Working in the gambling industry we fully appreciate the associated responsibility to customers’ welfare and minimising the risk of gambling-related harm. That is why our commitment to protecting our customers and promoting safer gaming is intrinsic to everything we do. Through advocating an understanding of responsible play, providing a range of robust safer gambling tools, utilising technology to identify ‘at risk’ customers, and cultivating a culture of awareness, we are well placed to fulfil this commitment.
As every customer is different, there is no one-size-fits-all approach to identifying ‘at-risk’ play. We employ a wide range of safer gambling measures to identify any issues at the earliest possible opportunity. Assessment and improvement of these measures is ongoing as we respond to developments in technology and customer understanding, as well as new legislation and regulation. However, the most effective means of preventing harm and ensuring a positive experience is through empowering our customers. By providing access to safer gambling tools and educating customers about responsible play, we are equipping our customers with the understanding to use our products and services safely.
Safer gambling messaging
Commensurate with our commitment to keeping our customers safe, safer gambling messaging is incorporated into our operations and communications. Our dedicated responsible gambling website, Keep It Fun (https://keepitfun.rank.com/), provides a hub for advice and information on safer gambling tools, and the Keep It Fun messaging appears on all our communications as standard. We are keen that this messaging is ubiquitous so that customers can easily access support should it be required.
Within our venues, safer gambling messaging is continually visible. We have resources on the casino floors and in bingo halls, display responsible gambling signage, and promote safer gambling on our media screens. We also have resources in the back offices of our venues to ensure that our employees remain cognisant of our commitment to safer gambling and are able to quickly access safer gambling materials.
Safer gambling tools utilised by Rank
We are continually assessing and improving the safer gambling measures we have in place with the objective of minimising the risk of gambling-related harm. The proportion of individuals that display problem gambling behaviours is very small, and we strive to identify these individuals and focus our efforts on providing them with the support they require, whilst at the same time seek to provide a seamless user journey for our customers. The approach that we take inevitably varies by channel and also by jurisdiction. We utilise data models to better identify ‘at-risk’ players, have 24/7 live monitoring for our online brands, and are progressing our ability to have a real-time single customer view.
Safer gambling tools available to customers
In addition to the tools that we deploy to identify those customers who may require support and with whom to interact when appropriate, we also provide tools to help our customers remain in control of their play and reduce the risk of harm. All the information, advice, and signposting for support is available to customers on our dedicated safer gambling website, Keep It Fun.
Customers themselves can apply machine loss and time limits at slots and electronic roulette machines in our Grosvenor venues, B3 gaming machines in the Mecca estate, and deposit alerts on Mecca Max electronic touch screen tablets. When a customer triggers an alert or reaches a self-set machine spend, an interaction is triggered and a notification is sent to a dedicated mobile handset carried by the relevant venue’s manager.
For customers that are concerned that they have a problem with gambling and feel that the tools available are not sufficient to protect them, they can choose to self-exclude. Our Grosvenor Casinos, Mecca Bingo clubs and online sites all offer the option to self-exclude, which is an enforced break from gambling. To support a customer that has self-excluded, their status will be updated automatically on our CRM system which will suppress all marketing communications to that customer and the process of re-joining following a self-exclusion is also arduous by design.
To ensure these tools are used to best effect, it is imperative our employees are equipped with the skills and understanding to support customers and intervene when necessary. Every employee must complete mandatory safer gambling training, with progress being monitored through our online platform. In the past year we have invested significantly in additional safer gambling training for our colleagues. In partnership with GamCare, the leading charity in our sector for support with problem gambling, we are delivering further training to employees to build upon their existing knowledge and skills as to how to interact with customers and recognise changes in patterns of play.
At Rank, we pay particular attention to protecting our younger and more vulnerable customers from being harmed or exploited by gambling in accordance with the Gambling Commission for Great Britain’s (‘Commission’) Licence Conditions and Codes of Practice.
Recognising that customers under-25 are more vulnerable than those in higher age brackets, we factor in the age of our customers as part of our affordability model, and apply automatic deposit limits for all customers under-25.
We employ a range of measures to prevent underage play online and in our venues. For example, our policy of registration at all Grosvenor venues limits the risk of under-18s entering the premises, and we use third-party credit reference databases to check and validate customer registration details online. We do not market our products and facilities in such a way as to appeal to children or young people.
As a means of providing reasonable assurance that we have effective policies and procedures to prevent underage gambling, Rank’s casinos and bingo venues participate in collective test purchasing programmes organised by the respective trade associations.
We take responsibility for protecting our customers’ privacy and keeping their data secure when they play with us. We have a mature approach to data security; our priority is to prevent breach or loss of data and to ensure data is used in a fair and transparent manner.
This is managed via appropriate tooling and processes, with broad alignment to ISO 27001 and enhanced requirements of other regulators including the Commission, the Information Commissioner’s Office and PCI-DSS regulations. We employ a wide range of protection measures, and to ensure the effectiveness of our systems we have regular audits and assessments. All employees are required to abide by policies and procedures that relate to the key data protection principles and information security protocols and must complete mandatory training in respect of data and information security.
For Rank, our focus on product safety and quality means ensuring fairness of play. Customers are not going to play on machines if they are not fair. Failing to ensure product safety and quality can also have regulatory consequences. Rank is required to source its gambling equipment and software for its UK-based casinos, bingo venues and online sites from companies licensed by the Commission. We ensure that our physical and digital games are compliant with regulatory requirements including, but not limited to, speed of play, random number generation, product performance, and return-to-player rate.
When advertising our products, our sole intention is to reach our intended audience, to enable those who are permitted to gamble with us to know about our products and offers and decide if they wish to play with us. We consider the appropriate level of marketing to deliver to our existing customers and the means by which it is delivered, taking a tailored approach rather than producing a high volume of communications. We also follow strict processes to prevent marketing communications from being received by vulnerable groups or persons who have self-excluded. We are constantly evaluating the content of our messaging, ensuring that it aligns with our values as a business and our approach to safer gambling.
While physical health and safety risk is not the most material issue in our wider industry, we treat the health and safety of our customers and colleagues as high priority and are committed to achieving the highest level of standards and ongoing improvement across the Group.
The General Managers of each of our venues are responsible for ensuring that their respective venue’s operations meet the requisite standards and a check and balance is provided in the UK by the dedicated health and safety team conducting regular health and safety assessments for each venue. Results are circulated to the venues leadership team, completion of resulting actions is monitored and any significant issues are escalated and followed up by management teams, with the assistance of specialist external consultants where needed.