Responsible Gaming for online Gaming

This is a transcript of the Responsible Gaming for Online Gaming panel discussion that aired during the SiGMA Americas Virtual Summit on September 13, 2021.

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SETH PALANSKY: Thank you everyone for joining us today for an exciting webinar on responsible gaming for the online gaming industry. We have an esteemed group of panelists here today to help answer some key questions throughout the industry, and we hope you find it insightful. Before we get to the questions, I'd like to introduce our panelists. Let's turn it over to Liz to introduce herself first.

ELIZABETH LANZA: Thanks, Seth. I'm Liz Lanza, and I am the director of the Office of Compulsive and Problem Gambling for the Pennsylvania Gaming Control Board.

LAURA MCALLISTER COX: Hi, everyone. I'm Laura McAlister Cox. I'm chief compliance officer for Rush Street Interactive.

STEWART GROUMOUTIS: I'm Stewart Groumoutis. I'm the director of eGaming operations with the British Columbia Lottery Corporation (BCLC).

SETH PALANSKY: Great, thank you. As you can tell, we have a couple of operators with us and Stewart sort of sits in that middle as a government regulated entity that's operating in his jurisdiction. And Liz represents the regulator side, so we have good voices here to contribute to this discussion all around. And we're going to start by asking all three panelists this question: Do you think it's the right approach to have a separate self-exclusion program run for just online gaming? There's been talk about some jurisdictions that prohibit players from participating in all forms of gambling, land-based, online, lottery, whatever the case, and others that you can exclude just for the activity in question. We're on online gambling in this panel today. Liz, let's start with you since your state, I think, does it separate by category. Can you explain if you think that's the right approach?

ELIZABETH LANZA: Sure. In Pennsylvania, the way our gaming act was written, we had to silo the different self-exclusion programs. In the beginning, I was really pushing for one list. We have four in Pennsylvania, and I was pushing for one list for i-gaming and casino self-exclusion. I was told that it can't be done the way our law was set up. And, you know, now that we have it separate, I can definitely see that there are pros to having it separate, it's definitely, depending on the person, it can be a completely different experience. We do have individuals who want to be able to continue to wager at a casino, they perhaps don't live close to one of our casinos. They may go once or twice a year and enjoy that. But they're not able to gamble responsibly when it comes to i-gaming.

You know, I can see pros and cons to both—where it's a con it can get a little confusing to the people enrolling in the program. Some people may say, you know, I just want to enroll in one time and be done with it. The way we created our enrollment process, people can do one enrollment for all the lists. We kind of had it like a one-stop shop when it comes to enrolling and self-exclusion. And I think that's an important way to go. But yeah, there's definitely pros and cons to having them together and having them separate.

SETH PALANSKY: Very good. Thank you, Liz. Laura, I'll come to you. I've spoken to operators who have said, look the accessibility of online, you can understand why you want to have self-exclusion specifically for that. But some of those patrons want to go to a casino—maybe they're there to see a show, or maybe they're there to dine—and to be excluded from that makes them not want to sign up for self-exclusion. If it's all bunched together, what's your sense of how self-exclusion should be managed?

LAURA MCALLISTER COX: It is challenging for the operators in the current environment. As Liz was saying, Pennsylvania has multiple self-exclusion lists. Pretty much there's no one size fits all as we go around the country, which for us as operators as we add on jurisdictions, then we have to customize to fit whatever the scenario is required there. Quite frankly, I think giving patrons choices, and clear choices, to determine how they want to utilize these tools is important. And right now with multiple exclusion lists, as was indicated, it's confusing for the player, right? They're making a decision here. We shouldn't look for ways to make that more difficult. I say that the basis for the foundation of this decision is tough enough.

So how can we make that experience for that player who wants to do something affirmative, more clear and easier to pursue with the separate self-exclusion list? I can understand the player who says, “You know what, at home, I got to turn it off. But I want to be able to go out with my friends, I want to be able to go to dinner at the casino.” Quite frankly, maybe they even want to wager with their friends at the casino in a more controlled environment where it's not constantly in their face 24/7, we understand that—we're willing to work with whatever tools we're given. But for a lot of reasons that I'll share—we'll go into those—standardizing this process a little bit more, streamlining it for the players, I think can help us reach our goals, better than a little bit of the ad hoc approach that we're seeing across the country now.

SETH PALANSKY: Very good. Thank you. And you're teasing our next question very, very well, but first, I'll go to Stewart to weigh in on this question. You've been operating in the jurisdiction longer than most, what's your sense? How's it done in BC? And do you feel the separated approach makes sense or not?

STEWART GROUMOUTIS: We have it linked, the only limitation we have is if you register for our voluntary self-exclusion program online, that doesn't transfer to the land-based. And that's because their inability to get a picture of the player through facial recognition, those types of steps, we're looking to see if we can solve that. We're also moving to a view of our customers, which we call Player 360, which is all data that we have on our customers all linked together, which I think is extremely important. Regardless of the list, I think having a single view of a customer allows you to recognize your gambling behaviors and recognize problematic gambling. I do think there's a lot of value in having a single view of customer.

But I'll go back to what Laura said, I think given the players, the choice is the most important thing, because there's some customers that play online with us that just want access to lottery products, and just want to block the casino and sports products or, you know, so giving the players the ability to customize what they want to block when they want to block it. And again, back to something worse, they're already in the midst of an extremely difficult decision. They're already at a point of contention in their own mind of do I do it? Do I not do it? They're fighting their inner demons, and for us to put up roadblocks, it's just the absolute worst thing we could do in that space. I think it's about choice. It's about clear choice. But I do think the power, the data, of being able to recognize a customer from online to offline is extremely powerful.

SETH PALANSKY: Well, very good point. Thank you, Stewart. Let's talk about modernization and standardization. It does seem like a lot of decisions around responsible gaming are taken from what has been done previously in land-based. For example, some states still require the printing of self-exclusion forums, going to get them notarized, mailing them back in, waiting for a response before you enter the program. And some states in the U.S. have adopted this format, even for online, right? But Liz's state, for example, offers a simple online and KYC [know your customer] approach. Is there a right approach? Should we be offering a buffer for all? Should we be looking at online gaming differently? If they can register and play online and by going through an online process, should they be able to self-exclude that way? How is it best looked at, and how should it be managed, specifically for online? Liz, let's go to you again first, based on what you've chosen to do there.

ELIZABETH LANZA: Sure. Prior to 2017, when the new gaming act was passed to allow for i-gaming and all the new gaming venues in Pennsylvania, our self-exclusion was enrollment in person only. And we kept it that way. We always discussed having an online enrollment, but we kept it in person only, for so long, because we really saw the benefit of that human interaction with people being able to provide information directly, you know, from one person to the next on treatment, and things like that. And it was a benefit, and it helped an individual have that personal contact with somebody else who is and was trained in problem gambling and things like that.

But then with i-gaming and this whole new world of online, you know, we have to give these people an option. You know, you can gamble from anywhere, so you should be able to technically self-exclude from anywhere. Now, once our offices are back open because of the pandemic, we will continue to allow people to come in to do the self-exclusion enrollments, if they choose, in office, so they can have that option. Unfortunately, right now with the pandemic, it's all online enrollments. But we do have an employee who will talk on the phone with individuals enrolling and help them through the process. We just don't want to give up that human contact piece of it. We're always there, we're always willing to, at least on the phone, speak with individuals. And again, once our offices are back open, we will allow for individuals to make appointments again, to come in to do the enrollment process in person. And really with the younger population who wants nothing to do with that, they'll do everything online, and be done with it. And then you see the older population saying, “You know what, I need to know exactly what I'm getting into and want to talk to somebody about it, I want to know exactly what this means.” I think it's important to have a mix of both.

SETH PALANSKY: Very good, thank you. Kind of what Laura was saying earlier, it also seems like categories matter, like sports betting is new and evolving in the U.S. and tends to attract a younger, male demographic in a lot of cases. And that's the only game they play. And they may be fully comfortable with doing it online. But there's different customers for different products who need different tools. The options, as Laura mentioned earlier, seem to make sense. Stewart, again, with the history you have in that market—anything you can glean on how to modernize and standardize some of this?

STEWART GROUMOUTIS: Yeah, I think again, it's about giving people the options to how they want to engage. It's about giving the different options, if you want to do it online, that you provide that option. I think the other benefit of online that I would point to is you have the ability to have shorter-term lock ups that are not your typical VS windows, typical VSU windows are going to be six months or beyond, just because of the oversight of ensuring that you're keeping people compliant. If you have people locking themselves out for one week from a land-based casino, it'd be quite problematic. Online you can add those options. And I think it's very important to have those short-term lockups that are precursors to a potential VSC. But at the same time, it could just be they recognize they need to save money over the next month for something, a specific purchase, or something along those lines.

I would also speak to the personal contact. So it's one of the things that we recognize is when people are gambling in their home, we have no idea of their environment, their current state, we have all those difficulties. And on top of that, you also have a person that could be going through a challenging situation, and feeling very alone depending on their living situation, depending on where they're gambling. And that can be very problematic. Over the past year, during the pandemic, we actually implemented our GameSense advisors, which are player-health trained advisors on PlayNow, which is our online platform. And customers can reach them not just through the phone, but they can reach them through chat as well. When customers just want to go on and have a little bit of a more passive interaction with these games and have advisors, they can do that. And I think that hits on what Liz said, it's just you have to make sure people have the support they need. It's not just a program of checkboxes and making sure you lock them out of whatever gambling they want to be locked out of. It's what happens after that as well. How do you support them ongoing? When the VSC expires, what are you doing to help them re-enter safely and in a healthy fashion? I think that all plays a massive part of it.

SETH PALANSKY: Very, very well said, good point, Stewart, and that it shows online is a different offering and something that we have to think about differently if we're going to be successful. Laura, what would you like to add on this point?

LAURA MCALLISTER COX: Well, to me, again, it's about choices and options. And the more that are available to address the situation, the better for the patron who needs help, right? The idea of having the options they can just do it online, they can place a phone call, they can do an online chat, I think helps reach the broad demographic that we're seeing online, as you said, sports betting patrons skew male and younger. We [Rush Street Interactive] also have an i-gaming platform and we're live in a number of states. And we see generally the tendency there is more 50:50 with females and of an older age demographic, and the sports wagering patron we're seeing is a broad base of the population, you know, entertaining themselves with our platform. But when they need that reach out, whatever is comfortable for that person should be an option. As for that face-to-face or in-person phone contact with the regulators, I'm a big fan.

And here and there, I guess in this conversation I'll do a little compare and contrast of different approaches and different jurisdictions in the U.S. But New York State where there are commercial casinos, tribal casinos, racinos, racetracks, DFS [daily fantasy sports], pretty wide selection of gaming channels. For a commercial operator, that casino has to register people for self-exclusion in the casino. It is the state gaming commission that is doing that—put that burden on the casino itself. And yeah, I would imagine that could be troubling for somebody who is delving into this. I want to speak to someone, and see someone, and fill out the paperwork, but I have to go into the casino to do that. You know, there are different ways to approach it. Again, compare and contrast, you know, what is offered, say, in Pennsylvania, where that contact is through the Pennsylvania Gaming Control Board, or as Stewart was saying, in British Columbia, you've got trained folks that are available to help folks with these choices.

So, although I think this is a partnership between all of us—regulators, operators, mental health professionals, I mean, there's so many stakeholders that go into addressing this—but is now a time to modernize that approach? Maybe make that approach more consistent for the good of those patrons reaching out. I'm a definite proponent of that. And by the way, if we haven't learned anything else in the past 15 months, it's that we can change quickly, we can adapt, we can find new ways, better ways to use technology to address a situation we didn't anticipate with COVID. This may very well be the time to embrace a different approach.

SETH PALANSKY: Stewart, I want to go to you and talk about the culture and emphasis on responsible gaming because BCLC, if I'm correct, was the first to launch the GameSense program and is renowned for that, and you seem to have a culture there that really emphasizes responsible gaming. Can you talk about the organization there and how it instills that in the team and how it can be effective for others to look to what you're doing?

STEWART GROUMOUTIS: Yeah, I mean, I go back to what Liz said. I mean, at BCLC, we've had a Responsible Gambling team since I got here 10 years ago. They've done a great job of what I would say transitioning from responsible gambling to player health, recognizing that all levels of player health are not just, you know, people becoming addicted to the products. There are other aspects to player health. And as an organization, we have three pillars, and one of those pillars is responsible growth. We don't want to focus just on the revenue, we want to focus on how are we obtaining that revenue, and one of the objectives under that is to gain no revenue from unhealthy play.

And what I would say over the last five years, what I've seen at BCLC, is it's become less of a stage gate, it's become less of, you know, a checkbox or a necessary evil that you need to put every game and every promotion through, you know, a review to make sure that it's on point and it's not going to cause players any issues. It's become that much more embedded. And we have people like myself who, in my position, at the end of the day, my position is to generate revenue off of the PlayNow platform. But I'm just as engaged in player health as the people on the Player Health team. And they've done a great job of embedding it in the culture, making sure that everybody understands when you show up and say, we need to stop doing x and y, and it's going to impact the revenue, but it's the right thing for the customer that you don't feel any fear in bringing that forward. That has to be a part of the culture at BCLC. We have achieved that culture where we always put the player health lens on everything we do.

SETH PALANSKY: Very good. Thank you. Yeah, that's great. Great to know the alignment there on the operator side as well. Laura, I want to come to you. I'm back to self-exclusion a bit and the difficulty of managing a self-exclusion program. It seems hard from an operator's perspective. And if there was a centralized system in the U.S. for i-gaming, would that be appealing to you? Because I've heard from operators who expect difficulties around the different data that they get from each state and the fuzzy logic and not always knowing who the person is and the methods for retrieving it and trying to get it uploaded into your system to prevent that. Would it be beneficial from an administration standpoint for an operator if it could become automated and standardized, and maybe lean into a little bit of the problems that exist there?

LAURA MCALLISTER COX: Yeah. I think I want to start out with the need for consistency, and this is going to hit a lot of categories, consistency in what information is being taken in about the player. We've had situations in another arm of Rush Street Gaming, which operates a few casinos in the country. And some, again, compare and contrast that we see what information was put in about that person's name—Is it Matt Jones, or Matthew Jones? Are they going to pick up and match, right? Or do we have, as we call it first, the matches, you used the term “fuzzy.” We need consistency in what information is being gathered, we need consistency on the time frames that are being offered to players.

For self-exclusion, those vary in every state. We need consistency in what method the player needs to follow to get removed from a self-exclusion list, some expire at the end of their term, some require the player to take an affirmative step and file a petition or request a gaming board to come off. That is something that some consistency from an office operator standpoint would help because we don't know when they come off, there's no way to predict because they'll contact us and say, okay, my three years is up, I'm ready to play. But perhaps it's a state that requires them to take an affirmative step with the regulator before they come off.

Consistency in life limits, right? We have to offer a cool-off period on our platform. We offer the ability to limit your deposits, the amount of money wagered in a day, a week, a month, how often you can withdraw, how much time you're playing, etc. So, lots of tools there. I think a consistent process with those things being available across the board, you know, would be helpful.

The other piece of this, where would an online database solve this problem, potentially, is how do we get the information? In a number of jurisdictions, we are tethered to a casino license partner. And that particular state agency may have a policy that a self-exclusion list only goes to the casino. And then the casino people are manually inputting the new names onto the list. And then it goes through their casino management system and integrates over to us. We now pick that up, we have seen situations where human error on both sides of the casino, and on the side of the regulator, the data that's been inputted has something wrong, there's a typo, information doesn't match. I think a system, whereas even if it's just for each state, and then hopefully, eventually some central database where that list can come directly to us. There's no reliance on some manual input in between.

Also, it would help us to know when something's effective. Now we're dependent on when the casino gets that input, and it goes through the system and comes to us, we need more direct integration of the information to make this truly work better. The idea, the concept of a central system for online gambling throughout the state, throughout the U.S. is a tempting concept. And Liz and I have talked about this on other occasions. It's not as easy as it sounds, to have a one size fits all because even as Liz's in Pennsylvania, she's got multiple laws that govern multiple lists. So how do we get all of those states talking to integrate into a central system? I think is a discussion point we in the industry have been having for a while. I'm not real sure how that's progressing at this point, but I think it is a topic we need to continue to talk about and look at.

And then crossing borders, right, as now we know, for us, we're looking at the Ontario market which is going to be opening up for i-gaming and looking at opportunities that we're going to be seeing through Canada, also operations in South America. I mean, remember problem gambling has no borders and so right now, the fact that things are different state to state—I don't know that is fundamentally getting to the problem, right? I think it's just putting a fence up, but maybe creating an unintended arbitrary result from that.

So I think that there is potential, if all of the legal issues, regulatory issues, data privacy issues, could be resolved to have sort of a central database. Maybe we're going to get there, but I know those are things that you, Seth, and you, Liz, can talk about from different perspectives and looking for solutions along the way to build some consensus.

SETH PALANSKY: Yea, very good, you raise a lot of points and a lot of issues and a lot of friction. And I think it's important, we all take a step back and go to what you guys have echoed throughout this discussion: we need to focus on the consumer and what's best for the consumer and giving them choices. And some of this is quite difficult for them to wrap their heads around. And to your point, the problem is not solved inside one border. Liz, maybe to ask you, how feasible would it be for different state regulators to work together on something like this? I know you've joined the PlayPause program. I can explain that a little bit after, but a multi-jurisdictional approach. Are there discussions amongst regulators? Should there be? How big a proponent are you of say a self-exclusion system built for the entire industry?

ELIZABETH LANZA: I think it's a great idea. I've been in multiple discussions with multiple other jurisdictions, other regulators, operators, on how to move forward on a nationwide self-exclusion program, and like Laura said, it is going to be hard, it is going to be difficult with all of the different regulations and the different laws. Like Pennsylvania may have an arrest policy where that state doesn't, and things like that. But like Laura said earlier, we're in times now, where things are changing, things are moving, and we have to adapt and adapt quickly. And I think that as long as we keep moving forward in discussions, I think that it is something that can be done, and it is something that is possible, in some form or another.

When Conscious Gaming brought the PlayPause program to Pennsylvania and introduced us to it, I thought, okay, at the extremely, very least, this could be beginning steps towards something like that. And I just think having a tool that can allow people to say, you know what, I want to make that step of self-excluding myself from multiple jurisdictions—having a tool in place like PlayPause is something that can empower the consumer, empower the person in their journey, in this world of addiction, and I think it can be done and I think it will be difficult. And we're just still in those discussions of how we can work all the policies, or none of the policies and have just a very generalized type of self-exclusion. But yeah, it's in discussions, we've been in discussions for many years with other groups and jurisdictions, and most people, most other jurisdictions and regulators and operators ,would like to move forward on something, especially in the i-gaming world that makes it a little bit different or a little bit easier.

In the self-exclusion atmosphere of taking it across the border, and I think it's definitely the way of the future, I think we're going to see us moving closer and closer to a more nationwide type of self-exclusion. It's just how? We're at that phase—what will benefit the person who's enrolling better and how we can do that as regulators? How can we get that information to operators and things like that? We're not there yet, but I feel like in the next few years we're definitely going to be moving in that direction.

SETH PALANSKY: Very good, and for i-gaming, particularly, it seems like there's a way to solve it when we talk about knowing your customer and all this sort of thing. I will say, you know, selfishly I've been with Conscious Gaming less than a year, I had hair when I started so I know how quickly and how difficult this issue is, but I can tell you PlayPause does believe it has a solution that can help fill a lot of these gaps with technology.

There's really two key points that we're focused on bringing to the industry and that's really a global unique player identifier way that all of us are dealing with the same player. And we solve all those fuzzy logic and issues around the Matthew/Matt, and all those sorts of things, and we believe we have a clever solution to that. And the other piece is trying to keep each database holder, each jurisdiction, in control of the rules they want to set, but still allow the information sharing to occur. It would be great to some of the points Laura made, of getting standardization around the term lengths that each consumer should use and how to come on and off less and all those things. And that takes us into the next discussion and getting comfort around those sorts of things. But there does seems to be a way now, technology-wise, for i-gaming to solve both database/data privacy, all those kinds of concerns, and knowing the right customer. So hopefully, we're moving in the right direction, so, Laura, maybe to you on what should a good responsible gaming program entail? For an operator perspective? What types of tools or safety measures should be available to players? Let's focus on the online market.

LAURA MCALLISTER COX: Sure. Well, look, first off in an organization, it starts at the top with the culture, right? To Stewart's point, the culture, the commitment to social responsibility, and responsible gaming awareness, education, and provision of the right tools is the beginning. Then it goes to the rest of the organization, right? That's where you pick up the team member, team member education, the reinforcement programs, the awareness, support within the organization so it's clear that that message is there. And that the balance of the revenue generation and responsible gaming commitment are not diametrically opposed at all, they're actually blended together. We don't want someone with a gambling problem wagering on our site, period! You're going to hear that from every operator. That's not what this is about. In the regulated environment, we take this very, very seriously.

Next is collaboration, the collaboration on many levels starting within the organization. In our organization we involve various departments in our discussions about how we want to approach responsible gambling, and whether it is our engineers, our product developers, our marketing team, our compliance team, our customer service reps, or VIP department, everybody is a part of that conversation. And they are not only comfortable speaking about it, but want to speak about it, because we're all bound together to do the right thing. You make the right cultural choice, you educate, you make folks aware, you collaborate—then what does the player see with this foundation? They're going to see tools like you can go onto your account, you can set up your limits, you can set up how you want to play, how much you want to play, when you want to cool off, the self-exclusion programs are available, and it links to the appropriate regulators as to how to pursue those options and make sure those things are available. And quite frankly, to participate in discussions just like this.

SETH PALANSKY: Very good. Thank you. Okay, I think we should wrap up our discussion here. We've gotten a lot of time. I want to thank each of you for being here today and sharing this information. This is exactly what can be very helpful to others as they look to get into this business, or from where they sit in the industry, sharing stories, working together, collaborating, as this new i-gaming really takes hold in North America. Thank you, Liz, Laura, and Stewart for your time today and for SiGMA for giving us the platform to discuss it. Take care.