Last May, a meeting was held between the Kansspelautoriteit (Ksa) and the providers to improve the player files. The Ksa announced that almost all license holders of online gambling were present.
For the Ksa, a carefully compiled player file is an absolute priority in order to properly fulfil its task as a supervisor.
Why are player files essential?
Providers of online gambling maintain a file per player. This contains anonymous data on monetary transactions, gaming behavior and the registration of contact moments with the player. As part of its task, the Ksa may request these files.
This can occur if there are signals that a player is suffering large losses, for example. In the file, the Ksa can then check whether the provider was alerted to this and what steps were taken to intervene.
Various file investigations since October 2021
Since October 2021, the Ksa has conducted various file investigations at multiple providers. This allowed them to view a large number of files. This gives the Ksa a complete picture of how the providers function and where there may still be points for improvement.
The reason the Kansspelautoriteit has organised this conversation is because of the differences in how and what is recorded in the player file. The providers stated that they are aiming for more clarity and structure.
Five important points of attention
During the meeting with the providers, the Ksa shared five points of attention to improve player data. Improved recording leads to better substantive files, which strengthens the supervisor in its supervision and to protect the players.
The points for improvement and leading practices that were discussed were bundled and shared by the Kansspelautoriteit. The supervisor also added the questions and answers from the conversation.
These are the 5 points of attention:
1) Why was there intervention or analysis, or why not?
The Ksa sees opportunities to better explain why there has not been intervention or analysis in player files. It’s not always clear why a provider makes certain decisions.
The Ksa therefore cited an example:
“Player has gone from an average of 100 bets per week to an average of 300 bets per week in the first month since registration. Therefore, loss limit of 500 euros per month based on the customer’s income.”
But based on this example, it is not clear what the client’s income is and why a loss limit of 500 euros per month is appropriate. The supervisor would also like to know why the intervention has been made now? And why not earlier? The action may have been correct, but this must be more clearly reflected in the player file, which makes improved registration better for all parties.
Therefore, the cause and the reason for the intervention are essential. On the basis of which analysis was a specific intervention applied? In this way, it is always clear afterwards why there was a reaction in that way at that particular moment.
2) A Clear Communication
The Ksa has clarified that sometimes terms are used in these files that are not specific enough. Mentions such as “gaming behavior is ok” or “no red flags” are not sufficiently substantiated to make clear what has been reported.
The purpose of the Ksa is to be able to prevent differences in interpretation. For someone who looks at the file, it must be clearly formulated what the situation was at that time.
3) At what moment?
The Ksa notes that it is often unclear when analyses and actions take place. And what about the noted date? Sometimes it is equally unclear whether the date refers to the signal, the analysis or the action.
This makes it unclear how quickly a response was made in certain situations. That is why online casinos must always record the date and time with each note, so that a clear timeline of actions can be created in the player file afterwards.
4) By whom or which department?
Sometimes it can be the case that a player file clearly states that something has been done, but the reason behind the action is unclear. Interventions can be due to the anti-money laundering policy, responsible gaming, or both. If that’s not clear, you also do not know which department took action.
The Ksa therefore asks licensees to always state who or which department is responsible for an analysis or action. If multiple departments are working on the same file, the exchange of knowledge must also be clearly recorded.
5) Which steps have been undertaken?
Finally, the Kansspelautoriteit would like to draw attention to full insight into the intervention procedures in a player file. By noting down reference numbers from the systems used and recording the procedures in their policy, all steps can be checked afterwards if necessary.
Essential steps for a complete file
With these 5 steps, a complete file can be obtained with a total overview of analyses and interventions that have taken place and how they are connected. This creates a practical working model that benefits all parties.