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2017/18 Gambling Commission Business Plan Consultation

Published on April 11, 2017 by Darren @ Betting Gods

Betting Gods was recently invited to respond to the open consultation with the UK Gambling Commission (UKGC): http://www.gamblingcommission.gov.uk/about/Corporate-governance-and-business-plan/Business-plan.aspx and we are happy to offer our feedback.

As a company, we are strongly in favour of increasing regulation for the industry and improving communication with the UKGC and its key stakeholders. We are also keen on any future action that will help keep companies “safe, fair and free from crime”, especially in relation to the secure storage and transmission of data within the sector.

Overall, we would like to see a drive for clear communication and reformed regulation that brings security to the sector and works to “build and maintain consumer trust and confidence”.

Our specific, detailed response to the consultation is given below


1. Strategic priorities: what should the key priorities for the Commission be over the next three years? For example, this year’s priorities are to:

a) Empower and protect consumers
We would encourage research into the latest online security standards that could be recommended across all gambling sites, helping protect against cyber-crime. Betting Gods is also committed to providing regular educational blog articles to help inform customers about healthy, best-practice gaming. We work to ensure that all articles are built around gambling safely, responsibly and within an individual’s means and encourage anything that would prompt other sites to do the same.

b) Raise standards across all gambling sectors
Innovation brought on by data and technology has changed the face of the sector, while social media, online video streaming and e-learning has made it easier than ever to educate users and pass on knowledge. We recommend that the UKGC invests in online learning initiatives or formalised short courses for stakeholders. These can be built in collaboration with the community and moderated by the UKGC which can enable course-takers to increase and refresh their industry knowledge and learn best-practice technique.

c) Build partnerships and understanding
We would be keen to see an improvement in communication among stakeholders but, primarily, from the UKGC itself. Online communication makes it easier than ever for stakeholders to build a partnership with the institution and Betting Gods would encourage a concrete commitment for the UKGC to commit to this across the next three years.

d) Ensure fair play on the National Lottery
While not directly relevant to our company, we believe that fair-play and transparency are vitally important to the industry. Any learning taken from encouraging fair play on the lottery should ideally be shared by the UKGC among other stakeholders to help consolidate contemporary best-practice.

e) Improve regulation.
Betting Gods is fully onboard with discussing any forthcoming regulation as it is particularly relevant to our sector and how it has been changed in the online sphere. Our response is given directly below, but it cannot be overstated that changing client behaviour and industry practice means any regulation will absolutely need to reflect the new (and constantly evolving) landscape of the sector.


2. Regulatory approach/innovation: how can we encourage innovative ways of meeting the outcomes of keeping gambling safe, fair, and free from crime?

As a tipster site, we are strongly in favour of bringing in increased regulation for the industry, the addition of which can only be of benefit for stakeholders and consumers. We would be keen to see requirements that all individuals, businesses, companies, etc. who provide betting tips are asked to register formally (or apply for a licence) with the UKGC. Betting Gods has historically raised this need with the UKGC on multiple occasions but has yet to receive a response. Given the UKGC’s stated commitment that it wants to “start a conversation” around this topic, we feel that improving regulation is strongly in the customer’s best interest and we will continue to actively campaign for this.

Currently, Betting Gods actively seeks out validation from online review sites and customer reviews through sites such as TrustPilot to fully verify our legitimacy. We have worked to build the trust of our customers and empowering and protecting their interactions with us is of the utmost importance.


3. Industry approach to data and technology: how can we support the industry to ensure that data and technology is used to protect as well as promote?

We are strongly in favour of any reasonable steps that will need to be undertaken in the next three years to help with the secure storage and transmission of data within the wider gambling industry. In such a rapidly changing marketplace, agreeing on a regularly reviewed set of shared technical standard and ensuring that the best sites are compliant would be invaluable.


4. Commission approach to data and technology: are there ways in which we should improve how we collect, use, or apply data? How can we do more to harness technology for regulatory purposes?

Our main observation is that some regulatory information could potentially pose a risk of leaks or hacks, which could compromise sensitive customer information. The rise in recent leaks means it is important for the UKGC to ensure that research is carried out into the latest encryption methods, determining what key information is required from the stakeholder and working to make sure the customer knows that their sensitive data is as safe as possible. Cyber-crime is a huge risk to the sector and a review of best-practice ways to non-intrusively harvest and access this data would be invaluable.


5. Over the next three years, what should we do more of, stop doing or start doing in order to have the greatest impact?

We believe that the UKGC should continue their commitment to promote responsible gambling with consumers. But, to do this effectively, they should make an increased effort to make themselves more accessible to stakeholders. We believe that consultations such as this are invaluable and we would be keen to see a marked commitment towards building a genuine partnership with companies of all sizes. This will help keep stakeholders and customers informed about the latest standards and encourage discussion and compliance in a rapidly changing marketplace.

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