6 Customer Interaction  

6.2Bingo Club/Venue Responsibilities
6.3Recognising a Problem – What is problem gambling?
6.4Stages of Interaction or Assistance
6.5Identifying Problem Gamblers
6.6Interaction with the Customer
6.7Recording the Details of Interaction/Assistance

Licensing Objective:  Protecting children and other vulnerable persons, from being harmed or exploited by gambling 

The Gambling Commission issues codes of practice in accordance with their duties which are set out in section 24 of the Gambling Act 2005, about the manner in which facilities for gambling are provided in order to ensure that the three licensing objectives are met. 

Social Responsibility Code Provisions must be adhered to by all licence holders; compliance with this is a condition of holding a licence. Any breach of them by an operator may lead the Commission to review the operator’s licence with a view to suspension, revocation or the imposition of a financial penalty and would also expose the operator to the risk of prosecution and imprisonment. The following section on Customer Interaction, represents one social responsibility code provision and one ordinary code provision. 

6.1 Introduction

The Gambling Commission has the view that operators’ ability to deliver effective customer interaction would be enhanced by ensuring that the policies and procedures outlined in the LCCP contain specific requirements covering a range of key points (identified through the Commission’s compliance work). 

These points are as follows: 

  • Behavioural and other triggers for customer interaction 
  • The use of data to guide customer interaction 
  • Dealing with difficult customers 
  • Recording and reporting customer interactions 

Behavioural and other triggers for customer interaction are covered in section 1.5. 

The use of data to guide customer interaction would be available from loyalty cards or accounts where the licensee has access to customer spend patterns. In considering all relevant sources of information, operators will be best placed to consider the range of customer information collected and collated on individuals for commercial and other reasons, and how this could be harnessed for social responsibility purposes; e.g. to monitor changes in customer behaviour where these changes might potentially indicate that the customer is experiencing gambling-related harm. 

Dealing with difficult customers is covered in 1.6 and recording and reporting customer interactions are in 1.7. 

Customer Interaction is a social responsibility code provision (3.4.1) which requires licensees to do the following: 

Social responsibility code provision 3.4.1 Customer interaction All licences, except non-remote lottery, gaming machine technical, gambling software and host licences. 

  1. Licensees must interact with customers in a way which minimises the risk of customers experiencing harms associated with gambling. This must include: 
    a. identifying customers who may be at risk of or experiencing harms associated with gambling. 
    b. interacting with customers who may be at risk of or experiencing harms associated with gambling. 
    c. understanding the impact of the interaction on the customer, and the effectiveness of the Licensee’s actions and approach. 
  2. Licensees must take into account the Commission’s guidance on customer interaction. 

6.2 Bingo Club/Venue Responsibilities   


The Staff should be aware of the identity of the local club/venue representative (usually the General Manager) who has responsibility for problem gambling issues and provides customer and staff guidance. 


The company should set out their procedures on how to deal with the identification and intervention when a customer exhibits signs of problem gambling. These procedures should detail what types of behaviour should be recorded and how it is to be reported and disseminated to all staff in the club/venue. 


The General Manager (or responsible person) will inform his senior Manager and Compliance Manager of any relevant customer/staff incidents, interaction or assistance that have occurred. 


The company procedure (or Terms and Conditions) should detail the rationale and process for a decision to withdraw service to a customer, or prevent them from using the company premises. 


The company should provide training to identify staff responsibility for reporting observations or incidents to the relevant person who is responsible for problem gambling. Training should also include guidance on how to deal with interaction, while ensuring the Health and Safety of the management and staff. 

6.3 Recognising a Problem – What is problem gambling?  

Problem gambling is behaviour which causes harm to the gambler and those around them, including family, friends and others who know them or care for them, such as those they work with. If someone is struggling to control their gambling behaviour, this can cause stress, depression, anxiety; they may fall behind at work and worry about money. If someone’s gambling is causing any of these effects, it is considered problem gambling. 

6.4 Stages of Interaction or Assistance  

There are 3 stages in the customer interaction process and due to the sensitivity of this interaction; the involvement of management and staff usually depends on their level of training and the company guidelines. 

In most circumstances members of staff will be trained in spotting the signs of problem gambling and will inform the Duty Manager who will evaluate the situation and decide on the most appropriate course of action. 

The 3 stages are: 

a) Identifying problem gamblers – It is crucial to be able to read the signs or look for the characteristics of problem gambling and know when it is appropriate to take action. 

b) Interaction with the Customer – This has to be managed carefully, sympathetically and by the person with the right level of training. 

c) Recording the Details of the Interaction – A company form, Incident Report or possibly the Smart Tablet should be used for this purpose. 

6.5 Identifying Problem Gamblers  

This section describes in detail many of the actions, characteristics or signs of problem gambling: 

  1. Customer informs an employee that they feel their gambling spend is out of control. 
  2. Family and friends may inform staff/management about people that they are concerned about. 
  3. Unacceptable behaviour towards staff, other customers, machines or company property. 
  4. Crying, mood swings, irritability, agitation, restlessness, not caring about their appearance or even personal hygiene. 
  5. Approaching other customers or staff for a loan. 
  6. Significant periods of time engaged in gambling activity, particularly on gaming machines. 
  7. Repeated use of the ATM 
  8. Obvious money difficulties and debts 
  9. Concealing or lying about their gambling behaviour. 
  10. Frequently spending all the money they have brought with them. It should be noted however that some customers may have brought in a pre-determined amount to limit their spending. 
  11. Sees gambling as a way to make money 
  12. Paranoid belief that their gambling losses are as a result of the game being fixed 
  13. Chasing losses, usually on machines 

6.6 Interaction with the Customer  


All conversations with a customer concerning problem gambling should be held privately and discreetly. In simple terms a Customer Interaction is a conversation with a customer about their wellbeing, which may or may not result in further action. These conversations should be logged appropriately. 


Where a member of staff is approached by a customer who believes they have a gambling problem, the member of staff must be supportive and sympathetic and direct the customer initially to notices, leaflets and other sources of responsible gambling information. Additionally, they should let the customer know that the Duty Manager (or appropriately trained employee) has more information available that will assist the customer with their query or concerns. Tell the customer that you will let the Duty Manager know that the customer was interested in the information. 

Report this incident to the Duty Manger who will follow up on this initial contact, to make sure the customer has the opportunity to discuss their concerns further. The Duty Manager will then provide either material produced by the company, or details of the most appropriate provider of help or guidance for the customer’s needs. 


In addition to providing contact details of the sources of help, the Duty Manager should discuss the possibility of self-exclusion with any customer who admits to having lost control of their gambling, or who are exhibiting symptoms of distress.


In serious cases it may be necessary to stop the customer gambling and asking them to leave the premises; this should be conducted at a time when it is safe to do so. The purpose of this is to allow the customer to cool off. 


Where deemed appropriate, or triggered by a defined activity, the member of staff may not get involved at all and the Duty Manager may speak immediately and personally to the customer to discuss evidence of their problem gambling. 


The Duty Manager may act on 3rd party information (such as family member or friend) after ascertaining the truth of the facts. 


With the player’s consent, the Duty Manager may act on information provided, including information from any treatment agency or service, or pass on information to these services. 

6.7 Recording the Details of Interaction/Assistance  


A company form, Incident Report or the Smart Tablet should be used to record the details of any customer Interaction or Assistance where problem gambling is suspected or evident. The Gambling Commission or local Licensing Authority may ask to see these records.