Gambling Act White Paper Advertising Sponsorship and Branding Wiggin LLP Wiggin LLP

Gambling Act White Paper: Advertising, Sponsorship and Branding

The Call for Evidence did not delve deeper into gambling advertising than other areas of potential gambling reform, acknowledging that the Committee of Advertising Practice ("CAP") had already conducted separate consultations on content restrictions for advertising to ensure the protection of under-18s and vulnerable groups. However, the Government noted that these groups are still exposed to gambling advertising and noted growing public concern about the link between sport and gambling, despite efforts such as the "Whistle to Whistle" ban to reduce the exposure of gambling advertising on live sports television.

Against this background, the Government requested specific evidence on:

The benefits and harms arising from allowing gambling operators to advertise (the Call for Evidence also notes that it acknowledges the significant revenue stream the gambling sector provides to broadcasters and advertisers);
The effectiveness of mandating safer gambling messages in advertising to prevent harm to consumers;
The benefits and harms of promotional offers such as free spins, bonuses and hospitality;
The positive or negative impacts of gambling sponsorship in sport and eSports.

What does the White Paper propose?

The White Paper recognises that gambling advertising and marketing has transformed since 2007 and the importance of adopting voluntary measures. However, the government's conclusion is that measures have not yet gone far enough to reduce the risk of the public experiencing gambling problems as a result of various forms of advertising and marketing used by the industry.

This view is likely influenced by the fact that following a question on advertising and sponsorship in the call for evidence, "a large number of responses were received, with opinions strongly divided". Unsurprisingly, respondents from health, charities and academia argued that gambling advertising needed significant reform, as there was widespread consensus among these sectors that the pre-2005 "total ban" approach should be recycled.

By the time the White Paper was presented, few people thought they would support the complete eradication of gambling-related marketing. Andrew Taylor, executive policy officer at CAP, managed industry expectations by saying that "advertising bans will displace loads of revenue to go to other marketing activities, and ultimately advertising will only be one part of what operators do".

Interestingly, the White Paper states that the call for evidence showed a "lack of conclusive evidence on the relationship between advertising and harm" - a point we consider important. Furthermore, the Commission's own research confirmed that advertising and sponsorship were passive factors that had "relatively little influence on behaviour". Perhaps that is one of the reasons why no changes have been suggested to the legal framework surrounding gambling advertising and sponsorship.

Despite agreeing that any form of advertising or marketing is harmful in "normalising" harmful practices (e. g. underage or out-of-reach gambling), the Government does not consider participation in gambling to be harmful in itself. This seems sensible in light of the fact that gambling is one of the biggest pastimes in the country, except for a small minority (even without taking into account the fact that gambling advertising and the sponsorship deals that result from it undoubtedly generate a lot of money).

Nevertheless, the White Paper sets out four main proposals for a tougher approach to gambling advertising and sponsorship.

1. Restrictions on bonuses and direct marketing

Customers who do not show "strong" indicators of harm may be restricted from receiving online bonus offers or direct marketing

The White Paper makes clear that gamblers with high gambling involvement are likely to be highly exposed to gambling advertising, as they are on many operators' mailing lists. It also points out that even non-gambling people can be tempted to gamble through promotions.

Currently, operators are required to ensure that customers who show "strong" indicators of harm do not receive direct marketing or new bonus offers, in accordance with requirement 10 of the European Commission's customer interaction guidance, but this requirement is something the industry is still grappling with since it came into force.

The White Paper suggests the Government wants to go further than requirement 10. Despite the Government’s acknowledgement that there was a lack of conclusive evidence about the relationship between advertising and harm from the Commission’s customer dialogue guidance and calls for evidence submissions, the White Paper suggests that even if customers are not.Even if they do not currently show ³strong³ indicators of harm, persistent targeting of a customer base with high levels of spending using online bonuses may increase the risk of future harm to certain individuals.As with other areas commented on in the White Paper, the Commission plans to launch a consultation to explore evidence on the potential impact of targeting mechanisms.

Ahead of that consultation, businesses would be wise to consider how to realise the Government’s proposals. The task of analysing their existing customer base, identifying those who do not currently show indicators of harm and placing them in a bucket of customers who are likely to require closer attention in terms of sending them marketing materials and promotional offers is not without difficulties.

Indeed, if this proposal were to come into force, it is likely that in order for operators to be able to justify why they considered it appropriate to send direct marketing materials or promotional offers to customers who do not currently show "strong" indicators of harm but who are at risk of suffering harm, clear records of punters' gambling behaviour would need to be maintained and justified in light of the corresponding known behavioural indicators to inform whether operators market to those customers. We believe that the response to the consultation should encourage the government to clearly indicate how it expects operators to achieve this potential requirement.

Treatment of VIPs

In the fall of 2020, the commission introduced new rules regarding expensive customers (“HVC” guide), which include the requirement to establish that: (I) any customer expenses were affordable and stable; And (II) the client did not show signs of harm before becoming a VIP client. The commission will continue to monitor this, but since the White Book does not provide for any further changes regarding online vip-clients, we can conclude that the HVC leadership corresponds to the goal (and given that since the introduction of new rules the number of customers participating in such schemes , decreased by 90 %, it is difficult to argue with this).

As for the ground VIP clients, the government seems to be satisfied with how they are treated, and considers existing control measures by the commission adequate.

Operators must still be ready to explain to the regulator how they demonstrate compliance with the Regulation 5. 1. 1 of the Code of Social Responsibility (“SRCP”) of LCCP and the leadership of the Commission for Cremming for the High Cost. They will have to do this with a special emphasis on why they considered it appropriate to participate in the client in these schemes in the light: (I) a known level of income of the client; and (II) his behavior in gambling.

Mechanics of bonus proposals and r e-waging requirements

欧州委員会が協議するもう一つ分野は、ボーナスオファーの仕組みに関するもの、ボーナスオファーの実現にな賭け金に関する性含まれる。欧州ははこの分野 " に業界によってすでに多くの取り組みなされていることを認識した上で賭け条件上限やオファーの有効期限切れるまでの最低をべきべきかかを "

It is clear that the industry needs to rethink the thresholds at which customers can re-bet and how bonuses are presented. These promotions are often complex and difficult to understand even for experienced gamblers. Operators should re-evaluate their current bonus campaigns and ensure that: (i) re-betting thresholds are not set at levels that encourage gamblers to place large bets to qualify for a bonus, (ii) the deadline for claiming winnings is extended (it was argued that a one-week period is too short), and (iii) offers that suggest a bet is "free" are avoided. These considerations go slightly further than the current SRCP 5. 1. 1, which aims to ensure that wagering and bonus terms are as transparent as possible. However, those looking at this from a general advertising compliance perspective might say that these considerations are consistent with the existing requirements of the CAP Code, which seek to ensure that this type of marketing is not misleading to consumers (this is a legal obligation). Consent for direct marketing and clear opt-in offers

The call for evidence specifically noted concerns about "cross-selling", i. e. encouraging existing customers of one gambling to try another. The main concern is, unsurprisingly, the cross-selling of what are considered high-risk products (such as online casinos) to, for example, recreational sports punters.

Operators are already subject to requirements such as obtaining informed consent or specific consent to send marketing to consumers, and not sending direct marketing to self-excluded customers or those with signs of harm, but the government believes there should also be additional requirements for retention marketing activities. All this would give customers more choice regarding promotional offers, but it would be a considerable step forward for the industry.

The Commission will consult on how operators specifically obtain consent for direct marketing and promotional offers, and the White Paper proposes guiding principles in the meantime.

There is no doubt that this guidance principle imposes a higher responsibility for all customers so that all customers can give freedom to choose for marketing and marketing that are not received from businesses. Some may already say that these principles are in line with ICO's guidance and consent, but white paper seems to propose an approach with only consent to direct marketing, probably. It would be more stepped in the current interpretation of most businesses on the "Soft Optin" rules for marketing of similar products based on PECR. As a result, the marketing team needs to "strengthen" resources in order to provide more options and thinness in the framework of consent and to record and act on the marketing and tastes of each customer. This not only requires investment in more sophisticated systems to ensure to deliver to appropriate people when sending marketing materials, but also reduces direct marketing that sells similar products. It seems to be.

(i) A more powerful and comprehensive approach to targeting and content standards, (II) A variety of online safety measures to reduce gambling content contact and make it easier to access support.

The government states in the White Paper on the fact that businesses should use ads and marketing targeting to children and vulnerable people, and social media aggresses.

2. Making advertising smarter and safer

At first glance, the advantages of targeting / data of advertising methods seem to be simple, but in fact, there are several core problems related to analytics used to identify the proposed customer profile. Cathing to someone's Internet activities is not a certain way to identify the age of that person. Furthermore, if the business operator suggests that the customer who has been proposed by data and analysis is the age required, how far it is to "untirting" advertisements from young people. Is it expected to step in?

Gambling and lottery ads must not be a "strong appeal test" (strong appeal test "). Combined with the new rules of the CAP, the standards for gambling advertising have been raised.

A strong appeal test prohibits content that appeals to the age of 18 (formerly only a “specific” appeal), regardless of how adults look. As a result, gambling operators, especially if there are marketing content using media and sports talents in the past, will be subject to more severe content restrictions.

The combination of a strong appealing power test and the white paper proposal means that the business operator is required to ensure: (i) The advertising campaign does not strongly appeal to children and young people, (II). Advertisements may not be targeting children and young people. Considering that one of the three goals of the 2005 gambling method protects children and the vulnerable from harm and exploitation, the purpose of these measures can be understood. In order to eradicate children and young people to touch gambling content, advanced technology and data are required. Based on the Strong appeal test, the required resources in the planning stage of the marketing campaign will increase dramatically. However, businesses have to invest in both. Without such an increase in investment, businesses will definitely face regulatory monitoring (and potentially reputational damage).

The White Paper is described in the three pillars of more secure gambling messaging presented in evidence: (i) Provided to customers when using online and offline products, such as the player reduction rate displayed in the game machine. The information that is displayed is displayed, (II) Links to the "Begambleaware. org" or "Time to Think" campaign are displayed, and (III) Gamcare, Gamstop, Gambleaware can access the Bet Regret campaign. A strong appeal test prohibits content that appeals to the age of 18 (formerly only a “specific” appeal), regardless of how adults look. As a result, gambling operators, especially if there are marketing content using media and sports talents in the past, will be subject to more severe content restrictions.

3. New approach to safer gambling messaging

The White Paper is described in the three pillars of more secure gambling messaging presented in evidence: (i) Provided to customers when using online and offline products, such as the player reduction rate displayed in the game machine. The information that is displayed is displayed, (II) Links to the "Begambleaware. org" or "Time to Think" campaign are displayed, and (III) Gamcare, Gamstop, Gambleaware can access the Bet Regret campaign. A strong appeal test prohibits content that appeals to the age of 18 (formerly only a “specific” appeal), regardless of how adults look. As a result, gambling operators, especially if there are marketing content using media and sports talents in the past, will be subject to more severe content restrictions.

The combination of a strong appealing power test and the white paper proposal means that the business operator is required to ensure: (i) The advertising campaign does not strongly appeal to children and young people, (II). Advertisements may not be targeting children and young people. Considering that one of the three goals of the 2005 gambling method protects children and the vulnerable from harm and exploitation, the purpose of these measures can be understood. In order to eradicate children and young people to touch gambling content, advanced technology and data are required. Based on the Strong appeal test, the required resources in the marketing campaign are dramatically increasing. However, businesses have to invest in both. Without such an increase in investment, businesses will definitely face regulatory monitoring (and potentially reputational damage).

Although such a road is already widespread, the white paper suggests that there is the advantage of developing systematic messaging separately from the industry to further push more secure gambling messages. This proposal is to start by developing a solid approach to information messages throughout the customer journey, replacing the industry that the industry owns, which is safer than the industry. After the development, gambling operators will be involved in new messaging and other requirements for further requirements to apply. Operators are definitely very different from the information messaging approach, and even if they are designed jointly, it is not yet known whether the uniform approach works.

4. Socially responsible sports sponsorship

Until this is realized, the BGC of BGC, which is updated, focusing at least 20 % of television and radio advertising slots, focusing on more secure gambling. Existing commitments are extended to include online media.

There is no real "muscle writing" here. As before, promoting participation in gambling in a safe and responsible way is a public health initiative, and once discussion is started, it is recommended that the industry to submit opinions on proposals.

A gambling sponsor contract in the sports industry is a very important source of income for the club. It is not really shocking that the white paper has not proposed a law amendment to prohibit or control gambling after recognizing this.

Instead, the "Code of Conduct" proposed by the White Paper provides "meaningful improvement" in the social responsibility of gambling sponsorship, but also gives the sports a flexible difference that is clearly present.

The details of the Code of Conduct are still unknown, and it is noteworthy whether the content has actually been stepped into "harm". Most sports management organizations have already set strong rules to manage their relationships with gambling companies, but they do not necessarily push social responsibility messages. Of course, after the Premier League ends on the 2025/26 season, some sports have already taken voluntary measures, such as removing the gambling logo from the front of the match day. This kind of debris has already become widespread, but the white paper suggests that there is the merit of developing systematic messaging separately from the industry to further push more secure gambling messages. 。 This proposal is to start by developing a solid approach to information messages throughout the customer journey, replacing the industry that the industry owns, which is safer than the industry. After the development, gambling operators will be involved in new messaging and other requirements for further requirements to apply. Operators are definitely very different from the information messaging approach, and even if they are designed jointly, it is not yet known whether the uniform approach works.

Reflection

The details of the Code of Conduct are still unknown, and it is noteworthy whether the content has actually been stepped into "harm". Most sports management organizations have already set strong rules to manage their relationships with gambling companies, but they do not necessarily impede social responsibility messages. Of course, after the Premier League ends on the 2025/26 season, some sports have already taken voluntary measures, such as removing the gambling logo from the front of the match day. Although such a road is already widespread, the white paper suggests that there is the advantage of developing systematic messaging separately from the industry to further push more secure gambling messages. This proposal is to start by developing a solid approach to information messages throughout the customer journey, replacing the industry that the industry owns, which is safer than the industry. After the development, gambling operators will be involved in new messaging and other requirements for further requirements to apply. Operators are definitely very different from the information messaging approach, and even if they are designed jointly, it is not yet known whether the uniform approach works.
Until this is realized, the BGC of BGC, which is updated, focusing at least 20 % of television and radio advertising slots, focusing on more secure gambling. Existing commitments are extended to include online media.

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Instead, the "Code of Conduct" proposed by the White Paper provides "meaningful improvement" in the social responsibility of gambling sponsorship, but also gives the sports a flexible difference that is clearly present.
The details of the Code of Conduct are still unknown, and it is noteworthy whether the content has actually been stepped into "harm". Most sports management organizations have already set strong rules to manage their relationships with gambling companies, but they do not necessarily impede social responsibility messages. Of course, after the Premier League ends on the 2025/26 season, some sports have already taken voluntary measures, such as removing the gambling logo from the front of the match day.
Noticeably missing from the White Paper's discussion of gambling sponsorships is clarity on how branded content should be regulated and who should be responsible for it. Drawing the line between sponsorship and advertising could not be more important for operators and rights holders hoping to extract commercial value.
Amid the myriad of scheduled consultations, the industry might want to consider this further: (i) a clearer understanding of how sponsorship deals should be structured and evaluated, and (ii) an understanding of which rules (and which regulatory consequences) apply.

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In summary, there are no real curveballs thrown in the White Paper on advertising, marketing and branding. Taken in isolation, some might say the government's line is a "light touch". However, given the current regulations, the consequences of the government's proposals, if implemented, will be significant. The proposals will not be simple to implement and will be costly. For example, the less-publicized proposals on cross-product marketing would require operators to obtain consent at the most granular level, store data appropriately and ensure their teams are properly staffed. The economic impact of this is likely to be substantial.

We strongly encourage the industry to participate in each consultation to ensure that the destinations of gambling advertising are actually achievable and have a measurable, positive impact on people who should be protected from the harm that gambling advertising may cause.

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A timeline showing the key dates for each consultation resulting from the White Paper can be accessed here.

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We have a strong security system to prevent unauthorized access, use, tampering, destruction, or accidental loss on your personal data. We take appropriate technical and organizational security measures, so that those who do not have access authority cannot access the personal data owned by the Company, especially those who have no access authority. In order to do so, the rules and procedures are determined to ensure the confidentiality of the customer. The Company has set a security policy that sets security standards used to protect your personal data, and strictly comply with it.

Updating gambling regulation in Great Britain – the final furlong?

If we use a third party to process your personal data on our behalf, we will require them to have appropriate security arrangements in place, comply with our contractual requirements and instructions, and ensure compliance with the GDPR and other relevant data protection laws.

How long will your personal data be stored by Wiggin?

It is our policy to keep your personal data for no longer than is necessary for the specific purposes for which it is processed by us, as set out in this Notice. However, we may be obliged to store your personal data for a longer period, for example if required by our legal or regulatory obligations or to ensure we have an effective IT back-up system. In such cases, we will ensure that your personal data will continue to be treated in accordance with this Notice, we will limit access to archived personal data, and we will ensure that all personal data is kept secure and confidential.

Website Cookies and Trackers

The only cookies we use on the website are session registration cookies:

When you fill in your details on our registration form (for example if you wish to register to receive communications or other services from us), this cookie remembers the details you have loaded into the registration form to prevent you from erasing all your details if you make a mistake and have to redo the form (which can be annoying and inconvenient). The cookie is a "session" cookie and disappears after you have filled in and submitted the form. We will assume that you consent to these cookies, but if you wish to deny your consent you can block them by changing your browser settings. See http://www. wikihow. com/Adjust-Browser-Settings.

Our email marketing messages may direct you to a web page which uses the ASPSESSIONID% cookie. This cookie enables the page to remember the specific settings you used. This cookie is temporary and is destroyed each time you close your browser.

For more information about cookies in general, see All About Cookies.

We also use Google Analytics, a web analytics service provided by Google. Google uses the collected data to track and examine the use of our website, to compile reports on its activities and share them with other Google services. Google may use the collected data to contextualize and personalize the ads on its own advertising network. The personal data collected are cookies and usage data, the processing of which takes place in the USA under Google's standard terms and conditions and privacy policy. Google Analytics cookies are processed under Google's standard terms and conditions and privacy policy.

Your rights

Under data protection law, you have various rights regarding your personal data. The UK Information Commissioner's Office website provides a useful summary of your rights, which can be accessed here (https://ico. org. uk/your-data-matters/). In particular, we inform you that you have the following rights:

The right to access a copy of the personal data we hold about you

The right to request correction of any inaccuracies in your personal data

The right to object to decisions made about you by automated means (however, we do not make decisions by automated means);

The right to withdraw your consent at any time where we have asked for your consent;

The right to ask us not to process your personal data for direct marketing purposes.

In addition, in certain circumstances, you may have the following rights in relation to your personal data:

The right to restrict or object to our use of your personal data;

The right to request that we provide another person with a copy of your personal data;

The right to request the erasure of your personal data.

If you wish to exercise any of your rights, please contact our Data Protection Manager at dataprotection@wiggin. co. uk.

There are exceptions to individuals’ rights in relation to their personal data and your rights may be limited, in particular where we are processing your personal data for the purposes of providing legal advice to clients. We will always respect your personal data and strive to be as transparent as possible, but please note that in some cases, the law may limit our ability to even acknowledge that we are processing your personal data.

How to lodge a complaint

If you have any questions or complaints about the information described in this notification, or if you have any concerns or complaints about our personal data processing method, please contact our data protection manager (dataprotection@wiggin. uk). In any case, you have the right to complain with the information commissioner. The contact information of the information commissioner is as follows: -
INFORMATION Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5af www. ico. org. uk. The ICO's help line number is 0303 123 1113.
Last update September 28, 2021

Insurance Update of gambling regulations in Britai n-Last step?

Following the promise of the major political parties for the 2019 general election, the Digital, Culture, Media and Sports Ministry (hereinafter referred to as DCMS) announced in December 2020 that the British Gambling Law (hereinafter referred to). We announced evidence recruitment that shows the possibility of changing the 2005 Gambling Act (hereinafter 2005). In the words of DCMS at the time, they wanted to create a legal framework that complied in the digital age.

Evidence recruitment was held for 16 weeks and closed on March 31, 2021. The industry and various stakeholders will be patient (how many times in recent months in recent months (how many times in recent months, the government will confirm the results of the reviews and to show the next version of the British gambling regulations. The word "Imminently" was used).

The white paper was announced this morning, and the highlights of this white paper, which have 268 pages, are described below.

Purpose of review

Lord Alan Bad said in a report that triggered the enactment of the 2005 law, "Central dilemma" of gambling regulations, "the desire to accept free choices and such choices are individual. Or, he pointed out the tension between the tensions with the fear that it could be harmful to society.

In some cases, regulations were left behind in industry innovation, but the 2005 law has been functioning as a framework for regulations. However, the criticism that the industry has faced in recent years has always been a government intervention, and now, it has been realized.

Notably, the "core dilemma" cited by Budo remains. As part of a call for evidence published in December 2020, the government said:

"We want the industry to have modern laws and protections, with a strong regulator with the powers and resources necessary to oversee a responsible industry that provides customer choice, protects players, provides jobs and contributes to the economy."

This is exactly what the Budo report recommended more than 20 years ago.

The aim of the review was to "ensure that there is an appropriate balance between consumer freedom and choice, on the one hand, and the prevention of harm to vulnerable people and the wider community."

Only time will tell whether the outcome of this review, and the resulting changes to the law and associated regulations, will achieve that "balance," and whether, in fact, the explicit aim of strengthening player protections does not entirely ignore the impacts on choice, employment and taxation.

Clearly, opposing views remain on how the gambling industry should be regulated, with some wanting a balance between consumer choice, consumer freedom, and the success/survival of the industry, and others saying gambling is a public health emergency and needs to be more heavily regulated or banned altogether.

In striking a balance, governments will be able to please some but not all. It remains to be seen whether the constant negative atmosphere surrounding the industry, as portrayed in the media, will fade over time.

But one thing is certain: some of the proposals, particularly those loosely termed "affordability" and those relating to betting limits, would impose regulations on the industry that will satisfy, to a significant extent, a relatively small but influential group of politicians, journalists, and tweeters routinely referred to by some in the industry as the "anti-gambling lobby."

It should not be underestimated that some of these initiatives will be welcome for an industry looking to move from an era of media attacks and regulatory uncertainty to an era of clarification of regulatory expectations and long-term sustainability.

The lawyers and scholars who are reading this may be particularly interested in how British gambling regulations are actually implemented. Until now, the European Commission has not had authority in regulating the gambling industry. However, the 2005 law is delegated to a minister, and apart from a wide range of authority that can be exercised by legal documents, the committee has given the committee to change the regulations on its own. Was revealed. Changes required in the White Paper are generally required to require secondary law revisions or by the "Committee's authority".

By clarifying his position, it is hoped that the European Commission will not feel that he has been in trouble, and in response to the government's support, it is hoped to actively rebuild the cooperation with the regulation. Huh. We have already witnessed the tone of officials of the European Commission in the role of the industry advisor, which is welcome.

Main suggestions

We will take the main proposals in order and provide hig h-level summaries of the questions described in the white paper. As described above, some of these provisions will be clearly evaluated as the path of implementation will be revealed and the meaning of the change will be better understood.

In particular, there is a background that the European Commission's guidance and compliance evaluation itself are ambiguous and inconsistent.

In the industry, there have been some voices seeking more regulations on when to check when online businesses must make a check that seems to be relatively irreplaceable about the customer's financial status. This is especially proposed in the context of compliance evaluation, which is said to be not doing sufficient things, but cannot tell how much "sufficient" is actually.

The government requires a lighter touch than many athleticists sought, and some suggest that customers should make some time to assess some form before customers suffer more than 100 pounds a month. 。 The White Paper is looking for the following:

If the monthly net loss reaches £ 125 or the annual net loss reaches £ 500, check the vulnerabilities of financials; For lawyers and scholars who are reading this, British gambling regulations You may be particularly interested in how the change is actually implemented. Until now, the European Commission has not had authority in regulating the gambling industry. However, the 2005 law is delegated to a minister, and apart from a wide range of authority that can be exercised by legal documents, the committee has given the committee to change the regulations on its own. Was revealed. Changes required in the White Paper are generally required to require secondary law revisions or by the "Committee's authority".

Main suggestions

In particular, there is a background that the European Commission's guidance and compliance evaluation itself are ambiguous and inconsistent.

If the monthly net loss reaches £ 125 or the annual net loss reaches £ 500, check the financial vulnerabilities; for lawyers and scholars who are reading this, a change in British gambling regulations You will be particularly interested in how it will actually be implemented. Until now, the European Commission has not had authority in regulating the gambling industry. However, the 2005 law is delegated to a minister, and apart from a wide range of authority that can be exercised by legal documents, the committee has given the committee to change the regulations on its own. Was revealed. Changes required in the White Paper are generally required to require secondary law revisions or by the "Committee's authority".

Main suggestions
We will take the main proposals in order and provide hig h-level summaries of the questions described in the white paper. As described above, some of these provisions will be clearly evaluated as the path of implementation will be revealed and the meaning of the change will be better understood.
In particular, there is a background that the European Commission's guidance and compliance evaluation itself are ambiguous and inconsistent.
In the industry, there have been some voices seeking more regulations on when to check when online businesses must make a check that seems to be relatively irreplaceable about the customer's financial status. This is especially proposed in the context of compliance evaluation, which is said to be not doing sufficient things, but cannot tell how much "sufficient" is actually.
The government requires a lighter touch than many athleticists sought, and some suggest that customers should make some time to assess some form before customers suffer more than 100 pounds a month. 。 The White Paper is looking for the following:
If the monthly net loss reaches £ 125 or the annual net loss reaches £ 500, check the financial vulnerability;
If the player makes a loss of £ 1, 000 within 24 hours, the spending check will be enhanced (intended to "deeply insight into the customer's financial situation", but most of these checks are "check. Unless concerns arise, it will not be interrupted by customer journey.) "and
If the player makes more than £ 2, 000 losses in 90 days, enhance the spending check,

Meanwhile, for players aged 18 to 24, they propose a squirming value of £ 500 in 24 hours and £ 1, 000 in 90 days, and propose to lower the enhanced triggers.

I've commented in detail before, but the requirements for "Aforiority Check" are the two questions: when it will be done in the customer journey and what it actually means. 。

In order to make sure that the industry is already considered to be more risky for a specific customer to suffer financial harm and that there is no clear reason that it will be restricted or completely banned by related operators. It incorporates a process to query specific databases and information generally published. The White Paper seems to support this approach by demanding such a "light touch" financial vulnerability evaluation if the player produce more than £ 125 pounds a month. However, a more stepped check of the financial status of the "Ordinary Panant" (the European Commission has been calling so) seems to have taken a step in the government.

This is the particularly notable paragraph in the white paper:

"Generally, the government agrees that people should be free to use their money. The assessment is a mediu m-level spending level (net or loss within one month, £ 125, 1). In the case of 500 pounds within the year), it starts with an unusual check, and if necessary, a higher risk level (a loss of 1, 000 pounds within one day, a loss of 2, 000 pounds within 90 days), more For details, you should escalate for friction, which is 18 to 24 years old. If you make a loss, you will strengthen the expenditure check (we intend to insight the customer financial situation more deeply ", but most of these checks are" Customer journey unless there is concern in checking. Is expected to be interrupted. " "and

If the player makes more than £ 2, 000 losses in 90 days, enhance the spending check,

Meanwhile, for players aged 18 to 24, they propose a squirming value of £ 500 in 24 hours and £ 1, 000 in 90 days, and propose to lower the enhanced triggers.

Wiggin's expertise, delivered direct to you

Instead, the "Code of Conduct" proposed by the White Paper provides "meaningful improvement" in the social responsibility of gambling sponsorship, but also gives the sports a flexible difference that is clearly present.
The details of the Code of Conduct are still unknown, and it is noteworthy whether the content has actually been stepped into "harm". Most sports management organizations have already set strong rules to manage their relationships with gambling companies, but they do not necessarily impede social responsibility messages. Of course, after the Premier League ends on the 2025/26 season, some sports have already taken voluntary measures, such as removing the gambling logo from the front of the match day.
Noticeably missing from the White Paper's discussion of gambling sponsorships is clarity on how branded content should be regulated and who should be responsible for it. Drawing the line between sponsorship and advertising could not be more important for operators and rights holders hoping to extract commercial value.
Amid the myriad of scheduled consultations, the industry might want to consider this further: (i) a clearer understanding of how sponsorship deals should be structured and evaluated, and (ii) an understanding of which rules (and which regulatory consequences) apply.

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Main terminology

Personal data means information about an individual (including you) and any information that identifies such an individual.

You means any individual whose personal data we process, including Wiggin's clients, Wiggin's clients' personnel, counterparties, counterparties' personnel, other lawyers and advisors, witnesses, suppliers, suppliers' personnel and general business contacts.
Data controller
Wiggin LLP is the data controller in respect of your personal data and takes great care to protect the privacy rights of individuals.
Data protection officer
Under the GDPR, there is no requirement to appoint a data protection officer. However, we have appointed a Data Protection Manager, currently Alexander Ross, who is responsible for overseeing our compliance with the GDPR and other applicable data protection laws and regulations. In addition, a Law Practice Compliance Officer, currently Alan Owens, oversees our compliance with our professional responsibilities and legal requirements.

The Data Protection Manager can be contacted at dataprotection@wiggin. co. uk.

How does Wiggin obtain your personal data?

In many cases we obtain personal data directly from you, for example through your use of our website or through direct contact with us. In other cases we may obtain your personal data from third parties. For example, we may obtain information from our clients or their representatives, agents and advisors, other law firms or advisors acting on your behalf, the company you work for, other organisations and people you do business with, our associated and related businesses (including INCOPRO, Overmorrow, Viewfinder, Reviewed & amp; Cleared and Cirkus), intermediaries, government agencies, credit reference agencies, information and service providers, and from publicly available records.
What about personal data about other people that you provide to Wiggin?
If you provide information about someone else (your stakeholders, directors, employees, or someone in a business relationship, etc.), you have the right to disclose the information, and We must make sure that the Company understands that there is a possibility of processing the information according to this notification without taking any more measures.
What is the personal data that Wiggin collects from customers (and customers)?
When we collect and use personal data for customers, the types of data to be collected vary depending on the status and purpose of processing. Here are some examples of exemplified and no n-comprehensive:
Personal data about you: Name, address, date of birth, spouse's presence, nationality, gender, desired language, job type, work life, resumes, or/ or necessary accommodations, in some cases Personal data about family life;

Personal information for contact at work or at home: Name, address, phone number, e-mail address

Personal data that may identify you: Photos and videos, passports and/ driver's license details, electronic signature;
Personal data for processing your personal payment: Bank account details, HMRC number, inquiry (if applicable);
Personal data for monitoring the use of our website: See the following "Website Cookies and Tracker" sections.
Reasons why we collect and use your personal data
If our office collects and used your personal data, it will be done for one or more reasons for many reasons. The main purpose is to provide legal advice and services to our client, which uses one or more (not comprehensive) methods (not comprehensive). It may be included:
If you are involved in the problem that our office is working on for clients, regardless of your occupation or personal position, to contact customers;
To conduct surveys, risk evaluation, and custom customers;
To examine, make, and disclose communication documents and other documents including court documents;

To give instructions to a third party instead of a client;

To create legal opinions and provide legal advice.

To enable information exchange between related companies and related businesses of Wijin and Wijin.

In addition, we may process your personal data for business management, which is likely to use your personal data in one or more (no n-paralyzed) methods:

Contracts and contacts with suppliers

To interview future staff;

To implement marketing and general business development activities;

I n-house reviews, surveys, implementation of audits
To conduct business reports and analysis
To measure business performance and improve services
Compliance with laws and regulations and related reports
Crime prevention and discovery
What is the legal basis for Wiggin to process your personal data?
Under the GDPR, we must identify the legal basis for processing your personal data, but the basis are the type of personal data to be processed, depending on the individuals related and the nature of the processing. it's different.
Performing a contract with the customer (if applicable)

Wiggin or a legitimate profit for third parties

Contact with individuals related to our office work and client projects;

Confirmation of documents and communication disclosed to our company, our clients, and third parties that may include your personal data;

Confirm and analyze evidence that we and our clients may include with your personal data

Submission of legal arguments that may include your personal data, create documents and communications;

Disclosure of documents and communications that may include your personal information to various parties to promote your purpose;

Give instructions to third parties on behalf of the client;

Receive payments from customers and third parties and promote payment to customers and third parties.

To enable all of the above, manage and store your personal data in the IT environment and hard copy filing system of our office.

Compliance with legal obligations that Wiggin should follow

For more information on the legal basis of personal data processing, please contact the Information Commissioner Secretariat's website (see below) or our data protection manager (details below).

Payment from customers and third parties in special categories to promote payments to customers and third parties.

To enable all of the above, manage and store your personal data in the IT environment and hard copy filing system of our office.

Compliance with legal obligations that Wiggin should follow
In a specific situation, we may be obliged to handle personal data to comply with legal obligations. This includes the necessary processing for tax and accounting purposes, the necessary processes required by regulatory authorities for the purpose of conflicts, the processing required by court or court orders, or under related laws or regulations. Includes processes that enable compliance and other obligations, but not limited to these.

For more information on the legal basis of personal data processing, please contact the Information Commissioner Secretariat's website (see below) or our data protection manager (details below).

Receive payments from personal data customers and third parties in special categories and promote payment to customers and third parties.

To enable all of the above, manage and store your personal data in the IT environment and hard copy filing system of our office.

We believe that the processing of our personal data based on our legitimate interests, as described above, may be unreasonable for your rights, freedom, or your legitimate interests. We regularly review our systems and processes to maintain such situations.
Compliance with legal obligations that Wiggin should follow
In a specific situation, we may be obliged to handle personal data to comply with legal obligations. This includes the necessary processing for tax and accounting purposes, the necessary processes required by regulatory authorities for the purpose of conflicts, the processing required by court or court orders, or under related laws or regulations. Includes processes that enable compliance and other obligations, but not limited to these.
For more information on the legal basis of personal data processing, please contact the Information Commissioner Secretariat's website (see below) or our data protection manager (details below).
Special category personal data

Disclosure of personal data
Our personal data is a staff member who provides legal services to customers or customers within the Wiggin LLP and (applicable) related businesses, and / customer or customer employer or customer employer or customer employer. Disclosure to other staff in which the agent contacts.
Our office may disclose your personal data into third parties (outside Wigin), but will be disclosed according to the confidentiality of our office only if it is necessary to disclose it. Such recipients include other clients, contacts, joint lawyers, and other clerks, court lawyers / experts / foreign law firms, our insurance brokers and underwriting. People, our banks, auditors and accountants, debt collection companies, our outsourced IT providers and other suppliers, HMRC, lawyer regulations, lawyer regulations, the Ministry of Home Affairs, HM Passport, and any projects Includes the parties (ordinary people and clerical lawyers), but are not limited.

In addition, the company's consultant, Brussels Office, and our related businesses (including Incopro, Overmorrow, Reviewed & Amp; Cleared) Information You may need to disclose it.

Will your personal data be transferred outside the EEA area?

About protection of personal information

Elim Poon - Journalist, Creative Writer

Last modified: 27.08.2024

on gambling advertising and sponsorship in its White Paper. In undertook a brief period of voluntary work experience at Wiggin LLP. (Solicitors. In conjunction with Chris Elliott and Rawa Kaftan of Wiggin LLP, iGB provides a regulatory snapshot of igaming across Europe. ⚠️ SCAM ALERT⚠️ We have been notified of a scam post being shared in some local event groups advertising trade space for an event at our site.

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