Guidance for iGaming Operators on Identifying and Supporting Players at Risk of Harm

The Alcohol and Gaming Commission of Ontario (AGCO) applies a regulatory model that is outcomes-based and places accountability on operators to actively prevent their players from experiencing gambling-related harm through their sites. Harm from gambling can take many different forms, primarily stemming from losing more than one can afford to lose. It can be observed through many different behaviours and signs. Player risk exists on a spectrum, and the potential for harm can shift based on a variety of factors and circumstances. Effective prevention requires a dynamic understanding of these factors and how they affect the risk of harm.  

The purpose of this document is to provide registered igaming operators with guidance on practices that support and identify players at risk of harm as required under the Registrar’s Standards for Internet Gaming – Standards 2.10 and 2.11.

The following sections outline AGCO’s current expectations of operators. In line with Standards 2.01, operators are expected to continually review and evaluate their approaches and seek to adopt best practices which, as they evolve and change, may go beyond the expectations in this document.  

We recognize that the ongoing evaluation of these expectations may indicate the need for adjustments to AGCO’s guidance. As operators uncover such insights, we encourage open information sharing with AGCO to support future updates.  

Our aim is for the Ontario igaming industry to lead the way in minimizing the risk of player harm.

Operators must have in place an effective mechanism for monitoring player behaviour in a way that proactively identifies those who may be at risk of harm, enabling timely support once signs of risk emerge. The mechanism should address the different ways in which gambling-related harm can occur and draw on all available data sources to assess risk on a player-by-player basis. Identifying players who exhibit signs of at-risk behaviour is a key part of an operator’s responsibility to minimize gambling-related harms.  

AGCO Expectations:  

• Use both automated and manual tools to monitor players’ behaviour in a manner that enables timely and effective provision of support.
• Monitor indicators either continuously or at a rate that reflects the dynamic nature of player behaviour to ensure detection of where and when potential harm may occur.
• Use available information from various sources to effectively identify indicators of situations where players may be experiencing harm by monitoring risk profiles and behaviours for all players. It is expected that operators are, at a minimum, incorporating the following sources into a comprehensive approach to player risk profiling:
  • Player behaviour indicators, including: chasing losses, playing multiple products, choosing higher-risk products, erratic betting patterns.
  • Player spend indicators, including: amounts wagered and lost.
  • Time indicators, including: “binge” gambling, changes in session duration patterns, late-night gambling, shifts in time of play patterns.
  • Account indicators, including: failed deposits, cancelled withdrawals, higher-risk forms of payment, multiple payment methods.
  • Customer service contact indicators, including: expressions of financial or emotional distress, use of keywords associated with harm, indicators of vulnerability such as bereavement or job loss.
  • Gambling management tool indicators, including: refusal to use tools after operator intervention, frequent increases or removals of bet limits, repeated use of play break tools, previous use of self-exclusion.
  • Player background information, including: player age, player occupation.
• Regular assessment of the effectiveness of risk monitoring methods to ensure that players at risk of experiencing harm are accurately identified, and when players at risk of harm are not identified, acting promptly to correct and improve methods.  

• Where an operator contracts with one or more third-party entities to deliver part of the gambling offering, the operator must have effective systems and processes in place for the operator to maintain its ability to monitor, identify and promptly address high-risk player activity. 

  Read the full standard 2.10 in the Registrar's Standards.

   

Based on players’ risk profiles, operators are required to intervene in a manner that is timely, commensurate with the level of risk, and believed to have the desired effect of reducing that player’s risk of harm. Further, operators are expected to build processes to evaluate the impact of the intervention to support ongoing improvement.  

AGCO Expectations: 

• Provide assistance immediately upon the identification of potential player harm.
• Intervene according to the severity of the situation when players may be experiencing harm.
• Intervene and provide supports for all players who may be at risk of experiencing harm, not just those already identified as high-risk.  
• Use technology to scale the delivery of tailored interventions to more players, rather than relying solely on individual interactions for only highest-risk players.
• Some examples of current practices for tailored and escalating interventions (i.e., adapting interventions to the changing severity of the situation) include:  
  • Player interaction to gather additional information to inform the player’s risk profile.  
  • Player self-assessment surveys (e.g., asking players questions to help them better understand their play).
  • Reminder emails highlighting resources, support services and responsible gambling (RG) tools available to players.
  • Personalized emails that communicate potential RG concerns identified by the operator, with effective communication channels for RG (e.g., dedicated inbox on gaming site).
  • Personalized interactions (e.g., phone call from an appropriately trained individual, e-mail alerts or interactive nudges and pop-ups).
  • Requiring active acknowledgement or response from the player.
  • Providing players with information about their play (e.g., the time spent in an active session and the corresponding losses).
  • Game play restrictions (e.g., operator-imposed breaks and limit-setting).
  • Account suspension or closure.
• Following the execution of each intervention, take necessary steps to assess the impact of the intervention on a player’s behaviour and whether evidence of potential harm persists that necessitates further action. While operators may use different approaches for assessing the impact of various interventions, changes in player risk following interventions should be continuously assessed and responded to as appropriate.  
• Proactively and carefully monitor new players to identify early signs of concerning behaviour and provide immediate assistance, rather than relying on a graduated ‘delay and observe’ approach. 

Read the full standard 2.11 in the Registrar's Standards.

In addition to the expectations related to Standards 2.10 and 2.11 above, the following key practices support overall effectiveness in meeting these and other regulatory requirements.  

• Ongoing RG Training: RG policies and procedures are only as effective as the understanding and buy-in of employees. Training on RG is required as part of initial onboarding for all employees and must be refreshed at a frequency that is appropriate for each position.  
• Training Program Evaluation: Operators should regularly evaluate the training content to include best practices and to ensure it reflects employee feedback.  
• Employee Understanding of Operator RG Commitment: Operators must ensure their employees understand the operator’s commitment to RG and how it is integrated throughout operations.  
• Employee Understanding of Gambling Harms: Operators must ensure their employees understand the harms associated with gambling, along with essential prevention and mitigation concepts.  
• Employees Who Interact with Players: Operators must ensure their employees who interact with players can identify and assist players who may be experiencing harm from gambling and can respond appropriately to players who may be showing signs of problem gambling. Certain roles and employees have a direct influence on player wellbeing, and these employees carry a significant responsibility in ensuring the operator’s RG policies and procedures are effectively carried out (e.g., VIP hosts, customer support representatives, game presenters). Operators should focus attention on such employees to ensure their training is effective to identify and assist players who may be experiencing harm.  
• RG Training Assessments: Operators are to regularly assess individual employees’ understanding of the policies and procedures and the impact of their job functions on player protection, and any identified gaps must be promptly addressed.
• Regularly assessing assistance and interventions to ensure they are effective in reducing harm, and when interventions are found to not be effective, acting promptly to correct and improve their methods.  

Effective record-keeping helps demonstrate how and when operator intervention has occurred and enables operators to assess the effectiveness of these interventions. Operators are responsible for creating and maintaining complete records for all customer interactions. Records should also be maintained for situations where a decision was made not to intervene, along with any resulting follow-up actions. Records should be available to staff to use them to support effective customer interactions. The records related to risk profiling and interventions, including any manual adjustments to player risk scores also help demonstrate compliance with the Registrar’s Standards.