Pre-commitment discussion paper
Response form
Interested persons and organisations are encouraged to provide
submissions commenting on all or any of the parts of the
pre-commitment discussion paper.
The Department is particularly interested in responses to the
questions posed throughout the discussion paper. Submissions
are not required to answer any, or all, of these questions and
may address other related issues.
The Department will not consider any parts of submissions
that seek to revisit the Government’s determination that
pre-commitment should be voluntary for players to use and
must be available on all gaming machines in Victoria.
This response form reproduces the questions posed
throughout the pre-commitment discussion paper.
The Department welcomes use of this form in part or in full.
It is not a requirement for submissions to use this form.
Submissions should be forwarded, in writing, to:
Post: Pre-commitment
Office of Gaming and Racing
PO Box 18055
Collins Street East
MELBOURNE VIC 8003
or
Email: [email protected]
For further information regarding this discussion paper,
please contact:
Susan Graham
Project Manager – Pre-commitment
Telephone: (03) 8684 1972.
Your details
Name
Mr Clayton Wheeler
Organisation (if applicable)
PVS Australia Pty Ltd
Email address
[email protected]
Address
Telephone
Suite 12, 574 Plummer St
Port Melbourne, 3207
(03) 8671- 1900
Please note:
Submissions will be published on the Department of Justice website.
Any information that is commercial-in-confidence should be
identified in your submission and a request should be made to
withhold the information from publication.
For the purposes of this document, commercial-in-confidence
material or information may be taken to include material or
information:
•
the publication of which would disclose information from
a business, commercial or financial undertaking, and the
material or information relates to:
––
trade secrets
––
other matters of a business, commercial or financial
nature and the disclosure of the information would
be likely to expose the undertaking unreasonably to
commercial disadvantage.
In deciding whether disclosure of material or information
would expose an undertaking unreasonably to commercial
disadvantage, for the purposes of the above, persons providing
submissions should give consideration to whether the material
or information:
•
is already in the public domain
•
would be generally available to competitors
•
could be disclosed without causing substantial harm to their
competitive position.
Each submission will be considered on a case-by-case basis.
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Pre-commitment discussion paper response form
Part 1: What is pre-commitment and what will it do?
Potential pre-commitment features and processes
Q.1. To what extent will the proposed features and processes be simple and easy for players to access and use?
• The features and processes should be simple to use to enable players to easily take advantage of
the benefits of the system. Over complicating the features and processes will only add barriers to its
effective use.
• Additionally the features and processes should be simplified so that the ‘systems’ objectives are
achieved within the prescribed regulatory time frames and at reasonable cost.
Q.2. To what extent will the proposed features and processes assist players to minimise the risk of experiencing harm from gambling?
• PVS is of the view that a pre-commitment system will in general have a limited effect on minimising
the risk of players experiencing harm from gambling. However players who nominate to use the
system as a harm minimisation tool will benefit significantly.
• The proposed system should be supported by effective in-venue harm-minimisation processes. A
reliance on pre-commitment alone may not have the desired harm reduction effect.
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Q.3. Can the proposed features and processes be easily implemented and are they cost-efficient (that is, are they the most effective
mechanisms that impose the least cost to industry)?
• It’s our view that this proposed system cannot be delivered “easily” and is not “cost efficient”. This system is an extensive project and will require substantial effort and cost
to whoever is approved to implement. However there are aspects of the features and processes that can be implemented with less resistance, cost and time such as;
• Limits; for ease of implementation the number of limits should be reduced to a daily time limit, daily expenditure limit and no limit. Other limits proposed such as session
limits should be eliminated due to likely duplication with daily limits. Also weekly expenditure limits should be eliminated to reduce the scope and cost of the system.
• Limit setting; this functionality to be limited to kiosk or web sites only. This functionality would have a universal feel to it across these devices. PVS does not support the limit
setting functionality at any other points in the system. Also note that this type of functionality is already prescribed in new gaming machines PID screens as part of the
Victorian Government regulations. Any additional functionality prescribed for game software could be duplication with no real harm minimisation benefit.
• Changing limits; Agree with functionality at web site and kiosks only.
• Alert Messaging; Agree with no audible or flashing lights in relation to messaging. Agree with regular messaging during playing sessions. We propose when a player’s limit
is reached a message appears on the screen advising that their limit has been reached accompanied with a RSG message. We also hold the view that no personalised
messaging should be included to protect the player’s privacy.
• Player Activity Statements; Agree with this proposed functionality. PVS suggest it’s the responsibility of the approved provider to send statements via mail or other methods
and not venues as players generally visit several different venues.
• Live Action Summary; PVS does not agree with this functionality. As part of the 1st stage of Victorian Government’s Pre-Commitment policy, all prescribed machines will
have the functionality for players to track their play via the PID screen. Adding “Live Action Summary” duplicates the legislation and regulation that is already in place. PVS’s
understanding is that as prescribed machines are installed this functionality will become more widely available to players across the next license period. This will ensure that
players have 2 methods of tracking play on prescribed machines, either via this proposed system or via the PID screen.
Q.4. What, if any, privacy issues might arise for players, and how can these be mitigated?
• It’s absolutely critical to the successful operation of this system that all privacy laws are adhered
to. Data is to be treated with the upmost confidentiality and not to be distributed in any way even for
research.
• PVS suggests a privacy policy to be written and available to players on the website/kiosk/code and
via staff.
• Whilst it would be ideal for kiosks to be located in areas with in a venue that would ensure patrons
can maintain their privacy, this in practice will be difficult to achieve.
Q.5. What, if any, impacts on venue staff might arise from the proposed features and processes?
• Venue staff will require extensive training in the features and processes of the system to enable its
successful ongoing operation.
• Also we believe that staff will be impacted by further compliance measures with RSG which will
require additional administration support.
• We believe the code needs to be amended to include venues requirement to deliver the proposed
features and processes.
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Pre-commitment discussion paper response form
Incentives and other factors that might influence the take-up and use of pre-commitment
Cashless gaming
Q.6. What are the benefits, costs and/or issues associated with linking pre-commitment and cashless gaming:
•
for players?
• Overall we believe that it would be beneficial for the take up of pre-commitment system for it to be
to linked to cashless gaming. The key benefit for players is the additional security of not handling
cash in and around venues.
The issues associated with this functionality for players are:
a) Identification procedure (100 points)
b) Pins & passwords at devices
c) Procedures for lost cards
d) Handling lost funds
•
for venues?
• Reduction of cash handling/cancel credit/jackpot payouts. The introduction of cashless gaming
would add cost to the implementation of this system We believe additional costs will be required for
sandwich board pin pads and supplementary devices.
• A critical issue for all concerned will be how players accounts are managed in a multi venue /
operator system. For example if a players wins at Venue A then seeks to redeem their cash on the
device at Venue B.
• The implementation of rules and regulations regarding this issues could be complex and will
require careful consideration
Q.7. Does cashless gaming create risks for gamblers or encourage problematic gambling behaviour? Please provide explanations
for your answer.
• PVS is aware there is conflicting research regarding cashless gaming.
• PVS would not advocate that cashless gaming systems be connected to banking accounts.
• PVS would recommend that the total amount that can be loaded on to an access device is equal to
the individual player pre-commitment loss level and/or current cash win limits.
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Pre-commitment discussion paper response form
Loyalty programs
Q.8. What are the benefits, costs and/or issues associated with linking pre-commitment and player loyalty programs:
•
for players?
• The benefits for players are improved quality in loyalty systems providing better customer experience.
The main issues that we perceive are;
• Personal identification & privacy matters.
• The processes involved in managing a loyalty system coupled with in venue RSG measures.
• We believe that players should not incur direct costs in the operation of a loyalty system.
• Player loyalty benefits will be lost if the facility is not networked. This maybe in direct conflict with the venues objectives.
•
for venues?
• The key benefit for venues is that they can create loyalty from existing players rewarding them for their custom.
• Venues will incur the administration costs associated with operating loyalty systems such as Player Activity
Statements, maintaining an up to date player database and other consumable items.
• A key issue is that each venue will desire to operate their individual loyalty system. Venues will want to accrue
points for player loyalty that will be used for the promotion and use within their own venue. These accrued points or
benefits will not be available for use by the player at other venues. This will mean that a player could access the
pre-commitment system with multiple loyalty system cards from multiple venues. This will complicate the whole
system.
Q.9. Does linking loyalty programs with pre-commitment create risks for gamblers or encourage problematic gambling behaviour?
Please provide explanations for your answer.
• PVS is of the view that consideration be given to the processes involved in marketing loyalty
programs. Loyalty programs need to be attractive to enable a positive take up of pre commitment
however, this needs to be tempered with harm minimisation strategies that ensure loyalty programs
are operated in such a manner that minimises the risk of problematic gambling behavior.
Q.10. How can loyalty programs be structured in a way that is complementary to pre-commitment or that actively encourages the
take-up of pre-commitment?
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Pre-commitment discussion paper response form
Other factors that might influence take-up and use of pre-commitment
Q.11. What other incentives could be provided in conjunction with pre-commitment to encourage its take-up and use?
Q.12. What, if any, elements could discourage players from taking up or using pre-commitment? What incentives could be provided
to mitigate this?
• Displaying EGM play information on the screen. The mitigation procedure is to not show player
information on the screen.
• The perception that the player’s information will be used for other purposes, such as research, can
compromise the player’s confidence in the system. All player information should be kept STRICTLY
CONFIDENTIAL. A policy and statement available players could mitigate this perception.
• The system should be simple to use. At the scoping stage elements of the system that over
complicate, duplicate or add unnecessary functionality should be removed.
Q.13. Please provide any additional ideas to:
•
encourage players to take up pre-commitment
•
encourage venue operators and their staff to promote pre-commitment to patrons.
• In venue staff training
• Review of the Gaming Code of Practice
• Advertising
• Free training
• Free distribution of POS material.
• No additional operational cost passed on to venues.
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Pre-commitment discussion paper response form
Part 2: What are the technical options for pre-commitment?
Networked
Q.14. What are the key implementation issues for a networked pre-commitment system?
• PVS advocates that when scoping pre-commitment requirements the simplest solution needs to be
implemented.
• The appointed pre-commitment provider to have enough development time to achieve regulatory
approvals.
• Licensed technicians should have sufficient logistical time frames to install the pre-commitment
hardware/software components along with any other configuration changes.
• Training and information sessions for venue operators and staff.
Q.15. What are the ongoing costs and benefits of a networked pre-commitment system?
• PVS believes that the ongoing cost (hardware/software) is approximately the same between
networked system as compared to a non-networked system.
Q.16. What are the advantages and disadvantages for players of a networked pre-commitment system?
• Security of information held at central repository and not remotely.
• Current pre-commitment limits/balances are updated regularly.
• All changes/modifications are centralised.
• Perception of use or manipulation of information data for other purposes by the provider,
regulatory body or any other party.
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Pre-commitment discussion paper response form
Monitoring network infrastructure
Q.17. What are the costs and benefits of using the monitoring network to deliver a networked pre-commitment system?
The benefits of using the licensed monitors network to deliver a networked pre-commitment system
are;
• Licensed monitor and network already approved.
• Gaming machines have a pre-existing connection and the ability to communicate has already
been established.
• The “per unit” cost should be lower due to existing infrastructure already in place and economies
of scale.
Separate network infrastructure
Q.18. What are the costs and benefits of using separate network infrastructure to deliver a networked pre-commitment system?
• Its important to note there are no additional functionality benefits from a separate network provider.
• The cost of a separate network provider to establish a WAN separate to the monitor’s WAN is
extensive. This setup cost will be passed on to players/venues to recover. The “per unit” cost as a
result will be higher.
• The development and implementation risks are much greater.
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Pre-commitment discussion paper response form
Non-networked
Q.19. What are the key implementation issues for a non-networked pre-commitment system?
• We believe the implementation issues between a non-networked system and a networked system
are very similar.
Q.20. What are the ongoing costs and benefits of a non-networked pre-commitment system?
• An issue to consider is how often the card is used at a kiosk to update the player information.
Encouragement to use kiosk would need to be considered.
• A non-networked system still require a central repository that is updated at periodic intervals. The
only difference is the timing of the player information updates to the central repository. It would be
necessary to create hundreds (the number of venues) remote repositories at each venue creating
multiple system failure points.
Q.21. What are the advantages and disadvantages for players of a non-networked pre-commitment system?
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Pre-commitment discussion paper response form
Part 3: Who should provide pre-commitment?
Responsibilities
Q.22. What do you see as the responsibilities of the pre-commitment provider?
• Provide a pre-commitment system that has high integrity, is secure to use, protects player privacy
and is reliable.
• The system also needs to be delivered at a low cost to users and adheres to all regulations and
legislation.
Monitoring licensee
Q.23. What are the key issues associated with the monitoring licensee providing pre-commitment?
• As above
Q.24. What, if any, are the advantages and disadvantages associated with the monitoring licensee providing pre-commitment?
• The monitoring licence provider has pre-established infrastructure to provide all necessary
components required to deliver this system.
• The monitoring licence provider has already satisfied all regulatory and probity requirements.
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Pre-commitment discussion paper response form
Single provider
Q.25. What are the key issues associated with a single provider, other than the monitoring licensee, providing pre-commitment?
• Overall delivery and implementation of second network will require;
• Extended regulatory uptake time frame.
• Extended research and development time frames.
• Extended time frame for Implementation in the field.
• Ability for EGMs to accept a 2nd system other than the monitors system.
• Probity and approval of another provider.
• Cost to players/venues.
Q.26. What, if any, are the advantages and disadvantages associated with a single provider, other than the monitoring licensee,
providing pre-commitment?
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Pre-commitment discussion paper response form
Multiple providers
Q.27. What are the key issues associated with pre-commitment being provided by multiple providers?
• As per Question 25
Q.28. What, if any, are the advantages and disadvantages associated with pre-commitment being provided by multiple providers?
Thank you for taking the time to share your views with us.
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