Consumer Protection Strategy

We know that extraordinary things happen when lots of people play a little. Encouraging Healthy Play is at the heart of everything we do, from the way we design our games to the tools that help put you in control of your play.

Introduction

We are committed to maximising returns to Good Causes through selling National Lottery products in a socially responsible way, with a lot of people playing a little. Our main priorities are the prevention of underage play and excessive play.

Our Consumer Protection Strategy is an important element of our overall business strategy. It sets out how we aim to achieve our ambitions by creating safe online and retail environments to play in, designing games in a responsible way and promoting Healthy Play.

The fact that The National Lottery is ranked just 66th in the world in terms of per capita spend, despite being the seventh largest lottery in the world in terms of sales¹, underlines the effectiveness of our approach to date in this area.

Our Ambitions

• To be the safest place to play
• To promote Healthy Play

We do this by focusing on:

• Player – Preventing underage players from accessing National Lottery products as players must be aged 18 or over to play National Lottery games; and detecting and interacting with at-risk players to minimise excessive play.
• Product – Designing games that are lower risk and don't appeal to vulnerable groups, including those under 18, through a rigorous game design process.
• Place – Creating controlled play environments – online and in retail – and promoting Healthy Play habits to all players.
• Leadership – Taking a leading role in advancing Consumer Protection practices.

Our Activities

Player

• To prevent underage play in our digital channel, we use a robust age and identity verification system to block anyone under the age of 18 from playing or trying our games.
• In retail, our mystery shopper programme will continue to help us gain assurance that retailers have effective safeguards in place to prevent underage play. To support retailers, training is provided along with in-store communications to ensure compliance with the rules on age to play. We retain the right to remove the retailer’s terminal and terminate their retail agreement at any time for failing to implement sufficient safeguards.
• Our products and advertising display the latest age restrictions.
• Online we have a rigorous registration process with age verification checks to ensure players are 18+.
• Healthy Play messaging plays a prominent role in our online player journey. This starts with our welcome email, through to our online toolkit encouraging players to stay in control of their play, through setting session time reminders, taking time out or choosing to self-exclude from individual or all games. Players can choose the duration of their exclusion from a short break between 1 day up to 5 months, a temporary exclusion between 6 months up to 5 years, or a permanent exclusion.
• We regularly communicate with our players via email, app alerts and website pop-ups to encourage Healthy Play behaviours and uptake of Healthy Play tools.
• With millions of people playing the National Lottery online via our website and on our Mobile Apps, we take online consumer protection seriously. Online we use a behavioural analytics model to spot patterns of behaviour that suggests a player is at-risk of playing excessively. We send these players targeted communications to encourage a positive change in behaviour. We continue to review and update these interventions to ensure they are effective in preventing excessive play and encouraging Healthy Play.
• Players who are identified as at-risk have significantly lower deposit and play limits imposed upon them to mitigate against excessive play, and, if appropriate, we will suspend these accounts. Players who have been identified as at-risk for a longer period of time may also have their accounts temporarily suspended or excluded for either a fixed period of time or permanently.
• In retail, our Healthy Play Mystery Shopper programme tests selected retailers’ knowledge on Healthy Play and whether they were able to correctly signpost players to sources of support.
• Those requiring support or treatment are made aware of the options available to them through our communications channels, Contact Centre colleagues and on our products. This includes signposting to relevant organisations and informing them of our online tools that can help them manage their play. We also engage with, and support, organisations addressing problem gambling in the UK, including GamCare and GambleAware.
• As well as being a time of extreme excitement and happiness, suddenly winning a substantial sum of money can be an overwhelming and emotional experience for many people. We have a complete support package in place for all high tier winners (winners of over £50,000) which includes a dedicated Winners’ Advisor, Private Banking, Financial and Legal advice and access to a Life Coach.
• Winners benefit enormously from practical advice like making wills and managing their finances but the win also enables them to enjoy new experiences and create special memories with their loved ones.
• We really want our winners to enjoy their prize, so they also have access to a Lifestyle Management/Concierge company to aid them with their life-changing transition.
• We are committed to ensuring our site is accessible and usable for all abilities and disabilities. Our website is built in line with accessibility best practice and is accredited by AbilityNet.

Product

• We have a robust Responsible Game Design Process in place to ensure that the games we design are safe to play. This process is overseen by our Game Risk Evaluation Action Team, with representatives from across Allwyn. The process is reviewed each year to ensure it is effective, adding enhancements where necessary.
• All games are risk-assessed prior to launch, ensuring that they are responsible in their design. We use both GamGard and Asterig, tools which assess the risk levels of a game’s structural and situational characteristics, and a risk checklist to identify any further risks posed by the game; for example, ensuring that the design doesn’t strongly appeal to children, in line with the CAP Code guidance. This is complemented by enhanced research and review for games that are significantly new and different.
• If any of these tools identify a risk level which is too high, we will revise the game. If the risk remains too high, we will not launch the game at all.
• In retail, we incorporate the helpline details for GamCare on all of our products, and our ‘Dream Big Play Small’ Healthy Play messaging on many of our products.
• New staff within relevant teams receive training on game design and advertising to ensure games are designed, marketed and advertised in a way that supports our ambition to promote Healthy Play.
• We are committed to ensuring that our employees understand our commitments to consumer protection and support them in their daily operations, with extra training for those in direct contact with players. For example, all Contact Centre employees are trained on how to spot signs of excessive play and what to do as a result, as well as receiving monthly Healthy Play knowledge tests.
• All of our advertising and marketing is checked to ensure it complies with the Advertising Standards Authority CAP Code and BCAP Code. The Codes promote safe marketing, in particular the need to prevent young people under 18 from being harmed by any unsafe advertising.
• Targeting to anonymous players (those not logged into an account) is only carried out if the user has agreed to Allwyn’s marketing cookie being placed on their browser or if they have opted-in to app push notifications on their device.
• National Lottery account holders are able to opt in and out of personalisation via their account settings.
• All communications with National Lottery players are in line with Data Protection Legislation.

Place

• Our ambition is for lots of people to play a little, and our Healthy Play messaging Dream Big Play Small reminds our players of how we want them to play. It features on media screens in Retail, draw-based games tickets, Scratchcard advertising and our website.
• We provide information and training to all National Lottery retailers through our Being a Responsible Retailer training programme. This sets out our requirements and expectations on how to support Healthy Play and prevent underage play. This is communicated through a range of leaflets, information packs, terminal messaging, terminal printouts, articles in our Jackpot magazine, face-to-face visits and telephone calls.
• Our Supporting Healthy Play training programme for all National Lottery retailers includes simplified guidelines and training to ensure retailers have an understanding of excessive play and the right tools to be able to support players if appropriate, such as a terminal printout signposting to GamCare and our Healthy Play page.
• We continue to further enhance Healthy Play support for all of our retailers, with a particular focus on those who need more advice and guidance to improve retailer confidence and understanding.
• Retailers have been trained to advise and provide information to players, including Games Rules.
• Our Players’ Guide is available at retail outlets and on our website, outlining our approach to Healthy Play and includes the GamCare helpline details.
• Through online personalisation, we have increased Healthy Play messaging to players identified as at-risk and removed the promotion of Instant Win Games to these players on the National Lottery website home page when signed in.
• We provide preset limits for our players on the amount they can deposit and spend per week. We also limit the number of Instant Win Games that can be played in a day. All players are encouraged to review these limits and set lower ones appropriate for their personal circumstances.
• Following research by the Behavioural Insights Team, we removed the weekly minimum and maximum deposit limits on our Add Funds page. Instead, we offer players a free-text box to enter the amount of funds they wish to add.
• Players can also use our online budget calculator to anonymously and confidentially assess their affordability to play and can use a self-assessment tool to find out what kind of player they are. A full list of our online tools can be found on our website.
• We are integrated with GAMSTOP for our Instant Win Games which provides a free service for players to self-exclude from online gambling websites and apps in Great Britain.
• Our website signposts to GamBan, GAMSTOP and GamCare. Our media screens in retail also signpost to GamCare’s website via a QR code.

Leadership

• We have contributed to consumer protection developments through industry working groups at the European Lotteries (EL) and World Lottery Association (WLA).
• We hold the highest levels of the EL Responsible Gaming Standard and WLA Level 4 Responsible Gaming Certification, and have been certified against both for over 10 years, recognising our commitment to continuous improvement.
• We hold Level 2 of the GamCare Safer Gambling Standard, a social responsibility quality standard for licensed gaming operators. It aims to increase overall standards of social responsibility practice across the industry, helping to make play safer for all.
• Research is fundamental to improving our understanding of and approach to unhealthy play. We support independent research, studies and conferences that contribute to the wider understanding of problem gambling. This includes an annual contribution to GambleAware, an independent charity that funds research, education and treatment services to help minimise gambling-related harm in Great Britain.
• All employees are required to complete a Healthy Play module each year, together with/supported by ongoing awareness driven through our internal communications channels and as part of our induction programme for new employees.

¹Source: La Fleur’s 2023 World Lottery Almanac