In an article published today (1 November), Kindred head of corporate affairs Tom Banks set out the operator’s response to several of the review’s key topics.
Financial risk checks
Among the most controversial government proposals set out in the white paper was the introduction of financial risk or vulnerability checks, designed to prevent customers from gambling with more than they can afford.
Kindred said it was supportive of the proposal generally, but “only where a truly frictionless check was possible in reality, piloted by operators and tested extensively before rolling out via a licence requirement.”
The operator fully believes in using technology to keep players safe, it added, and believes the introduction of financial risk checks is a natural progression from the framework it currently has in place across its UK business.
“However, we believe further work is needed on the nature of the frictionless check itself, so we supported the testing of the check before implementation as a licence requirement,” it said.
“A pilot of this technology is critical to its future success – operators have the experience and systems in place to understand whether it will work in reality, and crucially if it meets the government’s ambition as genuinely targeted and frictionless for players.”
Kindred suggested the checks should be technologically driven and therefore “strongly disagreed” with a proposal for operators to manually review all checks, as this would be “impractical and unreasonable.”
Further, the operator disagreed with proposals requiring operators to acquire postcode and job title data from customers, which it suggested is “not helpful when assessing affordability” and would add unnecessary friction to the customer journey.
Direct marketing opt-in
Another proposal put forward in the white paper would require operators to obtain all customers’ consent in order to share direct marketing and promotional offers with them.Again, Kindred expressed its support for the proposal in general but with some caveats.
The operator supports the introduction of a ‘by channel’ opt-in system where customers can choose through which communication channels they wish to receive direct marketing.
However, it said, the company strongly disagreed with a requirement which would oblige operators to seek ‘re-approval’ from those customers already opted in to direct marketing.
“Our current customers have already consented to receiving marketing communications across channels and for specific products – under law that is applicable at the time they gave consent – and should therefore not be in scope for this proposal,” it said.
Rather, a requirement for the operator to opt-out all of its existing customers and asking them to opt back in “would be going above and beyond the scope of the white paper,” it said.
“If any new requirement stops us from being able to contact these customers overnight, we will have a significant impact on our ability to communicate with them going forward (despite them having previously consented to receive communications from us) and it may impact the more sporadic and infrequent customers,” it concluded.
Online slot stake limits
The government also asked for feedback on its proposal to introduce stake limits to online slots of between £2 and £15, with the possibility of introducing a lower limit for customers aged under 25.
“We were supportive in principle of the overarching ambition to ensure online slots are safe – and made the point that on our platforms, we already integrate measures such as lower limits for 18-24 year olds and lower affordability players on a dynamic basis,” Kindred said in response.
However, it added that it believes stake limits should be based on risk and not “blanket numbers,” as any limit agreed upon will not be followed by operators in the unlicensed market.
“This impact is acknowledged in the white paper, but further consideration should be given to the knock-on effect of a slot limit that is too low in relation to player shifts to the unregulated market,” it concluded.
Consultations on the above matters have now closed, and stakeholders across the industry await feedback on their responses from the UKGC and government.