Customer Liaison Officers should be very familiar with the Queensland Responsible Gambling Guidelines for Player Loyalty Programs (PLP) if these types of programs are a feature of the venue.
PLPs should be advertised and promoted like any other gambling products or services in such a way as to encourage gambling as a form of leisure and entertainment (which a person must be prepared to pay for), with money spent on gambling being an ‘entertainment cost,’ i.e. as fun and enjoyable, if engaged in responsibly. The guidelines recommend the following nine practices.
Advertising or promotion of a PLP within the wider community complies with the Queensland Responsible Gambling Advertising and Promotions Guideline (March 2005).
Direct marketing practices comply with the Australian Direct Marketing Association (ADMA) Direct Marketing Code of Practice.
Registration process provides relevant information for the consumer to make informed decisions regarding their participation in the PLP.
PLP features and functions do not offend prevailing community standards.
PLP reward point accrual and redemption mechanisms do not focus exclusively on gambling activities where other venue activities are available, where practicable.
PLP features and functions are not implicitly or explicitly directed at minors or vulnerable or disadvantaged groups.
PLP features and functions do not involve any irresponsible trading practices by the gambling provider.
The Code of Practice defines irresponsible trading practices as:
The offering of an inappropriate enticement to customers that is in conflict with the objective of maximising responsible gambling and minimising problem gambling.
Irresponsible trading practices are actions designed to persuade an individual to gamble in an excessive and irresponsible manner by offering inappropriate inducements. Such inducements may involve individuals who are persuaded to gamble, who in the absence of an inappropriate inducement, would not have otherwise gambled. This may result in individuals being persuaded to gamble for longer periods of time in a more excessive and irresponsible manner than they otherwise would have done. Inappropriate inducements therefore have the potential to impact on people who are at risk of, or have a gambling problem.
Where appropriate and possible, positive responsible gambling messages are to be incorporated in PLP features and functions.
PLPs must comply with the Exclusions Framework.
This blog begins a series designed for Customer Liaison Officers to assist them comply with the Responsible Gambling Code of Practice, and in particular, relating to player loyalty programs.