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UK Submission
Licence Conditions and Codes of Practice Page
7 June 2006
Consultation Coordinator
Gambling Commission
Berkshire House
168/173 High Holborn
London WC1V 7AA
Submitted by Email to: consultation@gamblingcommission.gov.uk
Dear Consultation Coordinator:
The Interactive Gaming Council (“IGC”) has been in existence for over 10 years and is an
international non-profit trade association comprising leading companies from around the globe
involved with the interactive gaming industry. Members are operators of Internet gaming sites,
software suppliers, e-commerce providers, information-providers and other companies involved
in the industry and includes high profile companies listed on the UK financial markets.
The IGC is an advocate for regulation of the remote gambling industry and comprises that portion
of the industry that understands the necessity for regulation and licensing of this growth industry. To that end, the IGC commends the UK Gambling Commission on its efforts, including making available the opportunity for interested parties to participate in this important process. Following, please find responses to the questions raised in the consultation document on Licence Conditions and Codes of Practice.
The IGC has developed numerous Codes and Guidelines and has several representatives with experience in drafting remote gambling legislation in various jurisdictions. For general information attached is a copy of the IGC’s Regulation Position Statement. The IGC looks forward to further discussions and to working with the development of a regulatory model for the remote gambling industry. The IGC would welcome the opportunity to meet with the Commission and is committed to working with regulators and government to advance the common cause of industry and governments.
Please contact Mr. Rick Smith, Executive Director, at (604) 732-3833 or via email at with any questions or for additional information.
Sincerely
Rick Smith
Executive Director
Chapter 1
Q4. How should we strike the right balance between proper regulation of the remote sector and the danger of driving operators and customers away to sites outside Great Britain?
This is the most difficult question for regulating the remote sector, which differs from the land-based gambling sector in that the former can basically choose its regulator. The Commission is subject to the public policy of the government of the day plus identifying the end objective of a regulatory regime (to raise revenue or to provide a regulated alternative or perhaps both). The Commission should engage in candid, detailed discussions with representatives of the remote sector in regard to exactly how Commission rules and codes will be implemented, and how compliance can be achieved with minimal cost and disruption.
Flexibility is critical as is transparency and consistency. While the Commission needs to avoid being unduly burdensome, it must remain rigorous in its enforcement. The industry must also be regulated in an environment conducive to business and providing the ready ability for licensees to compete against businesses from less rigidly regulated jurisdictions. This may best be achieved through a balance of government oversight and industry selfregulation rather than overly prescriptive regulation. A balance needs to be achieved in consultation with industry. Jurisdictions such as Alderney, Malta, Isle of Man, Kahnawake and Antigua should be consulted as well as the likes of associations such as the IGC and eCOGRA to identify the best practical approach.
Chapter 2
Q6. Do you agree that those holding the roles of chief executive, finance director, chief compliance officer and marketing director should be required to hold personal management licences (PMLs)? What other roles, if any, should be restricted to personal management licence holders?
In summary, persons holding positions of responsibility consistent with land based regulation should be licensing accordingly. The IGC agrees with the above and would advise that some remote gambling operators are small companies whose job titles might not match those in land-based gambling or may spread across more than one business. PMLs should be required of all employees holding these job functions that can influence the integrity of the product or general business operation, even if their titles are different from above. Additionally, consideration should be given to requiring a PML for the person/s responsible for the chief technical function of a remote gambling operator. This person would likely have access to all of the operator’s passwords, customer accounts including credit card numbers, and gaming servers. The wrong type of person in this function could cause tremendous harm, and therefore should be required to hold an appropriate license issued by the Commission. Games software providers should also be licensed as with operators, or perhaps placed on an approved providers list. The software provider is an integral part of an online gaming operation and can affect the integrity and outcome of the game. Therefore appropriate probity / due diligence should be performed on these companies.
Q7. Do you agree that in larger operators, where responsibility for issues of regulatory interest is delegated, managers responsible for regions or areas or individual sites should be required to hold PMLs?
Yes.
Chapter 3
Q10. Do you have any comment on the way the Commission proposes to require compliance with our technical standards on gaming machines, remote gambling systems and bingo and casino equipment other than machines? (We will consult separately, in summer 2006, on the technical content of the standards).
We agree that the gaming servers (e.g. those where the game determination occurs) should be located in Great Britain. However, the Commission should ensure that the provisions in regard to the location of equipment are not unduly onerous and impede on the ancillary businesses such as marketing and payment processing (e.g. e-cash providers). This would place an unrealistic and unnecessary burden on operators, possibly even preventing efficient operation of their business. As an example in the financial industry, most all, if not all, processing for credit card transactions internationally occurs outside of the jurisdiction in which the “purchase” occurred. If the financial sector required equipment of the credit card companies to be located in the same jurisdiction as the transaction then the credit card industry could not function. Pending the development of the actual technical content of the standards, the Commission seems to be approaching this area in the right manner. A flexible regime to enable competition with less rigidly regulated businesses needs to be adopted, where the regime is not unduly onerous on the operator. We might advise that testing in the online environment is more controversial than testing in the real-world environment and that the Commission should be prepared for a rigorous debate over the proper methodologies. An example is. outcome based evaluations (per eCOGRA) versus traditional software checking versus checking only of “key modules” based on a risk based approach in which an element of recognition is afforded the quality assurance/s offered by the software companies).
Section 4.1: Financial robustness: general requirements
Q11. What indicators should the Commission use in assessing financial robustness of applicants for operating licences and for subsequent monitoring?
The IGC believes that online gambling should be subject to the same regulatory requirements as regulated land-based gambling organizations. This would include independent investigations of the backgrounds of key persons and owners, as well as assessing the financial capability of the company to carry on its operations in a competitive fashion and ensuring the security of player deposits. The regulatory infrastructure envisaged requires a cooperative approach between industry and government.
Q12. What other methods of financial assurance should we require from different types of operators?
The required financial assurances for traditional land-based casinos should apply to the remote gambling industry.
Q13. What specific financial underpinning should be required, if any, to secure the payout of sizeable winnings? Do you have any comment on our proposal to require the payout of winnings on demand and for notification of any failure to comply?
Payout of winnings on demand should be required, especially when appropriate age and identification regulations are satisfied upon player registration. Payments should be made in accordance with applicable financial regulations and credit card rules and only made to the player and deposited into that player’s account or mailed to that player’s confirmed address.
Q14. What would be an appropriate level for the cumulative prize liability below which we should rely on self-certification by small operators?
The IGC is a trade association focused on the interactive / remote gambling industry. We believe there would be more appropriate bodies to provide advice. One example could be the financial criteria established by the Queensland Office of Gaming Regulation in Australia (www.qogr.qld.gov.au) for interactive gaming licensees.
Q15. Do you have any other comment or suggestion on this section?
None.
Section 4.2: Protection of customer funds
Q16. What comment do you have on the proposal that customers’ funds held by operators must be ring-fenced from operators’ own funds? Do you have views on how best to make this proposal effective?
Ring fenced funds are appropriate to protect player deposits from creditors, etc. The establishment of trust account for player funds is a possible consideration.
Q17. Does this approach to the protection of customer funds pose any particular problem for operators? If so, do you have any suggestions for solving them?
Player protection is one of the most important components of an effective licensing and regulation framework. Remote operators should be required to have the financial stability to work within the framework of a regulatory system that requires protection of customer funds.
Q18. What would be an appropriate threshold below which the Commission should not require independent assurance of the effectiveness of the ring fence?
The IGC is a trade association focused on the interactive / remote gambling industry. We believe there would be more appropriate bodies to provide advice.
Q19. Do you have any other comment or suggestion on this section?
None.
Section 4.4: Cash handling
Q20. The Commission proposes that operators must draw up and implement documented procedures on cash handling to minimize the risk of theft, money-laundering and illicit credit and to monitor compliance with the ‘fair and open’ licensing objective. Is our proposal sufficiently specific to be effective? If not, what do you suggest?
This question is best answered as operators begin to implement procedures on cash handling, but compliance with the fair and open licensing objective is a good starting point for an evolving regulatory structure. Best practice methodologies should apply to ensure compliance by licensees with applicable anti-money laundering and countering terrorism funding criteria established by the likes of FATF.
Q21. What comment do you have on the proposal that operators must (subject to specific exceptions) bank customer cheques promptly, within two banking days, in order to prevent any delay which could give the customer illicit credit?
While it may be appropriate to require the prompt banking of customer checks, the Commission should also not forget about the international nature of the online gambling business and the resulting delays with regard to international checks, etc.
Q22. Do you have any other comment or suggestion on this section?
None.
Section 4.5: Money laundering
Q23. What comment do you have on the Commission’s proposal for code of practice provisions to reflect the duties on operators under money laundering laws?
Money laundering is defined in the draft EU 2nd Directive on Prevention of the Use of the Financial System for the Purpose of Money Laundering as:
•the conversion or transfer of property, knowing that such property is derived from criminal activity or from an act of participation in such activity, for the purpose of concealing or disguising the illicit origin of the property or assisting any person who is involved in the commission of such activity to evade the legal consequences of his action;
•the concealment or disguise of the true nature, source, location, disposition, movement, rights with respect to, or ownership of property, knowing that such property is derived from criminal activity or from an act of participation in such activity;
•the acquisition, possession or use of property, knowing, at the time of receipt, that such property was derived from criminal activity or from an act of participation in such activity;
•participation in, association to commit, attempts to commit and aiding, abetting, facilitating and counseling the commission of any of the actions mentioned in the foregoing paragraphs.
Online gambling does not lend itself to any form of cash movement because of the online nature of the business, specifically, there is no face-to-face contact in the business and financial institutions are used providing electronic tracking of transactions. Wire transfers, although subject to the banking system’s stringent wire rules initiated following September 11, 2001, are not generally used because they are not effective marketing payment options.
The Commission’s regulatory regime will likely mitigate any exposure. That being said, money laundering concerns are not and should not be treated as unique to remote gambling, e-commerce in general poses many complex issues with regard to global movement of funds. There may also be implications emanating from the U.S. Patriot Act and corresponding banks.
The IGC had a report drafted by NFC Global in which it concluded that there was no greater risk to the remote gambling industry in regard to money laundering, as there was for any other eCommerce business. The greatest potential weakness was in the financial transactions, a feature common to all businesses.
Q24. Do you agree that code provisions similar to those applying to non-remote casino operators should apply to all remote gaming? If not, what alternative approach do you propose?
A comprehensive regulatory infrastructure and compliance within the licensing jurisdiction similar to the regulatory philosophies that apply to leading land-based gambling jurisdictions is appropriate. Cooperation with the financial sector, and utilizing the strength of controls in that sector, is also important.
Q25. We propose code provisions for betting operators on arrangements for Suspicious Activity Reporting. Do you have any comment on this proposal? If you disagree, what alternative approach do you propose?
Technology will continue to provide the tools to identify suspicious transactions and the record keeping to account and report these transactions and suspicious transactions. The code provisions need to be flexible enough to allow for the usage of new technologies as they are developed. Reporting of suspicious transactions should be required in accordance with applicable financial oversight and reporting requirements for land based casinos.
Q26. Do you agree that, for other gambling operators, who are subject to the same general requirements as any other commercial or retail businesses in respect of anti-money laundering legislation, there is no need to apply any specific further requirement? If not, what requirements do you propose?
The IGC is a trade association focused on the interactive / remote gambling industry. We believe there would be more appropriate bodies to provide advice.
Q27. Do you have any other comment or suggestion on this section?
None.
Section 5.2: Access to gambling by children and young people
Q28. The Commission proposes licence conditions and code provisions on controlling access to premises subject to age restrictions. What comment do you have on the general approach and with the specific requirements proposed? If you disagree, what specific alternatives would you propose?
Blocking participation in gambling by minors is a key requirement, something best addressed by working with appropriately qualified bodies. The IGC is a trade association focused on the interactive / remote gambling industry. We believe there would be more appropriate bodies to provide advice.
Q29. What comment do you have on our proposals for licence conditions and code provisions to prevent underage gambling in premises open to children and young people?
The IGC is a trade association focused on the interactive / remote gambling industry. We believe there would be more appropriate bodies to provide advice.
Q30. The Act requires a code of practice on access to casino premises, with a special role for supervisors at each entrance or in the case of the regional casino, the gambling area. Do you have any comment on our proposed code?
The IGC is a trade association focused on the interactive / remote gambling industry. We believe there would be more appropriate bodies to provide advice.
Q31. We propose licence conditions and code provisions on preventing gambling using remote gambling facilities in breach of the statutory age restrictions. What comment do you have on the general approach and the specific requirements proposed? What alternatives do you advocate specifically?
License conditions and code provisions on preventing gambling by minors are appropriate as proposed. The IGC continues to take seriously the issue of preventing minors from gambling and urges all responsible remote gambling operators to ensure this does not occur.
To that end, the IGC supports that protection of children would be better accomplished through the UK provisions of licensing and regulation, specifically as proposed by the Commission.
Q32. Should there be any further controls on underage gambling, additional to those we propose?
The proposed controls are appropriate. Some jurisdictions require any funds involved with minors to be forfeited to a charitable fund. It will be important moving forward that requirements are altered to reflect updates to technology and available products / services. It is refreshing that the Commission understands that many tools, including data cross checks and age verification software, are currently available and continuously improving. The IGC contends that stringent computerized screening mechanisms implemented by remote gambling operators, and monitored by regulators, will be as effective as any measure in addressing this concern.
By way of reference, a copy of the IGC’s Responsible Gambling Guidelines can be found at https://igcouncil.org/aboutus_readmore.php?id=97 while a copy of the IGC’s Helping Hand program (aimed at providing general information, links to problem gambling service providers and possible blocking filters for use by adults) can be found at https://igcouncil.org/aboutus_readmore.php?id=251. These two documents are about to be reviewed by an expert in the field, Dr Jamie Wiebe.
Q33. Do you have any other comment or suggestion on this section?
None.
Section 5.3: Continuous and repetitive play
Q34. The Commission proposes licence conditions requiring operators to put in place policies and procedures aimed at preventing continuous and repetitive play. In addition, technical standards will contribute to the same objective. Is there more we should do in this area?
None.
Q35. Do you have any other comment or suggestion on this section?
None.
Section 5.4: Information on how to gamble responsibly and on help for problem Gamblers
Q36. The Commission proposes requirements on most sectors of the industry to ensure that operators provide appropriate information to customers about safe gambling and about sources of help in dealing with problem gambling. Are the general approach and the specific proposals right? Are there specific additional topics the information should cover?
The Commission has focused on the important issues surrounding safe gambling and sources for help with problem gambling. There should continue be consideration in the remote gambling industry of the international aspect of the gambling business. A global industry faces global problems which in turn need a global approach to resolution. International standards consistent across jurisdictions should be an ideal goal. The IGC has also drafted a Beginner Player Guide to try to provide advice to novice players – a copy can be found at https://igcouncil.org/aboutus_readmore.php?id=253.
Q37. Do you have any other comment or suggestion on this section?
As with other solutions / services for the industry, the IGC advocates global approaches in so far as is possible. A good example of this as it relates to problem gambling intervention and service redirection is the work of GamAid. The IGC has been a supporter of the efforts of GamAid and is happy to introduce Commission officials if needed.
Section 5.5: Intervention
Q38. The Commission proposes requirements to ensure appropriate intervention by certain operators in cases where problem gambling is suspected. Do you have any comments on our approach?
The IGC agrees with the Commission that gambling operators need to be responsible for appropriate intervention when problem gambling is suspected in so far as this is practically possible. The risk aspect also needs to be considered in attempting to be proactive. The specific requirements should continue to evolve with input from problem gambling experts.
Q39. Should other types of gambling operator such as pool betting operators, licensed family entertainment centres and lottery operators be required to intervene in cases where they suspect problem gambling?
The IGC is a trade association focused on the interactive / remote gambling industry. We believe there would be more appropriate bodies to provide advice.
Q40. How far is it feasible to use technology such as smart cards and loyalty systems to track, and intervene in, problem gambling behaviour? What behaviour would suggest problem gambling? To what extent is it possible to identify problem gambling in the remote gambling sector based on patterns of play?
The most appropriate response would be drafted by professionals that specifically deal with problem gambling behaviour.
Q41. Is it acceptable for the information gained from such systems to be used to identify cases of problem gambling, provided that this is made clear to customers when they first join the system?
The player information, while preventing inappropriate invasions of privacy, should be shared with professionals that are most experienced in fields such as counseling and problem gambling services. We also agree that remote gambling operators should provide employee training to assist in spotting problem gambling behaviors, again, in so far as is practically possible. Staff should not however be considered experts in this field.
Q42. We argue that operators should take into account information from third parties such as family members in cases where a possible problem gambler lacks the capacity to make adult decisions. However, we do not propose a formal requirement in this area. What is your view?
Given the very nature of third party information, it is best if operators utilize third party information only as a red flag, possibly requiring additional oversight of gambling activities. Third party exclusions was one of the considerations under the AUSModel but was also seen as a potential area for considerable problems. It may be something that is good in theory but very difficult to implement in practice.
Q43. Do you have any other comment or suggestion on this section?
None.
Section 5.6: Self-exclusion
Q44. The Commission proposes requirements on certain operators to operate self-exclusion schemes. Do you have any comment on our general approach? Is our proposed coverage (i.e. not including pubs, licensed or unlicensed family entertainment centres and lotteries) right?
Self exclusion schemes are appropriate, ideally aimed more at adopting a global solution (for global problems) rather than targeting narrow “fixes” at an operator level. A good example of a more global approach to self-exclusion is the project of the National Council on Problem Gambling in the U.S. in conjunction with a company called Aristotle with their Global Self-Exclusion Database (GSED). This is operator neutral and applies a philosophy that a player wishing to exclude themself should be banned from all sites and not just a particular operator, albeit a minimum requirement should be the ability for self-exclusion at an individual site. There are other companies, for example, age/identity verification service providers and payment processors who also have exclusion abilities linked to their core product/s.
Q45. Do you consider that the proposed minimum period of six months for self-exclusion is reasonable? If not, what alternative do you propose and why?
The best response would be drafted by problem gambling experts.
Q46. We propose a time limit of 14 days within which restrictions on marketing must be implemented after an individual has chosen self-exclusion. Is this reasonable and practical?
Marketing restrictions with regard to problem gamblers are appropriate. Remote gambling does pose additional marketing considerations based on affiliate marketing schemes, etc. The IGC believes that the operator must ultimately be responsible for the actions of third-party marketing companies acting on their behalf, especially in dealings with self-excluded consumers. Advice from experts in the field is recommended.
Q47. Do you have any other comment or suggestion on this section?
None.
Section 5.7: Employment of children and young persons
Q48. Operators must comply with the Act’s restrictions on the employment of children and young people on gambling premises. The Commission proposes code provisions indicating how operators must implement these restrictions. Are they sufficient?
The IGC agrees that minors should not be engaged in employment in the remote gambling industry. However, the IGC is a trade association focused on the interactive / remote gambling industry. We believe there would be more appropriate bodies to provide advice.
Q49. We consider that children and young people employed in remote gambling operations are not likely to be directly involved in providing facilities for gambling. Our tentative conclusion is that no additional guidance or code provisions are needed. We would particularly welcome views on this.
Young people should not be directly involved in providing facilities for gambling or providing gambling products or services linked directly to gambling.
Q50. Do you have any other comment or suggestion on this section?
None.
Section 5.8: Provision of credit by operators and the use of credit cards
Q51. What comment do you have on the Commission’s proposal to permit payment by credit card for certain types of operator, subject to a number of provisos? Do you support the proposed list of provisos?
Applicable financial requirements will need to be satisfied. The IGC is a trade association focused on the interactive / remote gambling industry. We believe there would be more appropriate bodies to provide advice.
Q52. To what extent do remote gambling operators currently offer credit to their customers? Is there a sufficient justification for allowing remote operators licensed by us to do so?
Responsible remote gambling jurisdictions do not permit licensees to offer credit to customers. If appropriately regulated, the remote gambling industry should be confined by the same restrictions of traditional casino operations.
Q53. Do you have any other comment or suggestion on this section?
None.
Section 5.9: Money lending between customers
Q54. What comment do you have on the proposal that operators should take steps to prevent systematic or organized money-lending between customers on their premises, including the exclusion from the premises of customers suspected of involvement?
Player collusion and money laundering are not subjects that should be accepted. As a trade association focused on the interactive / remote gambling industry, there would be more appropriate bodies to provide advice.
Q55. Do you have any other comment or suggestion on this section?
None.
Section 6
Q56. The Commission proposes to require all gambling operators to make available their terms of business to customers, to satisfy themselves that their terms do not breach the Unfair Contract Terms Act and the relevant regulations under the Act, and to be ready to give evidence that they have done so. Do you agree?
We strongly agree. The IGC believes in transparency.
Q57. Is our proposed list of issues to be covered in the information operators must make available to customers, together with the proposed requirements for making the information accessible, sufficient to secure the necessary openness?
Yes, although the Commission may wish to stipulate exactly how access to the information is to be provided e.g. posted on the home page, posted via a direct link from the home page, etc.
Q61. Should display of licensed status be required for internet website operators licensed by us? If so, is it important that customers should be notified when they are leaving a Commission-licensed site?
Yes, prominent display of such licensing status, and the link to the Gambling Commission, should be required. And yes, if a licensed site is redirecting customers to another gambling site that is not licensed by the Commission, customers must receive a prominent warning to that effect, and be required to acknowledge the warning.
Q64. Are there any games that you would like to be proscribed on Commission-licensed sites, terrestrial or remote? If so, why?
No.
Q66. Should remote operators retain the freedom to offer any games, subject to providing sufficient information about how to play, and subject to meeting technical standards and testing requirements for games software? Would this pose any threat to the licensing objectives?
We do not believe that the freedom to offer any games, subject to the conditions listed, would pose any threat subject to applicable rights to offer same. If in the future a new game did pose a threat, the Commission would be free to take action to take retrospective action.
Q67. We tentatively propose a code provision that if remote operators offer similarly named but different casino games they should identify any differences that may confuse players. Do you think that there is a real problem? Do you support our proposal?
Yes, we support your proposal. This can be a problem with proprietary table games such as Caribbean Stud. Some operators offer this game without paying royalties for its use, and some then proceed to alter the authorized and standard pay tables. Whether a game has the same name as a commonly used game or a different name, if the rules and/or pay tables are different, the site should clearly explain these differences to players. The same requirement should apply to play for free and play for money versions of the same game where differences exist.
Section 7
Q80. Do you agree with the principles of the advertising code that the Commission envisages? Is there anything you would add or remove?
We generally agree. We would add language similar to the following: “Advertising should not be false, misleading, or deceptive, particularly with regard to the chances of winning, and should be based on factually verifiable information and actual percentages.” Also, remote gambling licensees, and their affiliates, should be prohibited from sending spam email. We respectfully refer the Commission to the IGC’s Advertising Code of Practice, a copy of which can be found at https://igcouncil.org/aboutus_readmore.php?id=212.
Q81. Do you agree that adherence to the code by licensed operators should be required by a licence condition, to make it mandatory?
Yes. Additionally, the Commission needs to address the issue of affiliates, which are widely used by remote gambling operators. In some manner, the Commission must hold licensees responsible for the advertising practices of the affiliates that they engage in their behalf.
Q82. What do you think of the suggestion that gambling advertising should be required to include educational messages on responsible gambling?
While good in theory this may simply become “small print” that everyone will ignore, especially after widespread and repeated use.
Chapter 8
Q93. The Commission proposes to require operators to keep records of complaints and disputes and to put in place best practice procedures including an independent element. Do you have any comments?
We agree with the Commission’s proposal, and believe in the principle of independent third party dispute resolution.
Q94. Do you have any other comment or suggestion on this section?
The Commission might be interested in the Dispute Resolution project being finalized by Professor Rohan Miller on behalf of the IGC and looking at an industry best practice approach to this topic. Until recently, Professor Miller was an academic at the University of Sydney in Australia. Information can be provided upon request.
Section 9
Q95. Do you agree that it would be impractical and unnecessary to require accredited training qualifications for staff holding Commission licences? If not what do you propose should be required and why?
Yes.
Q96. What responsibility do you see us having in ensuring that staff we license are properly trained and kept up to date? And how should we discharge that responsibility?
We agree with your approach of encouraging the industry to complete a set of National Occupational Standards, and we would hope that such standards would include employee skills required for the remote gambling industry.
Q97. What should we do to encourage the development of nationally accredited standards both for technical and for social responsibility related training in the gambling field?
The standards for social responsibility are even more important than standards for technical competence. The Commission seems to be on the right course, especially in planning discussions with experts in the area of social responsibility training. With regard to both technical and social responsibility standards, the Commission might seek assistance from the academic world. More and more universities and colleges, in Great Britain as well as in Australia and North America, are offering curricula in topics such as casino management. We believe faculty at such institutions can be a source of independent expertise.
Section 11
Q114. The Commission proposes a straight forward licence condition that operators should give us full access. Do you agree?
We strongly agree. The Commission should have full access 24/7 to all operators’ premises, including gaming servers in the case of remote gambling. This is said taking into account that certain commercially sensitive items may not be accessible where proprietary issues dictate.
Q116. The Commission proposes a licence condition for all operators enabling us to require operators to provide information necessary for us to carry out our duties. Do you agree?
We strongly agree. The Commission should allow operators reasonable amounts of time to provide the necessary information but ultimately needs to satisfy itself as to the suitability and expertise of the operator.
Chapter 12
Q118. The Commission proposes public registers of operating, personal and premises licences. Could specific identifiers such as date of birth be added to the personal licence register without increasing the risk of fraud?
Applicable data protection and Privacy considerations will need to be satisfied albeit some risk may be necessary in the interest of transparency.
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