To achieve this, we want to offer our customers fun and entertainment, whilst ensuring that they play within their means. Safer gambling considerations are therefore at the forefront of our consumer engagement and embedded into everything we do. We continue to develop our approach, utilising new technology and deepening employee awareness, to increase the sophistication of our methods of detecting at-risk play.
Safer gambling messaging
The focus on keeping our customers safe underlines everything we do at Rank. Safer gambling messaging is incorporated into our operations and communications across the Group, internally and externally and across all the brands. The objective of consistent safer gambling messaging is to maintain a strong awareness amongst customers, ensure that relevant support is signposted and easily accessible, and keep safer gambling central in the minds of our employees.
In the UK, our standalone, dedicated safer gambling website, Keep It Fun (https://keepitfun.rank.com/), provides a hub for advice and information on safer gambling tools available for customers gaming online or in our venues, including ‘How to' materials. The Keep It Fun messaging appears on all our communications, as standard.
We follow industry best practice on safer gambling messaging. This year we conducted a full audit of our messaging against the GamCare Code of Conduct, which has updated the requirements for the visibility of safer gambling messaging in UK land-based venues. We now have ’360’ messaging on safer gambling across aour locations.
In our Spanish venues, safer gambling messaging can be found on all slot machines and on posters in the venues. These signs provide information on where players can seek help, and there are resources and links to gambling charities on the safer gambling page of the Enracha website. For the Rank Spanish digital business, all sites have a links to a safer gambling resources and support organisations.
Safer gambling tools for customers
To minimise the risk of gambling-related harm we provide customers with the right tools to help them remain in control of their play. We continue to review our existing measures, introduce new tools or updates based on player behaviour, and ensure that we are compliant with industry requirements.
Customers can set deposit, loss or time limits on machines in venues and on games online to manage the amount they spend or monitor the time spent playing. All our channels 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 marketing system which will suppress all communications to that customer.
Detecting at-risk customers
Even with the actions we take to inform our customers about safer gambling and the tools we provide to facilitate responsible gaming, a very small proportion of customers will exhibit problem gambling behaviours. As such, it is critical that we take every appropriate step to quickly identify these individuals and provide them with the support they require.
For the digital space we employ technological solutions for detecting at-risk customers including use of data models. We are developing a Central Engagement Platform (‘CEP’), with the objective to create a single source of truth for data in the business. Currently, the CEP draws on 35 data sets from Mecca, Grosvenor, and the digital brands in the UK, and we are beginning to utilise this information to enable data driven decision-making across the Group. As safer gambling is such a central focus for Rank, we have already developed models to improve efficiency in detecting at-risk customers, including monitoring play in our Grosvenor venues. Now, when an individual exceeds a pre-determined spend threshold, an alert is sent to the management system of that casino, triggering an interaction by a member of the team with that customer regarding their level of spend.
In our gambling venues our employees are trained to monitor players and recognise signs of harmful playing behaviour. Every employee must complete mandatory safer gambling instruction on an annual basis, with progress being monitored through our online platform. Additional training is provided as required or according to a particular role’s needs. Extensive training was provided to circa 1,200 employees across Mecca, Grosvenor and UK digital business this year to embed and enhance ownership of and accountability for promoting safe gambling behaviour amongst our customer-facing teams.
The response from participating colleagues has been excellent, with feedback reflecting a greater appreciation for the importance of safer gambling and a much greater understanding of how to approach customers.
Preventing underage play
A constant consideration in our marketing is ensuring that none of our communications or advertising is presented in a way that would appeal to children or young people. We employ a number of different methods in our venues to prevent underage individuals gaining admission, including IDScan technology, CCTV and compulsory registration. In our UK digital business, we use third-party credit reference databases to check and validate customer registration details; this check is aimed at preventing under-18s from qualifying for access to our sites.
In our Spanish digital business, the age verification process is conducted in conjunction with the regulator.
Protecting vulnerable customers
Our Markers of Harm model assists in safeguarding the interests of vulnerable customers by using demographic, transactional and behavioural data, as well as known markers of harm to assess customers. Any individual that scores in the high-risk category will not receive any marketing communications from any of our brands.
At Grosvenor we have taken a number of significant steps in relation to vulnerability. We have updated the safer gambling policy to make it clearer. This includes our approach to identifying potentially vulnerable individuals and we have provided complementary training for our employees on how to manage a situation like this, should it arise.
We recognise changes in customers’ circumstances when conducting interactions, particularly life events, changes to financial situation and any medical issues our customers bring to our attention. Potential or known vulnerabilities are recorded on the customer’s account and taken into consideration when assessing their play.
In Spain, we received specific guidance from a safer gambling specialist on dealing with vulnerable customers. There is a particular focus on the approach to customers in crisis, including those with drug addiction issues or at risk of suicide.
Customer privacy and data security
To ensure that our customers have complete confidence in their playing experience, it is critical that we protect their privacy and keep their personal data secure. As such, we maintain clear principles of accountability for data security. The Board of Directors has ultimate responsibility for data security, with clear reporting lines and delegated responsibility through the Chief Executive to the Chief Information Officer, Chief Data Officer and Director of IT Security.
Our Spanish business aligns to the same framework; an external local data protection officer (DPO) puts in place all data security protocols and monthly reports are provided to the Group DPO.
Our data protection policies provide direction on all data handling matters including user rights, data retention, data sharing and security. This year we introduced a new process for reporting of data breaches. The objectives were to improve ease of reporting and to encourage people to report near misses.
Reporting near miss data breach incidents should reduce the number of actual incidents, as people are more aware of the risks and improvements to processes can be identified before a breach occurs.
The protection measures we employ are dependent upon the level and type of security required. These include, but are not limited to, password management (complexity and frequency of change), multi-factor authentication, firewalls, encryption, role-based access controls, end point protection, intrusion detection/prevention, and employee education, and are all aligned with industry best practice.
A managed service Security Operations Centre is in place, monitoring data interactions by users and devices across the Rank estate. This then reports any activity of concern into our Information Security Team, ready for further investigation.
Product safety and quality
In accordance with regulations in the UK, Rank must ensure that the equipment it uses meets the conditions of its operating licences, both venue-based and digital.
All the gambling equipment and software we obtain comes via companies licensed by the Gambling Commission. In Spain, our Compliance Manager conducts audits of the venues every three months to ensure that the licences on slot machines are valid. All gambling products installed in our venues are certified and in accordance with regional regulation.
Monitoring the safety performance of our products is critical to delivering a seamless player experience for our customers, as well as ensuring that our games are operating in accordance with regulatory requirements. Across all our venue and online brands we track performance of the equipment so that we are alerted to any potential issues as quickly as possible and can take active steps to maintain target performance levels.
Promoting our brands to consumers requires a careful balance of effective advertising and ensuring that we are only doing so responsibly. In both the UK and Spain there are clear regulations governing the advertising of gambling products that ensure consumer targeted communications reach the intended audience and do not promote it as a resolution for financial difficulties or loneliness issues. Any new or materially different materials are reviewed by our Compliance Team before release to assess the tone and intent and that they are not contravening any regulations.
Safer gambling is a critical consideration in our advertising and we are committed to providing consistent and effective safer gambling messaging when we market our products. In the UK, in compliance with Betting and Gaming Council ('BGC') commitments, and in addition to the safer gambling messaging which must be included in all advertisements, 20% of our ‘above the line’ media expenditure in the UK is reserved for safer gambling messaging on campaigns. The Advertising Standards Agency (‘ASA’) guidelines were updated in October 2022, which has sharpened focus on the imagery used externally to make sure that it does not appeal to children. As a member of the BGC, Rank also follows the industry body's Code for Responsible Advertising.
For the venues business in Spain, there is no obligation to display the ‘responsible gambling’ message in our operating locations of Catalonia, Madrid and Andalusia, however, we always add the message to our advertisements. For the digital business in Spain, whilst we always display the ‘responsible gambling’ message when required, the obligation to do so is dependent on the following: content and type of communication, communication channel, the targeted users/those potentially impacted, and which company is responsible for the communication.
As an operator of physical venues across the UK and Spain, it is important we take all necessary measures to ensure the physical health and safety (‘H&S’) of our customers and colleagues. We are committed to achieving the highest standards in H&S across the Group and continue to improve and update our processes in line with the local government guidance and approved codes of practice. To improve efficiency and oversight, we have introduced a new safety management system for the UK venues which amalgamates all our previously disparate platforms into one online portal. This has streamlined and improved the data collection and management process, creating a singular dashboard with all relevant information.
Interactions with our customers are a key enabler to improving our service and turning player engagement into a competitive advantage. It is important that customers have clear channels of communication for them to feed back to the business and that they are provided with any support they require in a timely and friendly manner. The customer service team can be contacted via live chat, phone or email. The findings from the feedback gathered are shared with the relevant teams internally in order to drive continuous improvement.