamble. If this litigiousness were to reach our shores then we could potentially see gambling operators trying to mitigate their future liabilities by banning customers who show signs of possibly becoming problem gamblers. This may sound like a good thing but may also show up an awful lot of false positives (those considered problem gamblers but aren’t) as well, thus restricting their right to gamble.
On a similar theme, as more neurological research shows that a lot of problem gamblers are ‘born’ as well as ‘made’, surely it would make sense to pre-screen people for potential problems before issuing them with a gambling card. This would fit in with the thoughts of prominent anti-FOBT campaigner, David Lammy MP (Lab, Tottenham) who asked whether ‘someone [should] be able to walk off the high street and wager up to £10,000 in an hour, without any robust checks on your age or your mental health?v Yet again, a nice idea, but one which could produce false positives.
Politically we might not be that concerned about false positives; surely it’s better to be over cautious isn’t it? Does someone have an inalienable right to gamble? No ambling operators ban people all the time (usually for winning too much). Solving the false positives issue shouldn’t be overly onerous, whether it is caused by operators being overly cautious or the system improperly diagnosing a problem gambler, a trip to a trained problem gambling specialist would suffice to get the ‘all clear’.
But possibly the biggest issue would be would the British public wear it?
The majority of those who gamble ‘properly’ (i.e. not just on the National Lottery) do so rarely, possibly just a few times a year, like to bet on the Grand National, would they bother to get a ‘gambling card’? and if they didn’t bother, wouldn’t that take a massive chunk out of the bookmakers or racing’s profits?
According to the British Gambling Prevalence Study 2010;
‘Overall, 43% of adults had gambled on at least one activity in the past week. Prevalence was higher among men (47%) than women (40%). Over a third (36%) of adults had bought tickets for the National Lottery Draw in the past week. Only a small proportion of adults had taken part in each other activity. The next most popular activities were scratchcards (6%), other lotteries (5%), betting on horse races and playing bingo (both 3%). Past week prevalence of participating in other activities was 2% or lower. Notably, the prevalence of playing online slot machine style games, playing poker at a pub/club and spread betting in the past week was less than 1%. Overall, 1% of adults had bet online within the past week, and 5% had gambled online on the National Lottery, football pools, bingo, casino and slot machine style games.’[vii]
So our gambling card would really be of interest to just 6% of the adult population, taking it that we were excluding the National Lottery, whose draws don’t seem to be a problem gambling issue, but including scratchcards which are a different matter. This equates to roughly 2.74 million people[viii]needing to buy a ‘gambling card’ to monitor their regular gambling. Those who were irregular gamblers would either never gamble, or have an enormous proportionate cost of buying a ‘gambling card’ and the effort of registering it, just to have a flutter – so may very be deterred from having a ‘flutter’, or the industry could just pay for them to get a card and make registration as simple as possible and done online.
So it really could be feasible, except for the fact it stinks of a proxy ‘National ID card’, which the Labour government tried to introduce for all the right practical reasons, but failed because of the level of emotive opposition, that hated the idea that an Englishman had to be identified by its government, however much time and effort it would save. The right to anonymity trumping the desire to have to produce numerous different documents just prove who you are.
The other problem of a ‘gambling card’ comes with where it takes us. The British public’s biggest health crises is caused by our behavioural problems, we eat and drink too much, take too many drugs and don’t take enough exercise. In the same way that a ‘gambling card’ could prevent problem gambling by identifying those who may be exhibiting a problem and alert them (and others) to the need for intervention, a ‘drinking card’ could also be introduced to look at our alcohol consumption and even a ‘fatty food card’ could go to prevent a descent into obesity.
All of these legitimate health issues could undoubtedly be better solved by the tracking of our behaviour. The technology is there to do it and arguably, the unit cost of such technology can only drop with the more of the public that use it. If there was an ‘adult purchase’ card that covered alcohol, cigarettes, gambling and high fat products, we could, in theory save millions of our health costs and make us all happier in the future.
But do we really want the state, however well meaning, monitoring our vices? Big brother may well have our best interests at heart but do we want him watching us so closely? Do you want there to be a record, however well kept, of how much you drunk, smoked, ate and gambled?