Consumer Protection Strategy
Preventing Excessive and Underage Play and Promoting Safe Play
Camelot is committed to maximising returns to society in a responsible way. Our main responsibility is the prevention of underage play, prevention of excessive play and safety for all players and non-players.
This strategy is an important element of our overall business strategy. It sets out how we aim to achieve our aims through providing a safe gaming environment, both online and in retail, and how strict responsibility guidelines aid the development of National Lottery games so that they are safe to play.
We aim to maintain the clear differences between National Lottery games and those developed by gambling organisations, so that players continue to consider the National Lottery an activity which is fun, low risk and culturally acceptable. Our games encourage a lot of people to play a little, have robust measures to protect consumers, and show a clear link to National Lottery Good Causes.
This strategy is aligned with the European Lotteries Association (EL)1 Responsible Gaming Standard and the World Lottery Association (WLA)2 best practice guidelines and certifications. Camelot has been awarded the highest level of accreditation by the WLA Responsible Gaming Framework (Level 4) which recognises our commitment to continuous improvement in Consumer Protection. All our responsible play initiatives have been rigorously audited in line with the EL Responsible Gaming standard.
Underage Play Prevention Deter the sale of National Lottery products to people under the age of 16 and discourage underage play in any form
Preventing Excessive Play Promote and support positive, non-problematic play to all players, and prevent the misuse of National Lottery products
Safety Ensure that consumer safety is at the core of the design, development and distribution of National Lottery products, and that all consumers are able to make informed choices about play and support services
Camelot supports independent research, studies and conferences that contribute to the wider understanding of problem gambling. We use online player data to establish definitions of healthy and problem play which helps us understand triggers of problem play and fraud.
B. Staff training
All Camelot employees are trained to understand our commitments to Consumer Protection and support them in their daily operations, with extra training for those who directly impact consumers. Regular on-going awareness is driven through our internal communications channels.
Camelot provides information and training to National Lottery retailers about their responsibilities towards Consumer Protection issues via regular retailer training, our bi-monthly retailer magazine ‘Jackpot’, and with posters and stickers for their shops. Our mystery shopper scheme and a sales refusal register help us gain assurance that our safeguards to prevent underage play are effective. We retain the right to remove the retailer’s terminal and terminate their retail agreement at any time for failure to implement sufficient safeguards.
Camelot’s digital platforms offer protection to players from excessive and underage play. A rigorous registration process incorporating age verification checks is key to this protection, and ensures that all registrations are from individuals over the age of 16.
Once the player is authorised they are provided with information and tools to help them make informed decisions about their play, manage their experience and avoid excessive play. These tools include:
- 1. Account limits
- (a) Instant Wins play limit from 5 to 75 per day (operator-imposed maximum limit of 75 per day)
- (b) Weekly added funds limit from £10 to £350 per week (operator-imposed maximum limit of £350 per week). This limit can be set at any time, or during the registration process
- 2. Keep track of funds added and spent in Account pages
- 3. Direct communication via email about player protection issues
- 4. Self-exclusion options for players, including permanent exclusion
- 5. Time and money spent is highlighted on the gaming screens and play statements to serve as a reality check
- 6. Ensuring that all games, including trial games, are only accessible after registration and once age verification has been completed
We are committed to ensuring our site is accessible and usable for all abilities and disabilities. Our website has been built in line with accessibility best practice and is accredited by AbilityNet, a charitable organisation specialising in website accessibility. We comply with the Web Accessibility Initiative (WAI) guidelines set out by the World Wide Web Consortium (W3C) and we maintain Level AA of the Web Content Accessibility Guidelines 2.03
Digital player data is run through behavioural analytics to identify patterns that may be early signs of problem play, such as those who regularly reach the maximum weekly play limits. These players are sent an email to remind them of the tools and support options that are available to them in order to encourage responsible play.
Accredited by GamCare
Our digital platforms undergo an annual independent review by GamCare, which provides assurance that we are compliant with good practice in consumer protection and helps inform the evolution of our consumer protection strategy.
E. Game Research and Design
As well as conducting primary and secondary research two assessment tools are used in different stages of the game development process to assess the potential impact of games on players:
- Early in the game development process, the GAM-GaRD tool4 and the ASTERiG5 tool assess the main structural and situational characteristics of a game for potential problems for players
- Later in the development process, if the game is significantly different to existing games, a market research tool called Game Design Protocol (GDP) evaluates the appeal of the game to vulnerable groups of players
If either tool identifies a potential risk to players, we will either revise the game and/or our marketing, or if the risk is considered too high we will not launch the game at all. Once launched, games are reviewed against the predictions of the assessment tools to assure their effectiveness and inform changes to the game development process.
F. Public Information and Education
Camelot’s aim is that all players and non-players can make informed decisions about National Lottery games. We use a variety of platforms to reach our players and provide them with the right information about responsible gaming. For example:
- All National Lottery products display the GamCare6 helpline details, the odds of winning, and age restrictions
- Our retailers have been trained to advise and provide the information to players, including Games Rules
- Our Players’ Guide, available at retail outlets and The National Lottery website7, outlines how to play responsibly
- Our Corporate Responsibility website Playing Our Part8 has tools to help players understand their playing behaviour and its impact on themselves and others
- On our websites we highlight common Lottery scams so that we uphold the integrity of our brands
G. Advertising and Marketing
The Advertising Standards Authority CAP Code and BCAP Code9 apply to us when marketing and advertising the National Lottery within the UK, and ensure that marketing for lotteries is responsible; in particular the need to protect young people under 18 and others from being harmed by advertising that features or promotes lotteries.
H. Support and treatment for problem gamblers
We want all consumers requiring treatment to be aware of the options available to them. We engage with organisations addressing problem gambling in the UK through GamCare and the Responsible Gambling Trust10.
I. Support for Winners
As well as being a time of extreme excitement and happiness, suddenly winning a substantial sum of money can be an overwhelming and emotional experience for many people. For winners over £500,000, a private banking representative can visit them at home, and we also arrange for a panel of independent legal and financial experts to to offer impartial advice. To aid the winner with their life changing transition a life coach is also available.
Although our impact on problem play is low and we already lead in our provisions for Responsible Play we continue to innovate in our Responsible Play strategy to underpin our digital growth.
Game Design Tools
Our existing tools are acknowledged as very robust, but as we develop new game types we need to make sure that these leading tools are the very best at identifying risks associated with certain game characteristics.
Engage players in online tools
We will engage more players in using our online control tools, which are positioned prominently on our website to make them more accessible. During the period when players are still new to playing online we will include further messaging about Responsible Play. We are also improving the targeting of emails to those players that do hit the play and spend limits.
We seek to use play data to better understand patterns of play that can lead to problem play. Through understanding play patterns we hope to be able to identify problematic behaviours early, build these triggers into our game design process, and take steps to help players moderate their play.
Preventing excessive and underage play in retail
We are committed to improving our current mystery shopper scheme to better target our testing, and improve support and information for retailers who are not meeting our expectations.
1 European Lotteries Association (ELA) Responsible Gaming Standard – www.european-lotteries.org
2 World Lottery Association (WLA) Principles and Frameworks for Responsible Gaming – www.world-lotteries.org
6 GamCare is the leading provider of information, advice, support and counselling for the prevention and treatment of problem gambling. Call 0845 6000 133 or visit www.gamcare.org.uk