Im also wondering what all this Gamprotect trial is going to do as well it looks like its gonna get even worse....
This is just a bit of the GamProtect trial.............
Single Customer View
Single Customer View, Trial 1, is a project to ensure that people who display high-risk behaviours are protected from gambling related harm to their health. To do this Participating Operators that provide online gambling products will take steps to identify customers who they believe should not be gambling and share some key customer information with the GamProtect system. Participating Operators will use GamProtect to identify whether the same customer has an account with them and proceed to close their account to reduce the potential for harm.
This privacy notice explains how Participating Operators in the Single Customer View trial project use your personal data. Please note that from 08/02/2023 for a period of approximately 12 weeks Participating Operators will share customer personal data but not take any action on the data. This is so the Participating Operators can evaluate the effectiveness of the technical solution. You can see which operators are participating in the Single Customer View trial project by going to the Participating Operators section of this notice.
There are 3 key players in this process:
The “Closing Operator”: this is the Participating Operator that closes your account and can be any of the Participating Operators.
“GamProtect”: this is the system that allows for secure data sharing between all operators in a way that ensures privacy. They will receive customer data from the Participating Operators on a daily basis.
The “Receiving Operators”: these are the Participating Operators who receive a match from the data that is shared by the Closing Operator to GamProtect and the Receiving Operator’s own customer database. If the Receiving Operator and the Closing Operator have the same customer, then they will take a similar action to protect their shared customer e.g., closing the customer’s account.
The Receiving Operator will not know the specific reason why the Closing Operator has shared data with them via GamProtect. If your personal data has been shared with GamProtect and you would like to find out why, please contact the Closing Operator. You will receive an email from the Closing Operator informing you that your details will be shared with GamProtect.
How does the Single Customer View trial work?
Risk Identification
Participating Operators will identify a player as at risk of health-related problem gambling if the player indicates that they:
Have a gambling problem or addiction.
Are seeking external support or treatment for gambling problems.
Will harm themselves or someone else.
Should not be gambling because they have a medical condition.
Want to stop gambling forever due to problems with their gambling.
Initial Account Closure
Once a Participating Operator has identified a player as at risk of health-related problem gambling, it will close all of the player’s accounts and exclude the player from all of its gambling services.
It will also inform the player that they will be added to GamProtect due to issues with health-related problem gambling.
Registration
The Participating Operator will add the following Registration Data about the player to GamProtect:
Forename
Surname
Date of Birth
Postcode
Email address
Telephone number
Unique Customer ID set by Participating Operators
Matching
Each Participating Operator will routinely check all their current players’ details against the details of the players previously added to GamProtect by scanning their customer database against the system.
If a player who is playing with one Participating Operator has been previously added to GamProtect by another Participating Operator, GamProtect will provide the Participating Operator carrying out the GamProtect check with the following information about the player (GamProtect Response):
Status as added to GamProtect.
Category of health-related problem gambling risk (see Risk Identification box above).
Name of Participating Operator that added the player to GamProtect.
Further Account Closures
When a Participating Operator is informed by GamProtect that a player has been identified as being at risk of issues with health-related problem gambling, it will close all the player’s accounts with the company.
Initial active Period
A player will remain on GamProtect and subject to the matching process initially for a period of [five years] from the date they were first added by a Participating Operator. This is known as the initialactive period.
During the active period all Participating Operators will exclude the player from their gambling services.
The player cannot remove themselves from GamProtect during the active period.
However, if a player thinks they have been added to GamProtect incorrectly, they can follow the GamProtect redress process explained below.
Further Active Period
At the end of the active period (if the player is not removed from GamProtect by the redress process), the player will remain on GamProtect and subject to the matching process for a further active period.
During this further active period all the Participating Operators will continue to exclude the player from their gambling services.
The player can remove themselves from GamProtect at any time during the further active period by contacting the Participating Operator that has prevented them from accessing gambling services using the contact details below.
However, if the player does not remove themselves from GamProtect, the further active period will continue (and they will remain excluded from all Participating Operators’ gambling services) for a period of 35 years.
Archive Period
Following the end of the further active period (either by request or expiry), the player’s details will be held for an archive period of seven years.
Reidentification of Risk
If during a further active period or archive period a Participating Operator re-identifies a player as at risk of health-related problem gambling, the Participating Operator will re-add the player to GamProtect and the active period will restart.
Categories of personal data to be processed as part of the Single Customer View trial
Personal data
Data types
Source
Information concerning health-related problem gambling that a Participating Operator has identified.
This data is processed by the Participating Operator.
Information provided by the player that indicates that they:
Have a gambling problem or addiction.
Are seeking external support or treatment for gambling problems.
Will harm themselves or someone else.
Should not be gambling because they have a medical condition.
Want to stop gambling forever due to problems with their gambling.
Customer
Registration Data
Forename
Surname
Date of Birth
Postcode
Email address
Telephone number
Unique Customer ID set by Participating Operators
Customer
GamProtect Response
GamProtect Response is the response which provides a Receiving Operator to confirm the Customer has been added.
Status as added to GamProtect
Resulting flag that indicates health-related problem gambling issue for adding to GamProtect
Name of Participating Operator that added the player to GamProtect
Created by GamProtect
Correspondence for the purpose of GamProtect
Any personal data provided by a player in correspondence
Customer
Purpose & Legal Basis for this Initiative
Participating Operators will process customer’s personal data for the primary purpose of identifying customers with health-related issues with problem gambling that are common to any other Participating Operator and attempting to protect extremely vulnerable people from gambling related harm across those common Operators. This involves:
Communicating with a customer to identify a potential harm.
Closing, suspending or restricting the customer’s account.
Sharing customer personal data with GamProtect.
Searching for customers who have been registered on GamProtect.
Evaluating the ongoing effectiveness of the GamProtect solution.
The legal basis for the purpose we have described is the Participating Operator’s legitimate interests in protecting customers from harm. Specifically, these interests are:
To improve intervention for people suffering from health-related problem gambling issues.
To share the identification of players who are suffering health-related problem gambling issues.
To provide greater insight into effective ways of reducing people in the UK from suffering health-related problem gambling issues.
A proportionate approach to the identification of people in the UK from suffering health-related problem gambling issues and protect customers without unduly infringing their rights and freedoms.
Special category personal data is personal data that can reveal health data and other sensitive information about a person. As the scheme is designed to detect and prevent health-related problem gambling the Single Customer View trial data is considered to be special category personal data. Where the processing of customer data involves special category data the legal basis for the Participating Operator’s processing this data is substantial public interests. The substantial public interests are outlined in the UK Data Protection Act 2018 as: safeguarding of children and of individuals at risk.
Recipients of the data
Customer data will be shared with the GamProtect system which is owned and provided by Tutelar Limited. (“TUTELAR”) and its subcontractors The Data Shed Limited and Amazon Web Services. We can be compelled to share information within GamProtect with regulators and law enforcement agencies at their request. Participating Operators will also share the flag indicating a health-related problem gambling issue associated with a customer with other Participating Operators. If a Participating Operator ceases to exist, they will share the specific reasons why a customer’s data has been shared to GamProtect with another Participating Operator.
We will transfer your personal data to GamProtect who will then confirm matches with the other Participating Operators. We have implemented Standard Contractual Clauses with appropriate addendums to protect the personal data during the transfer.
Data Retention for Single Customer View
Categories of Personal Data
Purpose of Processing
Initial Exclusion Retention Period
Residual Exclusion
Retention Period
Archive Period
Total Combined Retention Period
• Forename
• Surname
• Date of Birth
• Postcode
• Email address
• Telephone number
• Unique Customer ID set by Participating Operators
• 1B Flag
• unique Customer ID set by GamProtect
• the time and date at which the request was received
• the date at which the “marker” was set by the Closing Operator (this is enforced by the API definition)
• the “brand” responsible for setting each “marker” as provided by the Closing Operator (this is enforced by the API definition)
• the details of which Closing Operator added the Closed Customer (including system authentication details used and the originating IP address.)
• To improve intervention for people who may have health-related issues with problem gambling.
• To share the identification of players who may have health-related issues with problem gambling.
• To provide greater insight into effective ways of reducing people in the UK from suffering with health-related issues with problem gambling.
• A proportionate approach to the identification of people in the UK who may have health-related issues with problem gambling and protect Customers without unduly infringing their rights and freedoms.
5 years
35 years
7 Years
47 years
Full text is on the attached file