Responsible Game Design BGC s inaugural Code of Conduct Wiggin LLP Wiggin LLP
Responsible Game Design: BGC’s inaugural Code of Conduct
In the other day's article "The next issue of responsible game design", we analyze the aristocracy report "Gambling's negative effects-at the time of action" ("report"), and in the field of responsible product design. He commented on the activities he was already working on.
The most notable is to minimize the harm to the gambler, which is a problem with a better game design, is most effective in the work that the European Commission and the Betting & Gaming Council (BGC) are currently working on in this field. This is the claim of our views.
BGC today announced the 1st BGC Game Design Conduct ("Country"). This is a culmination of gambling designs to ensure that the more secure gambling principle of gambling is completely incorporated into the industry game.
The Code of Conditions stipulates the new "Code of Conduct Standards" applied to online slot products in two stages:
Phase 1
The following criteria promise that BGC members will introduce them by September 30, 2020:
- Minimum game cycle speed 2. 5 seconds
- End of turbo play (enabling player's game speed up);
- The abolition of i n-game base games slam stops (these features enable the player to interact with the base game to end it before the base game ends naturally).
- The abolition of the mult i-slot play function (the player can put multiple games in different games at the same time).
Second stage
BGC members also promise to implement various additional measures to enhance the transparency of games for players, such as the display of winning and losing and clarification of the features of the game, and add friction and reflection to the game session. I also promised.
BGC members have listed some measures that can be introduced to new games by January 31, 2021:
- The sum of the wins below the bet is clearly distinguished from the same or higher wins as the bet, and the winning line wins so that the player is displayed in enough length to understand the effect of the bet. Make the betting display more clear (according to the existing RTS 7e).
- Bonus games are improved and bonus games other than base games (for example, clicks to confirm that they have won bonus games and can participate in bonus games). Includes the requirements that are not automatically activated without any, but requires the positive behavior of a player that is not limited to this.
In addition to Code Standard, the industry has announced that it will seek how to improve the labeling of the game to deepen the understanding of the main terms of players through the Game Design Research Institute.
BGC also works with individuals who have experienced academic, regulatory authorities, consumers, and identifying the best practices in future game designs, and can respond to changes in technology. I promised to do so.
This code stipulates a wide range of industry commitments that show the willingness to accept and improve the safety of players through responsible game designs.
It is not yet known whether the promises and suggestions included in the same rules will be convinced of the European Commission and the famous critics of the industry.
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Performance of a contract with you (if applicable)
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The legitimate interests of Wiggin or third parties
Our office may process your personal data based on the legal basis of our office and/ or the legitimate interests of a third party. This is mainly applied when the office provides legal advice and services to the client. In such a case, our legitimate interests are to properly implement the role as the official and regulatory provider of legal services. The client of our office also has a legitimate profit (and more legal rights) for gaining legal advice and services.
The widespread benefits of our office regarding the provision of legal services, and the benefits of customers regarding the receipt of such services, which are the basis for handling customer personal information, includes the following (but not limited to these). It can be divided into more individual categories:
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In addition, our office may process your personal data for the effective management and operation of our office, as needed for the legitimate benefit of our office. This includes the recruitment of suppliers and suppliers, interviews with future staff, ensuring the safety and efficiency of the system and facilities of our office, compliance with regulations and legal regulations, related audits and reports. Includes general business development, insurance, payment, payment and receipt, and recovery of money (but not limited to this). < SPAN> Our office may handle your personal data based on the legal basis of our office and/ or a legitimate profit of a third party. This is primarily applied when the office provides legal advice and services to the client. In such a case, our legitimate interests are to properly implement the role as the official and regulatory provider of legal services. The client of our office also has a legitimate profit (and more legal rights) for gaining legal advice and services.
The widespread benefits of our office regarding the provision of legal services, and the benefits of customers regarding the receipt of such services, which are the basis for handling customer personal information, includes the following (but not limited to these). It can be divided into more individual categories:
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 data to various parties to promote your purpose;
Give instructions to third parties on behalf of the client;
Receive payments from clients and third parties and promote payment to clients and third parties.
To enable all of the above, safely manage and store your personal data in our IT environment and hard copy filing system.
In addition, our office may process your personal data for the effective management and operation of our office, as needed for the legitimate benefit of our office. This includes the recruitment of suppliers and suppliers, interviews with future staff, ensuring the safety and efficiency of the system and facilities of our office, compliance with regulations and legal regulations, related audits and reports. Includes general business development, insurance, payment, payment and receipt, and recovery of money to the office (but not limited to these). Our office may process your personal data based on the legal basis of our office and/ or the legitimate interests of a third party. This is mainly applied when the office provides legal advice and services to the client. In such a case, our legitimate interests are to properly implement the role as the official and regulatory provider of legal services. The client of our office also has a legitimate profit (and more legal rights) for gaining legal advice and services.
The widespread benefits of our office regarding the provision of legal services, and the benefits of customers regarding the receipt of such services, which are the basis for handling customer personal information, includes the following (but not limited to these). It can be divided into more individual categories:
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 data to various parties to promote your purpose;
Give instructions to third parties on behalf of the client;
Receive payments from clients and third parties and promote payment to clients and third parties.
To enable all of the above, manage and store your personal data in our IT environment and hard copy filing system.
In addition, our office may process your personal data for the effective management and operation of our office, as needed for the legitimate benefit of our office. This includes the recruitment of suppliers and suppliers, interviews with future staff, ensuring the safety and efficiency of the system and facilities of our office, compliance with regulations and legal regulations, related audits and reports. Includes general business development, insurance, payment, payment and receipt, and recovery of money to the office (but not limited to these).
- 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 relevant 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
When processing the personal data of a special category, which is your race or ethnic opinion, political opinion, religious and philosophical beliefs, unions, health data, biological information, or sexual orientation data Unless it is obliged by the law (for example, the exercise or defender for the exercise of legal claims), or if information is required to protect the health of the customer in an emergency We will obtain explicit consent from. If we are processing personal data based on your consent, you will always send it to us by sending a dataprotection@wiggin. co. uk, a specific consent you want to withdraw. You have the right to withdraw consent.
- 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. < SPAN> The Company does not have the possibility that the processing of personal data based on our legitimate benefits as described above will cause unreasonable disadvantages to the rights, freedom of the customer, or the legitimate interests of the customer. We are reviewing our systems and processes regularly 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 relevant 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
- When processing the personal data of a special category, which is your race or ethnic opinion, political opinion, religious and philosophical beliefs, unions, health data, biological information, or sexual orientation data Unless it is obliged by the law (for example, the exercise or defender for the exercise of legal claims), or if information is required to protect the health of the customer in an emergency We will obtain explicit consent from. If we are processing personal data based on your consent, you will always send it to us by sending a dataprotection@wiggin. co. uk, a specific consent you want to withdraw. You have the right to withdraw consent.
- 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. 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 relevant 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
When processing the personal data of a special category, which is your race or ethnic opinion, political opinion, religious and philosophical beliefs, unions, health data, biological information, or sexual orientation data Unless it is obliged by the law (for example, the exercise or defender for the exercise of legal claims), or if information is required to protect the health of the customer in an emergency We will obtain explicit consent from. If we are processing personal data based on your consent, you will always send it to us by sending a dataprotection@wiggin. co. uk, a specific consent you want to withdraw. You have the right to withdraw consent.
Disclosure of personal data
Gambling Commission Announces New Changes
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.
Financial Risk Checks
Light touch vulnerability checks
- We may disclose your personal data to third parties (outside Wiggin) but only where such disclosure is necessary and in accordance with our confidentiality obligations. Such recipients may include, but are not limited to, other clients and contacts, co-advocates, other solicitors/barrister/specialists/foreign law firms instructed by us for you, our insurance brokers and underwriters, our banks, auditors and accountants, debt collection agencies, our outsourced IT providers and other suppliers, HMRC, the Solicitors Regulation Authority, the Law Society, the Home Office and HM Passport Office, opposing parties and/or other parties (lay people and solicitors) in any matter.
- We may also need to disclose your personal information to our consultants operating in the UK and US, staff in our Brussels office and our associated and related businesses (including INCOPRO, Overmorrow, Viewfinder, Reviewed & Cleared and Cirkus) in the course of our work.
Your personal data may also be disclosed to one or more third party service providers who provide us with IT and other technology services, who act as data processors under our control. We will take appropriate steps as required by law to ensure that where the parties involved are data processors, they have in place appropriate data security systems and process data only in accordance with our instructions.
Is your personal data transferred outside the EEA? If so, what safeguards are in place?
Enhanced financial risk assessments
Some of the third-party service providers we use and some of our consultants are based or have activities in the European Economic Area (EEA). Until the end of the Brexit transition period on December 31, 2020, no additional safeguards are required for data transfers to and from the EEA. Some of the third-party service providers we use and some of our consultants are based or have activities in countries outside the UK and the EEA. Where the latter service providers process personal data in the course of providing services to us, we ensure that our contracts with them include standard clauses approved by the European Commission (sometimes called "EU Model Clauses") to ensure that the processing meets the security standards required within the EU. The European Commission's decision, including these standard clauses, can be found at this link: http://eur-lex. europa. eu/legal-content/EN/TXT/PDF/? uri=CELEX:32010D0087& amp; from=en. Following the decision of the European Commission (CJEU) in Schrems II that the US/EU Privacy Shield does not provide adequate protection for personal data transferred to the US, we are monitoring cases where personal data is transferred to the US to see whether such transfers, even if made on the basis of the relevant EU Model Clauses, pose a significant risk to your rights and freedoms. If so, we commit to making the necessary changes.
About the protection of personal information
We have a robust security system in place to prevent unauthorized access to, use, alteration, destruction or accidental loss of your personal data. We have put in place appropriate technical and organizational security measures and rules and procedures to prevent unauthorized access to, and, where applicable, to, the personal data we hold that is particularly sensitive or confidential, and to ensure your confidentiality. We have established and strictly adhere to an information security policy that sets out the security standards we use to protect your personal data.
Where we use third parties to process your personal data on our behalf, we will require them to have appropriate security arrangements in place, to comply with our contractual requirements and instructions, and to ensure compliance with the GDPR and other relevant data protection laws, as required by the GDPR.
How long will Wiggin retain your personal data?
Our policy is that we will retain your personal data for no longer than is necessary for the specific purpose for which we process it, 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 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 restrict access to archived personal data and ensure that all personal data is stored securely and kept confidential.
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Game Design
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- What are your rights?
- Based on the Data Protection Law, there are various rights about personal data. The British Information Committee Secretariat's website provides useful summaries on your rights and can be accessed here (https://ico. org. uk/your-data-matters/). In particular, customers have the following rights:
- Right to access the copy of your personal data
- Right to request correction if there is an error in your personal data
Right to oppose the decision on customers by automated means (however, we do not make decisions by automated means);
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The right to withdraw your consent at any time if you ask for your consent.
The right to do not process your personal data for the purpose of direct marketing.
- Also, in a specific situation, we may have the following rights for your personal data:
- Right to limit or oppose the use of your personal data by our company;
- The right to request us to provide a copy of your personal data to others
The right to demand the erasure of your personal data.
Age verification in premises
If you wish to exercise your rights, please contact our data protection manager (dataprotection@wiggin. co. uk).
There are exceptions to personal rights for personal data, especially when we process customer personal data for the purpose of providing legal advice to clients, the rights of customers may be limited. Our office always respects your personal data and strives to maintain transparency as much as possible, but in some cases, it is legal to allow our office to handle your personal data. Please note that it may be restricted.
PMLs
How to file a complaint
- If you have any questions about the information described in this notification or if you have any concerns or complaints about how to handle your personal data, please contact our data protection manager (dataprotection@wiggin. uk). Please contact us. 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
- Following the publication of the White Paper in April 2023, the Gambling Commission conducted a consultation on various proposals from 26 July to 18 October (the Consultation). The consultation included several notable proposals on direct marketing, remote game design and financial risk checks, the latter of which we also reported on following the Gambling Commission's announcement earlier this year that it would launch a pilot program of financial risk checks.
Comment
If you make a net loss of £125 within 30 days.
If you make a net loss of £500 within 365 days.
Betting and Gaming Council Announces Game Design Code of Conduct
The Commission took the decision to remove the requirement for a 12-month continuous threshold, as data demonstrated that only a small minority of people could be subject to the annual threshold without having previously been subject to the 30-day threshold. The Commission therefore considered it disproportionate to introduce an additional threshold. It is encouraging to see the Commission acting in this way, based on evidence, as it has promised the industry. So is the Commission’s decision not to require operators to take into account personal information such as job titles or postcodes as part of these checks.
Overall, this requirement is likely to be well received by the industry, as many operators already carry out such checks in some form and they should be “frictionless” for customers. The consultation also confirms that these checks can be carried out quickly, so operators will not need to pause customer activity until the results of the checks are available.
The response confirms that the enhanced financial risk assessment for larger value customers will not be rolled out until a pilot program analysing data sharing has been implemented. This pilot program will start on 31 August 2024 and will last for six months, unless the Commission decides to extend the end date to the end of April 2025. Again, it is encouraging to see the Commission following through on the assurances it gave to the industry in the White Paper that such checks will not be implemented until they can be carried out in a way that is “frictionless” for customers (or at least the vast majority of customers).
It should be noted that the European Commission has decided to participate only for larg e-scale businesses belonging to three bands (J1, K1, L1) with the highest license fee. We are also looking for volunteer businesses other than bandwidth. In other words, flexibility is introduced to the revision of the SR code, and the gambling committee can change the threshold during the trial implementation period. If it is confirmed that the enhanced financial risk evaluation can be performed in the test operation as a result of the test operation, it will be deployed in the production environment, but in any case. , These checks will enter the production environment after 2025. The European Commission has confirmed that this test operation does not affect customers and the businesses do not need to act based on data (of course, this is the case that participants in dialogue with customers. It is not exempt from duty). It should be noted that this trial implementation does not require the implementation of financial risk assessments that have been strengthened up to 2025 as early as 2025, but Betting and Gaming Council (BGC) is related to customer checks and document demands based on expenditures. This is the publication of the industry's sel f-norm (BGC industry norm). This BGC Industry Code was jointly formulated by the BGC member and the Gambling Committee, aiming to bring some consistency throughout the industry until the enhanced financial risk check is introduced. There is. The BGC Industry Code stipulates the actions that BGC members should take if the customer wants to have more than £ 5, 000: £ 5, 000 per month, and Correspondence when customers wish to have a net deposit of more than £ 25, 000 in 12 months. The interaction between the BGC Industry code and the financial risk check will be separately performed, but these numbers are (apart from whether they recognize it publicly). It is noteworthy that it has deviated significantly from the previous European committee, which has called for evaluating affordability at a much closer level of 500 pounds than 5, 000 pounds. On January 17, 2025, multiple changes in the remote game design rules are enforced. As described in the consultation, this change expands the rules that are currently applied to slot products and apply them to other online gambling products. The changes are as follows:
Phase 1
Prohibition of playe r-led "spin stop" functions in all casino products
Introduced at least 5 seconds of spin speed in all casino games (excluding peer to pier poker and slot)
Prohibition of auto play in all online game products (including bingo)
Expand the ban on celebrating the false victory (wins below the bet) to all casino products.
Prohibition of simultaneous play functions in all casino games (excluding peer to piercing poker)
Mandatory to the operator to display the elapsed time and net position in all casino products (excluding pee r-to piercing)
In addition, RTS section 4 has been updated to correct security audit requirements. After October 31, 2024, the audit must be authenticated in accordance with the updated ISO27001 in 2022.
Consultation proposed a new social liability (SR 5. 1. 12). Eventually, it focuses on not being able to receive direct marketing against channels and product preferences, which is also the purpose of response.
According to the answer, the consultation proposal will be implemented from January 17, 2025. However, from the proposal of the discussion, there were remarkable changes:
The lottery is deleted from the list of the product category, and only betting, casinos, bingo (applicable) must be included in the product option;
Phase 2
Post notifications and push notifications are deleted from the channel category list, and if applicable, only calls, emails, and SMS must be included in the channel options.
Businesses do not need to stop marketing for customers who have not set marketing preferences according to the proposed product options.
Businesses do not need to stop marketing to customers who do not have marketing preferences, but do not set up marketing prepare when customers log in for the first time after January 17, 2025. In some cases, it is necessary to ask the customer to reconfirm. You need to uncheck all options so that customers can be consciously selected.
- As proposed in the consultation, the Licensei of Category A and B will be eliminated on the lan d-based exemption on the purchase of the age confirmation test. These changes were enforced on August 30, 2024, and all related facilities must be tested by March 31, 2025.
- In addition, a plan to introduce the "Think 25" policy approach for the age confirmation proposed in the discussion will be implemented. This will come into effect on August 30, 2024.
- The answer from the Gambling Committee indicates that multiple changes will be made to LCCP1. 2. 1:
Clarify that the CEO, the Managing Director (Managing Director) or the equivalent, must have PML.
- Expand the PML requirements below:
- The Chair of the Board of Directors (this is applied only to the chairman who was appointed in a fixed or uncertain term, and does not apply to temporary or shor t-term appointment for individual meetings).
- Money laundering prevention compliance person in charge
Businesses need to be carefully examined and apply to them by the due date. There is also a reassuring suggestion that the European Commission (ultimately) listens to consultation and considered a part of it. However, what is truly tested is how the European Commission will perform trial implementation to enhance financial risk checks, and the results will not be known for a while.
Comments from the industry on these changes will be important in the coming weeks, and we plan to continue providing more detailed information on these changes. In the meantime, the business operator needs to keep in mind the changes that are applied to themselves and the deadline that requires compliance. The checklist is shown below so that it is easy to refer to:
On September 25, 2020, the Betting & Gaming Council ("BGC") announced a new game design behavior ("norm"). The norms are the results of the industry's Safa Products Working Group formed in January 2020, and pursued the opportunity to reduce gambling harm through games and product design.
BGC members need to comply with this standard, including when operators use game suppliers other than BGC.
The norms are applied to online slot products and are intended to evolve as they are "live documents, and as the research base and understanding of game design continue to develop." This code stipulates 14 principles of commitment to transparency, transparency, player education, innovation, and research, based on the comprehensive purpose of enhancing players, and is classified in the following fields. :
Game features
Cooperate with academic experts, regulatory authorities, consumers, gambling experienced people, and other technical experts to identify and agree with the increased risk of players.
Selection of players based on information:
Innovation and Testing Lab
By providing clear information on products and game rules, including mathematical characteristics such as risk, winning rate, and optimal strategy, you can play more safely.
Strengthening control innovation:
- Improving gambling tools that support both player's gambling monitoring and control, such as expenditures, losses, victory, and tim e-based measures.
- Governance and continuous improvement:
- In addition to transparency, information disclosure, independent evaluation, the process of reviewing and updating the Code of Conduct.
- The code of conduct is divided into two stages:
At this stage, we will introduce four standards for game design. This requirement is in line with the recent discussions of the Gambling Committee on online slot game design, aiming to apply these standards to the industry as a whole. The Code of Academic has requested that BGC members will take measures by September 30, 2020, and BGC members will "take on these standards first."
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