Consumer Protection Strategy

Preventing Excessive and Underage Play and Promoting Safe Play

Introduction

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) Responsible Gaming Standard and the World Lottery Association (WLA) 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.

Our Focus

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.

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Our Commitments

Research

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. Camelot has made additional contributions to GambleAware to fund further research into participation of young people in gambling. These include a literature review of children and young people’s gambling, and research to develop an understanding of young people in relation to gambling and gambling–related harm.

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.

Retailers

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.

Digital

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. 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 things such as account limits, play limits, wallet load limits and self exclusion. A full list of tools can be found on The National Lottery website.

We aim to encourage more players to use 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 to maximise effectiveness.

We have been working in partnership with behavioural analytics company, Featurespace, to try and spot patterns of behaviour that may amount to problem play. Alongside this we have been trialling different intervention types to see what is most effective at changing players behaviour over time. We’re the first lottery operator to collaborate with Featurespace and we’re proud that this pioneering research will make sure our players continue to have fun, with all the tools necessary to make sure they can stay in control of their playing habits.

Our digital platforms undergo an annual independent review by GamCare, providing assurance that we are compliant with good practice in consumer protection and helps inform the evolution of our consumer protection strategy.

We are committed to ensuring our site is accessible and usable for all abilities and disabilities. Our website is built in line with accessibility best practice and is accredited by AbilityNet. For more information click here.

Game Research and Design

As well as conducting primary and secondary research an assessment tool is 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 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.

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 GamCare 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 website, outlines how to play responsibly.
  • Our Corporate website has tools to help players understand their playing behaviour and its impact on themselves and others.
  • On our website we highlight common Lottery scams so that we uphold the integrity of our brands.

Advertising and Marketing

The Advertising Standards Authority CAP Code and BCAP Code 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.

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 GambleAware.

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 offer impartial advice. To aid the winner with their life changing transition a life coach is also available.

Continuous improvement

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 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.

Online tools

We will continue to develop our suite of online control tools to support players in managing their play. In 2017 we will be introducing automated self exclusion, reality check pop ups and short term breaks.

Behavioural Analytics

We continue to use play data to better understand patterns of play to identify problematic play early. Using this data for targeting we are also exploring different ways to engage players in using our online tools.

Retail Strategy

Each year we strive to improve our underage mystery shopper scheme to better target our testing, and improve support for retailers. We are also researching additional support for retailers in spotting potential problem play.

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