Inside GAMSTOP’s journey to become the UK’s first online national self-exclusion scheme for gamblers

The ability for individuals to voluntarily exclude themselves from gambling premises as a way of preventing gambling-related harm has historically been one of the key weapons used in the fight against problem gambling. However, with the transition of gambling into the online sphere and the anonymising qualities that conveys, self-exclusion has become a whole different ball game.

In theory, the introduction of technology into the self-exclusion mix should make the whole process easier for individuals wishing to gain control of their gambling before it perceptibly becomes an issue. The sheer volume of data regarding player online gambling should make it easier to generate statistical models and means of countering gambling-related harm, right? However, as the solution becomes simpler, the possibilities for new issues to arise becomes even more prevalent.

This issue is no more readily illustrated than in GAMSTOP, the UK’s first national online self-exclusion scheme. GAMSTOP offers UK players the ability to exclude themselves from all online gambling and betting sites for a fixed period depending on individual player preference. It is a scheme which is billed as a “one site, one click” self-exclusion method, but has been hit by an issue outside of its remit, namely the absence of a national ID system. This has resulted in a scheme, which was due to go live in 2017, being delayed for more than two years and several technical issues relating to player identity verification.

But is GAMSTOP ultimately doomed to fail because of the lack of national ID? Fiona Palmer, GAMSTOP CEO, believes it’s too early to read the scheme its last rights, instead choosing to look upon this as a positive rather than a negative. “We are proving that by using clever matching mechanisms and having support from operators and the regulator, national self-exclusion can and will be an important harm minimisation tool for the online sector in the UK,” Palmer adds.

Getting over the final hurdle

The statistics certainly back Palmer’s optimism up, as over 100,000 people have registered with GAMSTOP since the scheme’s ‘informal’ launch in April 2018. This strong sign-up rate comes despite the scheme not having been actively promoted across the UK. Despite the informal nature of the scheme, Palmer asserts the scheme is effectively live to UK players. “We went live in April 2018 and a total of 63 separate operators integrated with us at that time. I think we’re down to about single digits of providers who are left to register with us, which is hugely positive.

“It’s important to remember that when we talk about operators, we’re talking about companies who have multiple websites, and in some cases hundreds of websites, which have all integrated with us,” Palmer adds.

However, one final hurdle remains in getting GAMSTOP to be recognised as a truly national self-exclusion scheme: the activation by the Gambling Commission of LCCP social responsibility clause 3.5.5, which states that ‘licensees must participate in the national multi-operator self-exclusion scheme’. At this point the need for operators to join the scheme moves from a voluntary to a mandatory requirement, with non-integration potentially landing the operator with a financial penalty.

Despite recent media coverage suggesting this activation was imminent, the UKGC subsequently issued a statement dismissing reports, claiming it had not received the “necessary assurances” in order to do so.  These reports were also a surprise to Palmer who believes this is an understandable issue of confidence, for both GAMSTOP and the UKGC, in that GAMSTOP needs to demonstrate the effectiveness of all aspects of the service, which includes evidencing that all licensed entities can effectively integrate with the scheme, while the UKGC can only publicly instil its confidence in GAMSTOP (via the licensing condition) once this is done.

Ticking all the boxes

So, what remains for this to occur?  Some operators which have received a licence from the Gambling Commission have yet to commence regulated operations. As Palmer explains: “We have several operators which are registered with us, but which are not fully integrated with the GAMSTOP database mainly because they are not live to players in the UK.”

As part of its role, the UKGC will direct these firms to GAMSTOP’s door during the licensing process. Indeed, Palmer believes, as has already been demonstrated by many newly licensed operators, responsible operators will want to be “set up from the absolute outset” to integrate with the scheme, asserting from her experience of dealing with integrating operators that it is “far easier to build in GAMSTOP functionality from the outset rather than retrospectively integrating with it”.

Despite the symbiotic relationship between the UKGC and GAMSTOP, the two entities remain independent of each other, something which is in stark contrast to national self-exclusion schemes in other countries which are all largely run by their respective regulatory entities. As Palmer explains, regulator run schemes overseas usually rely on a national ID system run by the government involved, meaning the scheme can operate a very “one-to-one” relationship. “Without the national ID, we must take a far different approach regarding self-exclusion, which ultimately comes down to the actual identity of the person involved,” Palmer adds.

Independence day

Aside from dealing with the absence of a national ID, Palmer cites the need for GAMSTOP to remain independent from the industry as being a central part of her role as CEO. “It’s important that we are seen to be an independent organisation because, at the end of the day, we are providing a service for consumers.”

This drive for the scheme’s independence is something which has been reflected in its board appointments, most notably in the appointment of Jenny Watson CBE as the scheme’s first independent chair in September 2018. GAMSTOP’s board currently comprises five members, including Watson, who are appointed on two-year terms. Watson’s appointment was followed by the appointments of independent board members Kevin Beerling and Dr Jo Watts earlier this year, and more recently the appointment of Mike Dixon, CEO of Addaction. Board members are mandated to meet on a quarterly basis, however Palmer says board members are in regular contact with each other on pressing issues affecting the scheme’s day-to-day operations.

In addition, the Remote Gambling Association, which was appointed as the sole owner of GAMSTOP’s parent company, National Online Self-Exclusion Scheme Limited, during the scheme’s development phase, divested this responsibility to the GAMSTOP board. This recent development marked full independence for the scheme for the first time.

A key part of increasing awareness of the scheme among players is promotion, something which GAMSTOP has not actively undertaken in the same way as its publicity hungry counterpart GambleAware. Despite this, Palmer asserts her belief the scheme has surpassed expectations in attracting almost 100,000 players despite no obvious publicity and the fact that it has not yet become a licensing requirement.

Much of the credit, she believes, goes to the scheme’s operator partners, which have all played their part in signposting players to GAMSTOP using branding and links on their respective websites. “It shows the industry can come together and collaborate on something to the mutual benefit of all and deliver something which will hugely benefit players,” Palmer adds.

However, there is much more work ahead for both the scheme and operators in raising awareness of GAMSTOP. As part of this, GAMSTOP will be conducting several as yet undisclosed activities designed to better market and raise public awareness of the scheme among UK players, and is building closer relationships with organisations that support people who have a problem with their gambling such as Gordon Moody and GamCare. Self-exclusion remains a tough sell to players, largely because of a perceived lack of willingness among gamblers to recognise when a normal activity becomes a problem and a reluctance to deal with it. Palmer disagrees and thinks that greater education about the self-exclusion process and its potential benefits is important in its own right. “It’s also about reaching out to all those people who need to know about it, making them aware that in the event their gambling becomes out of control that it is easy for them to access the tools and information that they need to address the issue,” she explains.

Stop the press

In January, GAMSTOP hit the headlines for the wrong reasons when a BBC investigation found individuals who had previously self-excluded on the GAMSTOP site could gain access to operator sites merely by changing a few personal details. At the time, GAMSTOP cited difficulties in matching consumer records, together with the diversity in verification methods being used by operators, as important factors in the issues.

When pressed about how the scheme has overcome these issues, Palmer asserts that they have been dealt with through technical changes to the scheme during the year but is reluctant to define specifics for fear of giving away the keys to the kingdom, so to speak. Qualifying this decision, she asserts that GAMSTOP “is about giving people control to exclude themselves from gambling, so we don’t want to let them know the way to get around that self-control because they may take it. They are doing something brave and difficult in acknowledging that their gambling has become a problem and we need to support them in tackling that, not inadvertently undermining their effort”.

Much of the work in addressing these issues has been done by the UKGC through external changes to the licensing codes of practice, closing many of the technical loopholes hampering the scheme. “They have been extremely supportive in promoting the use of GAMSTOP to UK operators and players, not so much in terms of advertising, but in terms of the regulatory changes they have put in place,” Palmer adds.

Citing numerous instances where the UKGC has come to the aid of GAMSTOP, one important area is the change of regulations to force operators to verify player identities before any deposits are taken. The removal of the 72-hour verification window will, she believes, prohibit the sorts of issues identified in the BBC’s investigation from occurring again.

In addition to paying homage to the role of the UKGC in at least vicariously helping to address GAMSTOP’s issues through regulation, Palmer singles out the role of the scheme’s technical team in keeping GAMSTOP a “one-size-fits-all” scheme. “The scheme caters for operators of all shapes and sizes, but as part of that approach we deal with the complexity element on our side of the divide, so that it is as easy as possible for operators to integrate with us quickly and securely.”

Despite this perceived success in getting operators to sign on, Palmer is reluctant to label the scheme as the most definitive method of addressing gambling-related harm, claiming there is no ‘silver bullet’ in addressing this issue. “No tool is infallible, but it’s about layers of friction, barriers, and putting multiple layers in place to prevent individuals from encountering gambling-related harm,” she adds.

A busy marketplace?

The responsible gambling sphere of treatment solutions and tools has become a more crowded place over the last five years, with self-exclusion schemes now not the only pony in the race. Gambling blocking software such as Gamban has enjoyed successful trials with some of the bigger operators and has attracted the support of GambleAware. In addition, many financial institutions, including so-called ‘challenger’ banks like Monzo and Starling and several high-street banks, have begun to introduce gambling-related spending functionality, enabling players to stop their gambling by stopping payments.

With so many options now available to players, is GAMSTOP in danger of being left behind? Palmer does not think so, in fact she asserts every solution plays its part in preventing gambling-related harm and none are in competition with each other, rather they complement each other. Explaining this multi-faceted approach, she adds: “Ideally, individuals would register with GAMSTOP, download gambling website blocking software and then switch to a bank with the ability to block gambling-related transactions.”

The switching of the responsible gambling agenda increasingly towards a bank and affordability-led approach is something that GAMSTOP welcomes because it gives people a greater degree of control over their gambling. “Consumer choice is absolutely key. I also think putting the right layer of friction is also high on the agenda because you don’t want to make it too easy for individuals to switch the controls they’ve put in place off,” she adds.

Another brick in the wall

Despite the increasingly elaborate nature of the solutions on offer, Palmer believes the importance of face-to-face treatment for gambling-related harm cannot be underestimated. As part of its activities, GAMSTOP has worked, in conjunction with fellow awareness body Gamcare, to train NHS staff working at the government’s flagship NHS Northern Gambling Treatment service on a variety of gambling-related issues.

“It’s very much about working together to deliver a common goal. We’re part of that solution and as I’ve said there’s no silver bullet to addressing gambling-related harm. It is a layered approach that centres on making it easy and accessible for consumers to access problem gambling treatment,” she remarks.

So, what does the future hold for GAMSTOP? Ultimately the biggest test will come when the scheme becomes a national one with the activation of the UKGC’s licensing condition. However, until that takes place, Palmer believes much of GAMSTOP’s work is about educating gamblers on the merits of self-exclusion as “ensuring that people who need us know about us”. Once both these factors are aligned, the scheme can take its place among the national self-exclusion schemes of the world.