Introduced changes
Last December 13th ADM’s Remote Gambling Office published a new version of the communication protocol of Gambling Account Registry, which introduces new messages regarding some responsible gambling parameters. The new version is coded 2.0. The name of the protocol has been changed from PGAD to PACG. The new version is available to licensees in staging environment since December 18th 2017 and will be made available in production starting from February 13th 2018. The mandatory adoption deadline has not been defined yet.
PACG version 2.0 adopts following new messages:
• 4.22 Gambling account limit update
• 4.23 Limits of gambling account query
• 4.24 Management of transversal self-exclusion
• 4.25 List of self-excluded accounts
• 4.26 Open physical person gambling account 2 (it substitutes message 4.1 Open physical person gambling account)
• 4.27 Open simplified physical person gambling account 2 (it substitutes message 4.16 Open simplified physical person gambling account)
• 4.28 Integration of opening simplified physical person gambling account 2 (it substitutes 4.17 Integration of opening simplified physical person gambling account 2)
Messages 4.22 and 4.23 introduce the acquisition and management of player deposit limits by ADM’s Gambling Account Registry. Players registration is anyway mandatorily subdued to player’s choice of deposit limits since introduction of Player Accounts Registry in 2011.
Messages 4.24 and 4.25 extend to all Italian remote public gambling licensees self-exclusion required by player to any single licensee.
Messages 4.26, 4.27 and 4.28 transpose changes consequent to deposit limits and self-exclusion messages to player registration ones. The introduction of new messages regarding simplified registration must not be interpreted as having passed the sieve placed to it by AML legislation renewed by legislative decree 80/2017, which must be intended still in progress by ADM.
Changes introduced by PACG 2.0 refer in conclusion exclusively to measures aiming to strengthen player protection against problem gambling.
Publication of circular notice and of its attached protocol document raised interpretative doubts and application problems among licensees, which make useful some supplementary analysis and also possible introduction of adjustments. Present article contributes to interpretation and identifies some open issues proposing possible solution.
New messages for acquisition and management of deposit limits
Introduction of messages 4.22 and 4.23 provides obligation to send information regarding deposit limits to the ADM’s system.
Circular notice specifies three allowed time periods: day, week and month, which coincide with those currently adopted by licensees. However, guidelines for certification in force state mandatory adoption of at least one limit “which time period must be not less than a week”. The protocol seems consequently in contradiction with guidelines because it allows to adopt the daily limit only. Taking into account that a daily limit is, necessarily, also a weekly limit (equal to seven time the amount of the former one) we think it make sense to actually remove that current guideline’s restriction. In the event ADM want instead to keep the obligation to adopt at least one limit which time period is at least a week, we think it could be avoided to request to communicate the daily limit (or, more in general, any limit which time period is less than one week) by 4.22 message.
Provision reports also method for calculation of each time period: daily period from midnight to midnight; weekly period from Monday to Sunday; monthly period coinciding with the calendar month. That method is actually adopted by some Italian providers and licensees, but practice internationally adopted in the industry calculates weekly period as seven days that can start from midweek and adopts thirty days period not monthly calendar one. It does not seems reasonable to compel international operators to modify their systems, which serve all international markets using the same sw and, consequently, the same rule. We think it should be allowed by ADM to adopt alternatively both calculation methods.
Transversal self-exclusion
This change introduces a relevant new responsible gambling measure. Self-exclusion decision expressed by player on any site of a single licensee must be communicated to the Gambling Account Register that transversally imposes its application to all licensees – without prejudice to player’s withdrawal right – through the refusal of sub-registration message con-validation.
That hoped and expected measure lets to value the specificity of the Italian model which, unique in the world, provides real time dialogue between the licensee system and the ADM’s one. Provision adopted by new protocol publication leaves anyway pending some issues, which require clarification.
The circular notice provides communication of indefinite self-exclusion that can be revoked by the player not before 6 months (as already stated) and three specific time periods for temporary self-exclusion, i.e.: 30 days, 60 days and 90 days. Previously length of time periods for temporary self-exclusion were instead not stated by ADM and were freely defined by licensees.
With reference to the indefinite self-exclusion we understand from the circular notice that ADM imposes now to all gambling accounts a 7-days-long delay before reactivation of gambling account – i.e. before player will be enabled to play – behind the date of player’s revoke and licensee’s approval.
Circular notice states gambling account “self-excluded” can contemporarily be either in the active status or in the suspended or in the blocked one. Consequently we understand the ADM’s system does not interpreters self-exclusion as a status of the gambling account and it manages instead that as a different parameter, orthogonal toward the status one. Therefore licensee communicates execution of player self-exclusion by new 4.24 message but will not send a 4.5 – Change of status message, unlike what – we think – is generally now sent by licensee to take the account in the suspended status in the ADM’s system.
The concerned licensee will use the message 2.24 to communicate both the self-exclusion activation and its termination, at the end of the pre-defined time period for the temporary self-exclusion or after player’s revoke request and licensee’s approval for the indefinite self-exclusion.
Licensee will be able to integrate the list of transversal self-excluded players using message 2.25. It is relevant to notice licensee will be compelled to adopt a specific procedure to frequently update the list of self-excluded players, to be able to act in compliance with prohibition to send to self-excluded players promotional mailing and communication. It could be useful ADM will clarify how that obligation should be accomplished.
Circular notice provides “licensee can execute transversal self-exclusion only for Physical Persons that hold or held in the past an account with”. We would expect that players, in order to self-exclude, must be identified by login or at least on the phone as the owner of a gambling account and, consequently, they must hold a non-terminated gambling account. It puzzles us players can request to transversally self-exclude to a licensee which they held an account with in the past now terminated. We assume the above-reported statement identifies licensees which are enabled not only to accept the transversal self-exclusion request but also its revoke. About the latter case it could be a licensee which “player held” an account with in the past subsequently terminated or, better, which player held an account with at the moment they submit self-exclusion request (to that licensee or to another one). We notice that licensee in accordance with certification guidelines must have a “special identification procedure” by which it should check if there are elements which advise against self-exclusion removal. We find consequently advisable self-exclusion revoke must be executed only by a licensee which held a gambling account with the player before self-exclusion and holds consequently some elements to evaluate player gambling behaviour.
It seems no doubt licensee can exclude players on its own initiative, if they show a problem gambling behaviour, though this reason is not expressed in the player gambling account agreement recalled from paragraph 2.4.5 (Enforced exclusion by licensee) of certification guidelines among reasons for exclusion from gambling. This is anyway an “exclusion” not a “self-exclusion”. We assume that in the event licensee excludes player on its own initiative it is not a transversal exclusion and message 4.24 must not be sent. It consequently becomes necessary to send a 4.5 message, to move gambling account from active status to suspended one.
We understand non-transversal self-exclusion (i.e. limited to the licensee which collect the request only) is not provided by circular notice. However, that states constraints regarding the allowed self-exclusion time periods, which are equal to 30 days, 60 days and 90 days while till now some licensees provided also different time periods, both longer than 90 days and shorter than 30 days. We think ADM should take into consideration the opportunity to adopt one or more further periods over 90 days, for example 120 days.
We further think licensee should be allowed to adopt “non-transversal” self-exclusion, referred to the site on which self-exclusion is requested or even with reference to a single game, for time period shorter that 30 days. Availability of short self-exclusion periods, for example 7 days or even 24H, is useful for the player, though they serve a different purpose in comparison with longer self-exclusion durations. In the former case players do not intend to stop to play. They intend instead to take a pause, for example to protect themselves from a phase in which they lost lucidity and self-control (in poker they say “she/he tilted”). In this case we think licensee should send 4.5 message to move account from active to suspended status.
It does not seems to us instead a relevant limitation to make unavailable to player non-transversal self-exclusion for time periods equal to 30 days or more with reference to unlikely possible reasons different from protection from problem gambling.
Mandatory activation of new messages
As already noticed mandatory activation deadline is not defined yet. Furthermore, circular notice does not expressly clarify if transmission obligations of deposit limits and of self-exclusion refers also to requests executed before mandatory activation of new messages. We understand that is anyway ADM’s willing. Therefore, if that will be confirmed, licensee will have to send a batch of PACG messages for communication of deposit limits and of possible self-exclusions regarding any player which holds an account in active, suspended blocked or (in this case also) closed status.
Conclusion
This article provides interpretations and suggestions for the adoption of some adjustments in recent changes of protocol that raised doubts among operators. That is not anyway sufficient to surrogate a further ADM’s intervention, aiming to let licensees to introduce needed changes of their systems.
