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Executive summary
Following the review of the Gambling Act 2005, the gambling white
paper published in April 2024 set out the government’s plans for modernising the
regulation of the gambling sector. It outlined a comprehensive package of measures to
introduce robust new protections against gambling-related harm, targeted to minimise
disruption for the millions of gamblers who participate with no ill effects.
One of the
key proposals in the white paper was the introduction of a stake limit for online slots
games. This is in line with one of the Review’s overarching objectives, of ensuring an
equitable approach to the regulation of online and land-based gambling, and responds to
the evidence of specific risks associated with the availability of high stakes play on
online slots games.
The white paper committed to consulting on a stake limit of between
£2 and £15 per spin to structurally limit the risks of harmful play including large
losses, binge play, and loss chasing. This document sets out four options for
consideration and consultation:
a maximum online slots stake limit of £2 per spin
a
maximum online slots stake limit of £5 per spin
a maximum online slots stake limit of
£10 per spin
a maximum online slots stake limit of £15 per spin
In addition, the white
paper committed to consult on slot-specific measures to give greater protections for 18
to 24 year olds who the evidence suggests may be a particularly vulnerable cohort. In
regard to that cohort specifically, this document sets out three further options:
a
maximum online slots stake limit of £2 per spin for 18 to 24 year olds
a maximum online
slots stake limit of £4 per spin for 18 to 24 year olds
not introducing a specific
statutory stake limit for 18 to 24 years olds (meaning they could access the general
maximum limits above), but instead introducing specific requirements on operators to
consider age as a risk factor for gambling-related harm which could justify a range of
mitigations, including limiting access to higher staking opportunities on a
case-by-case basis
Alongside consideration of the options above, this document also
consults on details to support the effective implementation of the policy, including
the meaning of ‘online slots games,’ ‘maximum stake’ and ‘spin/ game cycle’.
The
purpose of this consultation is to ensure that the government is able to consider the
best available evidence, including on the impact of each option, when finalising policy
decisions. A consultation stage impact assessment including a cost/benefit analysis is
being published alongside this document. The consultation will be open for 8 weeks,
closing at 11:55 pm on 20 September 2024. We encourage all of those with views or
evidence on the options above to make submissions via the online survey by that point.
The government will then publish a formal response to set out our decision and
reasoning before implementing the changes. Any changes to the law will be made by
secondary legislation to create a new licence condition on remote gambling
firms.
Chapter 1: Introduction
In Great Britain, there are currently no statutory
limits on the amount people can stake on any online gambling products. This is in
contrast to the land-based sector, where electronic gaming machines (offering games
which are otherwise similar to online slots games) are subject to stake and prize
limits in legislation. There are no statutory limits on in person betting or other
gambling products such as games in land-based casinos.
As set out in the white paper,
there is strong evidence of product driven risk from online slots games, which is
likely to be exacerbated by the ability for operators to offer theoretically limitless
stakes. In line with the formal advice from the Gambling Commission and the general
weight of evidence, government has committed to introducing a maximum stake limit for
these games to minimise the risk of runaway or rapid losses which can contribute
significantly to gambling-related harm. This measure is designed to work in concert
with the wider package of policies in the white paper, including financial risk checks,
data sharing on high risk customers, and making online games safer by design.
Context
and the case for a stake limit
Online slots games contribute a significant proportion
of operator profits. According to Gambling Commission industry statistics, in the
2024/2024 financial year online slots contributed over £3 billion to the industry’s
Gross Gambling Yield (GGY), which totalled £9.9 billion across the whole online and
land-based sector in Great Britain excluding lotteries. This made online slots games a
bigger driver of GGY than all online sports betting and online bingo combined.
While
participation data is difficult to obtain because many surveys group online slots with
other online casino products and sometimes even bingo and National Lottery instant win
games, we know commercial slots have relatively low (albeit growing) participation
rates. For the year to March 2024, the Gambling Commission’s quarterly participation
and prevalence data found less than 1% of all adults had played any online casino games
(including slots) in the month prior to being surveyed. Figure 1 below shows data
gathered since the start of the COVID-19 pandemic from major remote operators
representing around 80% of the licensed sector on how many accounts actively played
slots games, and the GGY their gambling raised.
Figure 1: Online Slots monthly GGY and
active accounts from leading operators (c. 80% of the online market) - March 2024 to
March 2024
Source: Gambling Commission, Gambling business data on gambling to March
2024 (published June 2024). Note that individuals can be represented more than once if
they hold accounts with multiple operators, and the GGY data may include free
spins.
This combination of relatively low participation but high GGY means that online
slots games are associated with one of the highest average losses per customer of any
gambling product. Even within this the losses are relatively concentrated, with 1% of
accounts providing over 40% of slots GGY according to the data considered in NatCen’s
Patterns of Play research.
While concentrated or high spend does not necessarily equate
to harm, there were a number of other signs (explored in full in the white paper) that
online slots as currently available involve a number of factors which have been shown
to elevate the risk of gambling-related harm to consumers. For example, they are
associated with:
Binge activity - the Gambling Commission’s research into why consumers
gamble found that of the 14% of past month gamblers who reported binge gambling, 24%
had done so on online slots - more than any other gambling activity.
Engagement by
those who went on to seek support - online slots were the most commonly used product by
National Gambling Treatment Service patients in 2024/22; 38.1% had engaged in online
slots compared to 11.7% for remote casino games and 16.3% for gaming machines in
bookmakers.
Taken together, the general weight of evidence justifies government action
which addresses a key structural characteristic (potential for high losses in a short
period of time) which is likely a key driver of gambling-related harm among online
slots users. We acknowledge, however, that further evidence would be useful to inform
precisely what the limit should be to achieve the government’s objectives of effective
harm prevention with minimal disruption to those not being harmed.
Current
protections
The Gambling Commission introduced new rules in October 2024 to address
some of the potentially harmful characteristics of online slots, including to some
degree the potential for large and rapid losses. These included imposing a maximum
speed of play of 2.5 seconds per spin (in line with land-based equivalents), banning
losses disguised as wins, and prohibiting features which increase the intensity of play
or give an illusion of control, such as ‘slam stops’, ‘turbo modes’, and functionality
which allows auto-play or enables concurrent play on multiple slot games. Slots must
also display the money and time spent during a session. The Gambling Commission
recently published an assessment of the impact of these changes. It found that the
changes have resulted in reduced play intensity with no increase in staking activity in
response to the limit on spin speeds, and no significant negative impact on the
enjoyment of the games on gamblers.
Some online operators have also already voluntarily
introduced a maximum stake limit for online slots, either in response to certain risk
triggers or as a universal preventative measure. For example, Flutter introduced a
maximum stake limit for slots games of £10 per spin across all of its brands in 2024,
in response to its data that showed £10 was an inflection point where customer risk
levels started to increase sharply. According to data provided by Flutter ahead of this
consultation, the measure impacted the 4% of customers who had staked over £10 on at
least one spin in the year prior to implementation.
Online slots are also offered
within the wider context of licensed online gambling. This means there are a range of
protections at all stages of the user journey, from controls on how online slots can be
advertised, robust age and identity verification requirements before accounts can be
created and slots accessed, and requirements on gambling operators to monitor a variety
of player and play data to identify signs of harm and intervene accordingly. As
outlined in the white paper, many of the broader safeguards are being strengthened
alongside the introduction of a maximum stake limit for slots games to ensure our
regulation is fit for the smartphone era.
Next steps
This 8-week consultation on
options will ensure that the government is able to consider the best available evidence
in deciding which of the options outlined below to pursue.
Gambling policy is
substantially reserved in Scotland and Wales but devolved in Northern Ireland. This
consultation relates to online slots games provided and/ or advertised to customers in
Great Britain, by operators who are consequently required to hold the appropriate
licence from the Gambling Commission.
Responses to this consultation will be reviewed
and the draft regulations will be revised appropriately before they are laid before
Parliament. The government plans to formally respond to this consultation to announce
our decision later this year. We expect any new licence condition to come into force in
early 2024. Given the relative ease with which operators can adjust slot stakes and the
clear notice of our intention to introduce such a change, we will give a minimum of 6
weeks transition period for operators to become compliant with the new rules.
Chapter
2: The scope of limits
Under Section 78 of the Gambling Act 2005, the Secretary of
State may provide for a specified condition to be attached to gambling operating
licences through secondary legislation. We intend to use this power to attach new
conditions to remote casino operating licences, specifying the maximum stake per spin
permitted for online slot games.
However, there is no statutory definition for most
subtypes of gaming in the Gambling Act 2005, such as ‘slots’ or ‘roulette’. While there
are product categories for gaming machines in the land-based sector, these are agnostic
to game type and instead defined in terms of the limits on structural characteristics,
such as on speed of play and the maximum prize value. Slot-type game variants are found
across all gaming machine categories, with maximum stakes varying from £5 on B1
machines to 10 pence on category D machines.
Therefore, while stakeholders broadly
recognise online slot-type products as a distinct class of remote casino game, this
will need to be formally set out in the statutory instrument to determine the scope of
the limit on stake size. We are seeking a precise description which catches the
intended game types and does not create loopholes or incentivise the development of
products which are functionally similar but might be argued to be technically exempt
(such as those which combine fundamentally slots type gameplay elements with other
games like bingo). Similarly, the description should provide clarity to stakeholders as
to the regulatory status of certain gambling activities.
In 2024, the Gambling
Commission introduced rules which apply specifically to online slots in its Remote
Technical Standards. For these purposes, slots are defined as: “casino games of a
reel-based type (includes games that have non-traditional reels)”. The Gambling
Commission consulted on this definition before introducing the new rules, and
considered a number of amendments and / or alternatives suggested by stakeholders. It
ultimately concluded that this definition was well-understood across the different
types of stakeholders, and was sufficiently specific to prevent catching non-slot games
(particularly if applied to remote casino licensees) while minimising the risk of
circumvention. We agree with this assessment, and our aligning with the Gambling
Commission will avoid unnecessary complexity in the regulatory framework and reduce the
risk that some products fall within scope of one definition of slots and not the
other.
For the purposes of this consultation, we therefore consider online slots to be:
Remote casino games of a reel-based type (including games that have non-traditional
reels or which combine elements of other games within a slot game mechanic).
We are
aware that some operators have subsequently sought to challenge the Gambling
Commission’s definition, with a view to exempting some of their products from the game
design requirements specific to slots games and the government’s intended stake limit.
Our view is that the description above is clear on the types of game in scope, but if
necessary the Gambling Commission has powers to update the remote technical standards
definitions to respond to emerging risks or boundary pushing products.
Consultation
question 1: For the purposes of introducing a maximum stake limit, the government
intends to align with the definition of online slots used by the Gambling Commission.
We therefore intend for the limit to apply to: Remote casino games of a reel-based type
(including games that have non-traditional reels or which combine elements of other
games within a slot game mechanic). 1a) Does this description of online slots
adequately describe the products intended for inclusion in the maximum stake limit’s
scope? (Mandatory response)
[Yes / No / I don’t know] 1b) Please explain your answer.
(Optional response)
[Open text box]
The legislation must also define what is meant by a
“maximum stake.” “Stake” is defined in section 353(1) of the Gambling Act 2005 as
follows:
“stake” means an amount paid or risked in connection with gambling and which
either- i. is used in calculating the amount of the winnings or the value of the prize
that the person making the stake receives if successful, or
ii. is used in calculating
the total amount of winnings or value of prizes in respect of the gambling in which the
person making the stake participates
However, it may be simpler to think of a stake
from a customer rather than operator perspective. Therefore, we consider the
description of stake below to be the most suitable for the purposes of this
consultation. Sometimes operators add a bonus to the stake as a promotional device, but
here the stake is taken to refer only to the customer’s own money put at risk.
‘Maximum
stake per spin’ means the maximum amount a player can pay or risk per spin or game
cycle.
To note, our intention is that the imposed limit should serve as a maximum stake
which customers can choose to stake up to, rather than as a new default which operators
drive customers towards, or which is otherwise seen as objectively ‘safe’. Operators
currently offer stakes from as little as 1 penny per spin, and we would expect a range
of staking options below the maximum to remain available.
Consultation question 2: The
government is developing a description of a maximum stake. This description will be
adapted in legislation to introduce a maximum stake limit. The proposed description of
a maximum stake is: ‘Maximum stake per spin’ means the maximum amount a player can pay
or risk per spin or game cycle 2a) Is this description of stake suitable for the
purpose of the introduction of a maximum stake limit for online slots games? (Mandatory
response)
[Yes/No/I don’t know] 2b) Please explain your answer. (Optional
response)
[Open text box]
Again, the concept of a slots ‘spin’ is well understood among
stakeholders, but for clarity we use the term in a way consistent with the Gambling
Commission’s Remote Technical Standards which defines a game cycle as:
A game cycle
starts when a player depresses the ‘start button’ or takes equivalent action to
initiate the game and ends when all money or money’s worth staked or won during the
game has been either lost or delivered to, or made available for collection by the
player and the start button or equivalent becomes available to initiate the next
game.
Consultation question 3: For the purposes of introducing a maximum stake limit
per spin or game cycle, the government intends to align with the definition of game
cycle used by the Gambling Commission’s Remote Technical Standards. Game cycle is
defined as: A game cycle starts when a player depresses the ‘start button’ or takes
equivalent action to initiate the game and ends when all money or money’s worth staked
or won during the game has been either lost or delivered to, or made available for
collection by the player and the start button or equivalent becomes available to
initiate the next game. 3a) Is this description of game cycle suitable for the purpose
of the introduction of a maximum stake limit for online slots games? (Mandatory
response)
[Yes / No / I don’t know] 3b) Please explain your answer. (Optional
response)
[Open text box]
As outlined in the white paper, we do not intend to introduce
a maximum stake limit for online games other than online slots. This is due to the
typically slower spin speeds, a range of other controls on structural characteristics
which are being consulted on by the Gambling Commission, the functional role of stake
variation in non-slots gameplay (including to mitigate risk), and the less clear-cut
evidence of a product-driven association with harm. In our view, the descriptions above
are clear on which products fall within or out of scope.
We also do not intend to
introduce maximum prize limits for online slots games as exist for land-based gaming
machines. Submissions to the review call for evidence focused on the risks posed by
high stakes, especially in the context of high speed games like slots, rather than the
potential for high maximum prizes to cause harm. With the imposition of a stake limit,
we expect maximum prizes will also shrink as operators adjust their commercial
exposure. Following the white paper commitment, some operators have told us they expect
that game development is likely to trend towards less volatile slots products which are
designed to keep customers engaged without the pull of high stakes and prizes.
Chapter
3: Data and considerations for a maximum stake limit for online slots games
In line
with the overarching objectives of the Review of the Gambling Act 2005, our aim is to
strike an appropriate balance between preventing harm and preserving consumer freedoms.
In setting out the options below, we are seeking to understand the various impacts
across industry, society and on individuals. Further consideration is given to these
issues in the impact assessment being published alongside this document.
A further
overarching goal from the review was to level the playing field between offline and
online gambling, and the terms of reference highlighted the need for an equitable
rather than necessarily identical approach between the two sectors. The Gambling
Commission’s formal advice to our Review was that a starting point for determining the
appropriate maximum online slots stake levels could be considering the current limits
on electronic gaming machines, and then the structural differences between those and
online play. This could include:
Accessibility: There are no supply-side restrictions
on the accessibility of online slot products, which are available to consumers 24 hours
a day and often with the immediacy of a readily accessible smartphone. In contrast, a
player’s access to electronic gaming machines is subject to factors such as the
location and opening times of gambling premises, as well as limits on the number of
machines that may be operated in each venue.
The wider package of protections in place:
Online gambling is account-based, giving operators a detailed understanding of the
person playing and whether they are at risk of suffering harm. This underpins a range
of protections applied at an account level and across products. These background
safeguards are being continually strengthened including through the Gambling
Commission’s new customer interaction requirements and guidance, and the introduction
of financial risk checks for high spending customers. In contrast, play on land-based
gaming machines is often anonymous, although staff are on site and able to
intervene.
Game design: While the Gambling Commission’s remote technical standards and
machine technical standards apply similar controls with regard to online and offline
slot games including on speed of play, the remote sector offers a wider and more
rapidly evolving product mix. A single digital gaming machine cabinet might typically
offer in the region of 100 to 200 variations of slots games, whereas online there are
thousands of functionally similar but visually varied games available.
Box 1:
International approaches Several governments and regulators in other jurisdictions have
mandated stake limits for online slots games in recent years, often in line with
longstanding limits on land-based gaming machines in those jurisdictions. Other
jurisdictions have opted for different approaches such as not licensing the provision
of higher risk online casino games like slots, or introducing cross-product deposit/
loss limits to minimise the risk of gambling-related financial harm. The experience of
other jurisdictions is being considered as part of this consultation process, but each
jurisdiction has a unique historical and socio-economic relationship with gambling, and
measures which are effective or ineffective in one jurisdiction may not have a similar
impact elsewhere. Measures adopted worldwide include: Germany: Overhauled its
regulatory framework for gambling in 2024,and introduced a €1 maximum stake limit for
online slots (to bring it in line with its land-based sector). Spins cannot be quicker
than every 5 seconds.
Overhauled its regulatory framework for gambling in 2024,and
introduced a €1 maximum stake limit for online slots (to bring it in line with its
land-based sector). Spins cannot be quicker than every 5 seconds. Greece: Introduced a
€2 maximum stake limit for both online slots and other online casino games in 2024.
However, this was increased from €2 to €20 per spin in 2024 following a
review.
Introduced a €2 maximum stake limit for both online slots and other online
casino games in 2024. However, this was increased from €2 to €20 per spin in 2024
following a review. Spain: Spanish law has no limits on stake per spin for any online
product — however, operators must establish daily, weekly and monthly deposit limits
for player accounts. The Spanish regulator is proposing new rules, including
session-based loss limits for online casino gaming where players would have to set a
time limit and net spend limit at the start of every session.
Spanish law has no limits
on stake per spin for any online product — however, operators must establish daily,
weekly and monthly deposit limits for player accounts. The Spanish regulator is
proposing new rules, including session-based loss limits for online casino gaming where
players would have to set a time limit and net spend limit at the start of every
session. Italy: Similarly, Italy does not have slot specific limits, but players are
required to set account level (monetary) limits of their own choice which apply across
products.
Similarly, Italy does not have slot specific limits, but players are required
to set account level (monetary) limits of their own choice which apply across products.
Czech Republic: Introduced stake and prize limits across land-based and remote gaming
to reduce the risk of harmful gambling. For internet games, the bet on one game must
not exceed CZK 1000 (approx £35) and the winnings from one game must not exceed CZK
500000 (approx £18000).
Introduced stake and prize limits across land-based and remote
gaming to reduce the risk of harmful gambling. For internet games, the bet on one game
must not exceed CZK 1000 (approx £35) and the winnings from one game must not exceed
CZK 500000 (approx £18000). France: Online slot games and most other remote casino
games cannot be offered by licensed operators.
Factual information and data
To help
inform responses, this section sets out some of the best available descriptive
statistics on online slots and how they are currently offered and used. The Gambling
Commission has made a formal data request to industry using its regulatory powers, in
order to provide more detailed advice to the government ahead of our making a final
decision and preparing a final impact assessment. That data will where appropriate be
published with the government response to this consultation, however we do not expect
it to vary significantly from the currently available information outlined below.
Since
March 2024, the Gambling Commission has been collecting and publishing detailed
information from online gambling operators. This includes a detailed breakdown of
staking patterns with leading operators who represent approximately 80% of the online
gambling market (but given size and product mix they may not be fully representative of
all online slots providers). The data for the 2024/23 financial year covers some 76
billion individual staking events (spins), and shows that high stakes are very rare,
with stakes over £20 comprising just 0.02% of all spins. To note, the collected data
did not distinguish between stakes above and below £15 within the £10.01 to £20
bracket, however based on the best available data we estimate half of those stakes were
above £15, and half below. We have also estimated the importance for revenue of
different staking bands within the current framework.
Figure 2: Staking behaviour on
online slots in 2024/23 financial year and estimated importance for GGY of different
staking bands
Stake size Individual spins at given stake % of all stakes Estimated % of
slots GGY derived from stakes in each band* £1 and below 69,818,001,655 90.96% 69.39%
£1.01 to £2 4,683,732,773 6.10% 12.55% £2.01 to £5 1,832,226,925 2.39% 10.65% £5.01 to
£10 356,699,701 0.46% 4.78% £10.01 to £15 24,882,820 (estimated) 0.03% (estimated)
0.59% £15.01 to £20 24,882,820 (estimated) 0.03% (estimated) 0.85% £20.01 to £50
18,217,617 0.02% 1.06% £50.01 to £100 687,791 0.00% 0.09% >£100 108,758 0.00% 0.04%
Total 76,759,440,860 100% 100%
*This assumes all slots games have a 95% return to
player, and the distribution of spend within each bucket is modelled as non-linear.
Source: Gambling Commission, market impact data
While high stakes are rare in the
context of all spins, it is clear that individual players often vary their stakes over
the course of a year, for instance just after big wins, to meet any rewagering
requirements on bonuses (being separately considered by the Gambling Commission), or
just to maximise enjoyment at certain times. Flutter told us that in the year before
its imposition of a £10 stake limit, 4% of players staked over £10 on at least one
spin, and that under the new limits approximately 9% of players staked over £5 over the
course of 2024. However, even among these players most staking is at lower levels, and
Flutter reported that prior to its stake cut just 0.1% of slots players staked over £10
for more than half of their total number of spins.
As outlined in the white paper, a
data request to industry in April 2024 alongside the review call for evidence provided
important insight into how stake sizes are associated with harm, as measured by
operator-assigned risk scores as the best available proxy. This highlighted the
overrepresentation of customers identified as high risk among high stakers, although
this data could not explore the cause of such overrepresentation. However, it also
found that even high risk players play mainly at low stakes. The white paper gave
fuller consideration to the data, including its limitations. We note that distributions
may have changed as operators’ algorithms and approaches (including voluntary slots
stake limits) have continued to evolve.
Figure 3: % of spins by stake size and operator
assessed harm detection score
Stake size Not flagged Low Medium High Total ≤ £1 63% 22%
12% 2% 100% £1.01 - £2 53% 26% 17% 4% 100% £2.01 - £5 48% 26% 19% 7% 100% £5.01 - £10
41% 25% 22% 11% 100% £10.01 - £20 38% 24% 23% 15% 100% £20.01 - £50 42% 23% 23% 13%
100% £50.01 - £100 35% 18% 29% 19% 100% > £100 36% 20% 21% 23% 100%
Source: Gambling
Commission Data request April 2024
Box 2: Summary of best available statistics about
current slots play The below is based on Gambling Commission market impact data for
2024/23 which covers approximately 80% of the online gambling market by GGY. The mean
stake size is 60 pence
The average online slots session length is 17 minutes, but about
15% of slots sessions last over an hour
The average number of spins per session is
145
The average loss per session is £4.26
The quickest slots game cycles can happen is
every 2.5 seconds, but, we estimate the average spin takes approximately 7
seconds
While there are currently no statutory limits on stakes, most operators offer
minimum stakes of between 1 penny and 10 pence per spin, up to maximum stakes of
between between £10 and £50 per spin. We have heard reports of (but been unable to
confirm) some licensed operators offer spins of up to £500 for certain individuals on
certain games.
Any of the options under consideration will result in a significant
change in the maximum stakes which operators offer. Customers who would have staked
above limits will broadly respond in one or a combination of the ways below. This
depends on a number of factors, including the level at which the stake limit is set,
and each of the possible responses comes with different potential risks or
benefits.
Slots play adjustment. When customers are unable to stake at the level they
wish per spin, some customers may simply play more spins at a lower stake level,
potentially by extending session length or playing more intensely.
Displacement to
other products. The appeal of slots play may diminish for some customers if they are
unable to stake to a certain level, and they may move to other products in the licensed
land-based or online sectors, such as roulette.
Displacement to the black market. While
the risk is not a reason to forgo changes to make licensed products safer and we are
taking wider action to improve the regulator’s ability to disrupt illegal operators, a
proportion of slots players who cannot access their desired stakes in the licensed
sector may turn to unlicensed providers. These providers are easy to access online and
do not offer the wider player protections which are required with a Gambling Commission
licence. We expect the overall black market risk to be higher for the lower limit
options considered below (which are likely to have a greater impact on player behaviour
and spend in the licensed sector).
Spend less overall. Some customers will moderate
their gambling behaviour in response to new limits, and spend less. Our intention is
that particularly those customers who are at risk of incurring harmful losses could
have this prevented or substantially mitigated by playing at lower levels. However, we
recognise those already in the grips of an addiction are the most likely to respond to
the stake limit in other ways than reducing spend.
The information provided to DCMS by
Flutter helps illustrate these potential customer responses. It found that following
the implementation of the £10 limit, the number of stakes between £5 and £10 increased,
suggesting many players simply reduced the stakes they played with, but may have
moderately increased their number of spins to stake the same amount overall. In
Flutter’s experience there was no evidence of displacement to other products, but they
estimate approximately a quarter of the revenue derived from stakes over £10 was lost,
with customers going either to other licensed operators offering higher stakes slot
play or to the black market. A range of other safer gambling measures such as account
level controls and the online slots game design rules were introduced over this period,
making it difficult to measure the impact of stake limits in isolation.
Chapter 4:
Policy options for a maximum stake limit for online slots games to apply to all
adults
The options below relate to the maximum stake limit which would be available to
any adult playing online slots with a licensed operator. Specific controls for young
adults are considered in the next section.
The limit would apply to all slots games
offered by licensed operators, and operators would under no circumstances be allowed to
offer higher stakes, even if customers can provide evidence of lack of harm or their
ability to afford them. As outlined in the white paper, we considered the case for a
tiered limit, but decided on a universal limit given the benefits for speed of
implementation, clarity for businesses and consumers, and lower dependence on wider
harm detection algorithms which we do not yet consider to be sufficiently established
safeguards across all remote operators.
Our intention is that no matter what option is
chosen, there will be future opportunities to review and if necessary adjust the
limits. For instance, on several occasions in previous years, the limits on land-based
gaming machines have been adjusted to reflect the impact of inflation.
Options
Option 1
- A maximum online slots stake limit of £2 per spin As the most restrictive option
under consideration, a £2 stake limit on online slots would have the greatest impact on
consumers and businesses. It would align online slots limits with those on widely
available B3 gaming machines in high street gambling premises such as bookmakers, bingo
halls and arcades, although they have different wider requirements on monitoring and
intervening with players. While 97% of all individual online slot stakes are below £2,
operators have reported to us that as many as 35% of online slot players stake over £2
on at least one spin in a given year. They would not be able to do so within the
licensed sector if this option is chosen. Stakes over £2 currently contribute an
estimated 18% of slots GGY.
Option 2 - A maximum online slots stake limit of £5 per
spin A £5 limit for online slots stakes would align them with the limits on B1 gaming
machines in casinos. This is the highest limit permitted on any land-based gaming
machine at present. Stakes over £5 make up just over 0.5% of all staking events on
online slots, but contribute an estimated 7.4% of slots GGY. Operators have provided
different figures of between 8% and 23% of players currently staking over £5 on at
least one spin per year. These customers would therefore be unable to maintain their
exact current staking pattern in the licensed sector.
Option 3 - A maximum online slots
stake limit of £10 per spin A £10 limit on online slot stakes is higher than that
permitted on any land-based gaming machine. These higher limits are under consideration
due to the account based play online and the associated protections which are not
required or easily replicable in land based products. While one large operator reported
to us that around 12% of its slots players ever stake at £10 or above in a year, the
vast majority will do so only very occasionally, so the disruption to them is unlikely
to be severe. According to the April 2024 data request, around 37% of all stakes placed
above £10 were made by high and medium risk players. Our data suggests around 2.6% of
slots GGY came from stakes over £10.
Option 4 - A maximum online slots stake limit of
£15 per spin A £15 limit on slot stakes would result in the smallest change from how
consumers currently play on online slots, impacting only a small minority of habitually
or occasionally high-staking players. While playing with high stakes does not
necessarily cause harm, the data in figure 3 above does highlight the
overrepresentation of customers identified as at high risk among high stakers. A £15
limit would also have the smallest effect on operator GGY of all the options being
considered. Stakes over £15 make up just 0.05% of all staking events on online slots
and contribute an estimated 2% of GGY.
Consultation question 4: The government is
aiming to introduce a maximum stake limit that strikes an appropriate balance between
preventing harm and preserving consumer freedoms. 4a) What maximum stake limit for
online slot games would you support, if any? (Mandatory response)
[£2 / £5 / £10 / £15
/ None of the above / I don’t know] 4b) Please explain your answer, providing evidence
where possible. (Optional response)
[Open text]
Chapter 5: Considerations and policy
options for protecting young adults using online slots
The age of 18 is widely
recognised as the age at which one becomes an adult, and gains full citizenship rights
and responsibilities. It is the age from which age-restricted products such as alcohol,
tobacco and the full range of gambling activities are permitted. However, in light of
the evidence that young adults (specifically those aged 18 to 24) may be a particularly
vulnerable cohort, the white paper committed to consult on extra slot-specific
protections for this group, as well as lower thresholds for financial risk checks. This
builds on the extra protections for young adults which some operators have already
introduced, but are not consistent across the sector.
According to the Public Health
England Gambling-related harms evidence review, the problem gambling rate in the 16 to
24 age group is 0.8%. This age group also has the highest average Problem Gambling
Severity Index (PGSI) score (0.26) of any age group. The white paper also considered
the evidence on the importance of young adulthood in forming gambling behaviours, and
the concerning links between suicide and problem gambling in young adults.
As set out
in the Gambling Commission’s formal advice to the review, there are a number of
potential factors at play including continuing cognitive development (up to the age of
25), and common life-stage changes such as changing support networks and managing money
for the first time. Other evidence considered during the Act Review highlighted that
adolescents have a greater risk tolerance compared to older adults and this may be
reflected in their attitudes towards gambling. Data included in the Gambling
Commission’s remote customer interaction consultation also shows that those aged 18 to
24 have the lowest average discretionary income of any adult age bracket, so may be
more likely to suffer financial harm from relatively modest losses.
Allied to the
evidence considered above on the product specific risks on online slots, there is a
strong case for slot specific measures for this cohort. However, evidence is limited on
precisely how young adults (as opposed to all adults) currently engage with slots. The
Patterns of Play data in figure 4 below indicates that the typical stake size for
online slots for those aged 18 to 24 is lower than for other age groups (with the mean
in this July 2024 to June 2024 data set being £1.05 compared to £1.30 across all adults
aged 25+), but we lack other important information. We are hoping to address this
through a data request to industry which is being made alongside this consultation and
will inform the government’s response.
Figure 4: £ average stake size by age group
Age
group Mean stake size (£) Median stake size (£) Under 21 £1.11 £0.51 21-24 £0.99 £0.53
25-34 £1.12 £0.57 35-44 £1.08 £0.55 45-54 £1.44 £0.54 55-64 £1.46 £0.50 65-74 £1.21
£0.51 75+ £1.53 £0.50
Source: NatCen Patterns of Play Technical Report 2- Account Data
File: Table 16
Alongside the options for slot specific protections outlined below, the
white paper proposed other protections for young adults gambling online. Specifically,
the thresholds for financial risk checks, where operators will be obliged to consider a
gambler’s spending in the context of their financial circumstances for signs that their
spending is out of control or harmful, are proposed to be lower for younger adults. The
Gambling Commission will shortly be publishing updated guidance on remote customer
interaction which includes specific provisions that operators should ‘have regard to a
customer’s age when considering potential vulnerabilities’. These measures are intended
to provide extra protections for a potentially vulnerable group, without unnecessarily
restricting their ability (as adults) to participate.
Options:
The options considered
below are intended to work as an additional targeted protection beyond the limits
considered above. The appropriate limit for all adults is being considered alongside
the case for extra protections for younger adults, and the stake limit for young adults
will be the same as or lower than the limit for all adults, whatever level is
chosen.
Option A - a maximum online slots stake limit of £2 per spin for 18 to 24 year
olds The best available evidence shows that 18 to 24 year olds typically stake lower
amounts than other age groups, with an average stake 20% lower than the average for all
adults according to Patterns of Play. A £2 limit for this cohort specifically would
therefore be less disruptive than it might be as a general limit, but is still the most
disruptive option being considered.
Option B - a maximum online slots stake limit of £4
per spin for 18 to 24 year olds A young adult-specific £4 limit on online slot stakes
would be less restrictive than the £2 limit on B2/B3 gaming machines. The potential
argument for this is that even while the young adult cohort is potentially vulnerable,
the extra protections around online play including the lower financial risk check
thresholds, could still give greater protection than largely anonymous land-based play.
The limit would still be lower than the £5 stake limit on land-based casino machines,
which is available to all adults.
Option C - Applying the same maximum stake limit to
all adults, but building on wider requirements for operators to consider age as a risk
factor for gambling-related harm Some respondents to the call for evidence argued that
young adults should not be prevented by default from accessing the gambling products
and staking options available to other adults. Instead, they argued that the default
should be to treat all adults in the same way, and that any targeted protections for
young adults instead come ‘behind the scenes’, through operators’ existing obligations
to identify risk. As outlined above, the Commission’s customer interaction guidance
already suggests operators should have regard to a customer’s age when considering
vulnerabilities. Rather than introduce a specific lower stake limit in statute for this
cohort, we could reiterate to industry that limiting customers to only lower stakes
play on certain products is already part of the toolkit of responses at their disposal
when responding to risk on a case-by-case basis. In line with the current outcome based
regime, the Commission could continue to take enforcement action when an operator’s
approach to identified vulnerabilities or risk was not proportionate.
Consultation
question 5: The government is seeking a balanced approach to the protection of young
adults. We recognise the evidence of risks which can accompany potentially vulnerable
young adults gambling on high risk online slots at high stakes, but also that as adults
we must treat those aged 18 to 24 fairly and proportionately. 5a) What maximum stake,
if any, do you support for young adults aged 18-24? (Mandatory response)
[£2 / £4 /
consistent with the limit for all adults but with extra operator vigilance / I don’t
know] 5b) Please explain your answer and reference any relevant supporting evidence if
appropriate. (Optional response)
[Open text]
Chapter 6: Impact
To help inform our
consideration of this issue, we have published a consultation stage impact assessment
alongside this consultation. The IA contains a cost/benefit analysis and consideration
of wider impacts of the options explored in this consultation to help inform responses,
and explores how the chosen measure will be monitored and evaluated following
implementation. A summary of the cost/benefit analysis is provided below.
Figure 5:
summary of estimated GGY impact of options for general online slots stake limits
Option
GGY reduction in £m (central estimate) GGY reduction as a % of online slots GGY in
2024/22 GGY reduction as a % of all remote GGY in 2024/22 Option 1 - A maximum online
slots stake limit of £2 per spin £310m 10.3% 4.8% Option 2 - A maximum online slots
stake limit of £5 per spin £124m 4.1% 1.9% Option 3 - A maximum online slots stake
limit of £10 per spin £39m 1.3% 0.6% Option 4 - A maximum online slots stake limit of
£15 per spin £31m 1.0% 0.5%
Figure 6: summary of estimated GGY impact of options for
slots specific protections for young adults
Option GGY reduction in £m (central
estimate) GGY reduction as a % of online slots GGY in 2024/22 GGY reduction as a % of
all remote GGY in 2024/22 Option A - a maximum online slots stake limit of £2 per spin
for 18 to 24 year olds £18m 0.6% 0.3% Option B - a maximum online slots stake limit of
£4 per spin for 18 to 24 year olds £10m 0.4% 0.2% Option C - Applying the same maximum
stake limit to all adults in statute, but building on wider requirements for operators
to consider age as a risk factor for gambling-related harm TBC - but likely minimal in
addition to impact of the general limit TBC - but likely minimal in addition to impact
of the general limit TBC - but likely minimal in addition to impact of the general
limit
Our economic assessment of the impact of potential changes is limited in some
ways by the lack of available data from the industry, but the Gambling Commission has
issued a formal data request to inform advice to government which will help improve our
estimates. Further, there are difficulties in estimating the precise behavioural
responses to new limits. Alongside the GGY reduction, there may be some other costs to
operators, such as the implementation costs of game development teams needing to adjust
the stake levels on live games. These are explored fully in the IA, and we will include
any new information on impacts in a final stage impact assessment which will be
published alongside the consultation response later this year.
Given the complexity of
gambling-related harms and the role of many different factors in creating or
exacerbating it, we are also unable to accurately estimate how limiting the maximum
stake on online products will in isolation impact the population rates of
gambling-related harm. However, as explored in the impact assessment, we have evidence
that any of the options above will limit the potential for harmful losses from those
gambling at elevated levels of risk or experiencing problem gambling compared to the
status quo of theoretically unlimited stakes.
Consultation question 6: The options
considered throughout this consultation are likely to have significant impacts on both
gambling customers (including those being harmed by gambling) and businesses. Our
impact estimates for each option under consideration are considered in full in the
consultation stage impact assessment. 6a) Are there any additional impact
considerations, including on the assumptions in the accompanying impact assessment, or
on the risk of unintended consequences? (Mandatory response) [Yes / No / I don’t know]
6b) Please explain your answer and provide relevant evidence. We would particularly
welcome input on transition costs, and on the impacts for small and micro businesses.
(Optional response) [Open text]
Consultation question 7: The Department for Culture,
Media and Sport will have due regard to the public sector equality duty, including
considering the impact of these proposals on those who share protected characteristics,
as provided by the Equality Act 2010. 7) Please indicate if you believe any of the
proposals in this Consultation are likely to impact persons who share such protected
characteristics and, if so, please explain which group(s) of persons, what the impact
on any such group might be and if you have any views. (Optional response)
[Open
text]
Consultation question 8: 8) Are there any other factors or points you wish to
highlight that have not been considered above? (Optional response)
[Open
text]
Consultation question 9: 9) Please upload any further supporting evidence that
you wish to share. (Optional response)**
[Upload attachment(s)]
Chapter 7: Summary of
questions
Pre consultation demographic questions Are you responding on behalf of an
organisation or as an individual? (Individual / Organisation / Other [please specify])
If individual What is your age? (0 to 17 / 18 to 24 / 25 to 44 / 45 to 64 / 75 to 84 /
85+ / Prefer not to say) What part of Great Britain do you live in? (England / Scotland
/ Wales / Prefer not to say / Outside of Great Britain [please specify]) Have you
gambled in the past year? (Yes / No/ I don’t know / Prefer not to say) Which of the
following best describes your interest in gambling policy (select up to two options)?
(Gambling industry professional, gambling researcher/academic, gambling treatment
provider, personally harmed by gambling, affected negatively by another person’s
gambling, recreational gambler, government/regulatory professional, other, prefer not
to say) Is any of the information you have provided confidential, commercially
sensitive or otherwise unsuitable for publication (including in anonymised)? If so,
please indicate what. (Free text box) If organisation What is the name of your
organisation? (Free text box) Is the organisation headquartered in Great Britain? (Yes
/ No / I don’t know) Which of the following best represents your organisation’s sector?
(remote gambling industry, land-based gambling industry, both remote and land-based
gambling industry, gambling-related sector (e.g. advertising, sport, or broadcasting),
government/regulator, lived experience peer support charity, academic/research,
treatment provision, trade association, local authority/ licensing board, other, I
don’t know) How many employees does the organisation you are responding on behalf of
have globally? (1-9 / 10-19 / 20-49 / 50- 99 / 100 - 250 / 250 - 499 employees / 500+
employees / I don’t know) Are you happy for government to attribute responses to your
organisation in a published response to this consultation? (Yes / No) Is any of the
information you have provided confidential, commercially sensitive or otherwise
unsuitable for publication (including in anonymised)? If so, please indicate what.
(Free text box)
Consultation questions
Q1) For the purposes of introducing a maximum
stake limit, the government intends to align with the definition of online slots used
by the Gambling Commission. We therefore intend for the limit to apply to: Remote
casino games of a reel-based type (including games that have non-traditional reels or
which combine elements of other games within a slot game mechanic). Q1a) Does this
description of online slots adequately describe the products intended for inclusion in
the maximum stake limit’s scope? (Mandatory response)
[Yes / No / I don’t know] Q1b)
Please explain your answer. (Optional response)
[Open text box]
Q2) The government is
developing a description of a maximum stake. This description will be adapted in
legislation to introduce a maximum stake limit. The proposed description of a maximum
stake is: ‘Maximum stake per spin’ means the maximum amount a player can pay or risk
per spin or game cycle. Q2a) Is this description of stake suitable for the purpose of
the introduction of a maximum stake limit for online slots games? (Mandatory
response)
[Yes/No/I don’t know] Q2b) Please explain your answer. (Optional
response)
[Open text box]
Q3) For the purposes of introducing a maximum stake limit per
spin or game cycle, the government intends to align with the definition of game cycle
used by the Gambling Commission’s Remote Technical Standards. Game cycle is defined as:
A game cycle starts when a player depresses the ‘start button’ or takes equivalent
action to initiate the game and ends when all money or money’s worth staked or won
during the game has been either lost or delivered to, or made available for collection
by the player and the start button or equivalent becomes available to initiate the next
game. Q3a) Is this description of game cycle suitable for the purpose of the
introduction of a maximum stake limit for online slots games? (Mandatory
response)
[Yes/No/I don’t know] Q3b) Please explain your answer. (Optional
response)
[Open text box]
Q4) The government is aiming to introduce a maximum stake
limit that strikes an appropriate balance between preventing harm and preserving
consumer freedoms. Q4a) What maximum stake limit for online slot games would you
support, if any? (Mandatory response)
[£2 / £5 / £10 / £15 / None of the above / I
don’t know] Q4b) Please explain your answer, providing evidence where possible.
(Optional response)
[Open text box]
Q5) The government is seeking a balanced approach
to the protection of young adults. We recognise the evidence of risks which can
accompany potentially vulnerable young adults gambling on high risk online slots at
high stakes, but also that as adults we must treat those aged 18-24 fairly and
proportionately. Q5a) What maximum stake, if any, do you support for young adults aged
18-24? (Mandatory response)
[£2 / £4 / consistent with the limit for all adults but
with extra operator vigilance / None of the above / I don’t know] Q5b) Please explain
your answer and reference any relevant supporting evidence if appropriate. (Optional
response)
[Open text box]
Q6) The options considered throughout this consultation are
likely to have significant impacts on both gambling customers (including those being
harmed by gambling) and businesses. Our impact estimates for each option under
consideration are considered in full in the consultation stage impact assessment. Q6a)
Are there any additional impact considerations, including on the assumptions in the
accompanying impact assessment or on the risk of unintended consequences? (Mandatory
response)
[Yes / No / I don’t know] Q6b) Please explain your answer and provide
relevant evidence. We would particularly welcome input on transition costs and on the
impacts for small and micro businesses. (Optional response)
[Open text box]
Q7) The
Department for Culture, Media and Sport will have due regard to the public sector
equality duty, including considering the impact of these proposals on those who share
protected characteristics, as provided by the Equality Act 2010. These are age,
disability, gender reassignment, marriage and civil partnership, pregnancy and
maternity, race, religion or belief, sex, and sexual orientation. Q7) Please indicate
if you believe any of the proposals in this Consultation are likely to impact persons
who share such protected characteristics and, if so, please explain which group(s) of
persons, what the impact on any such group might be and if you have any views.
(Optional response)
[Open text box]
Q8) Are there any other factors or points you wish
to highlight that have not been considered above? (free text box/ file upload)
(Optional response)
[Open text box]
Q9) Please upload any further supporting evidence
that you wish to share. (Optional response)
Chapter 8: How to respond
Please respond to
this consultation by completing the online response form below:
Start online form
If
you cannot access the link, please send responses to gamblingactreview@dcms.uk in a
document format like PDF or Microsoft Word.
By submitting your responses via email you
are agreeing to the terms outlined in the privacy notice.
We welcome evidence from all
parties with an interest in the way that gambling is regulated in Great Britain. We
also welcome international evidence. The consultation will close at 11:55 pm on 10
October 2024.
Chapter 9: Privacy notice
Who is collecting my data?
The Department for
Culture, Media & Sport (DCMS). DCMS is consulting on policy options for measures
relating to the land-based gambling sector. For the purposes of personal data collected
in the course of this consultation, DCMS is the data controller.
Purposes of this
privacy notice
This notice is provided to meet the obligations as set out in Articles
13 and 14 of the UK General Data Protection Regulation (“UK GDPR”) and the Data
Protection Act 2024 (“the DPA”). This notice sets out how DCMS will use your personal
data as part of our legal obligations with regard to data protection.
What personal
data do we collect?
The personal information we collect and process is the data
provided to us directly by you in the responses to this consultation. As an individual,
this includes: your gender, age bracket and region of residence. As an organisation,
this includes: your organisation name and size. All questions requesting an individuals
personal information offer a ‘prefer not to say’ option.
How will we use your data?
We
will use your data to enable us to carry out our functions as a government department.
Your data will be used to inform the development of policy measures to introduce
maximum stake limits on online slots.
What is the legal basis for processing my
data?
To process this personal data, our legal reason for collecting or processing this
data is:
Article 6(1)(e) of the UK GDPR: to the extent it is necessary to perform a
public task (to carry out a public function or exercise powers set out in law, or to
perform a specific task in the public interest that is set out in law). In this case,
the processing of your personal data is necessary for the performance of a task in the
public interest, as the information gathered helps inform future policies; and
Section
8(d) of the DPA: to the extent it is necessary for the effective performance of a task
carried out in the public interest.
What will happen if I do not provide this data?
You
have the option to select ‘Prefer not to say’ in response to any of the questions that
ask for your personal data.
Who will your data be shared with?
DCMS has commissioned a
third party, Qualtrics, to collect your personal data on its behalf. This means we have
asked Qualtrics to collect your information via an online survey platform, which we
will review as part of the consultation process.
Information provided in response to
this consultation (not including personal information) may be shared with other
government departments and arm’s length bodies, such as the Department for Health and
Social Care and the Gambling Commission. The information provided may be published at
an aggregated or anonymised level in the government’s consultation response, or
disclosed in accordance with the access to information regimes (primarily under the
Freedom of Information Act 2000 and the Environmental Information Regulations 2004)
subject to any applicable exemptions.
Please indicate if any information you provide is
commercially or otherwise sensitive.
How long will my data be held for?
Your personal
data will be kept for one year in line with DCMS retention policy.
Will my data be used
for automated decision making or profiling?
We will not use your data for any automated
decision making.
Will my data be transferred outside the UK and if it is how will it be
protected?
Your data will not be transferred outside the UK.
What are my data
protection rights?
You have rights over your personal data under the UK GDPR and the
Data Protection Act 2024. The Information Commissioner’s Office is the supervisory
authority for data protection legislation, and maintains a full explanation of these
rights on their website DCMS will ensure that we uphold your rights when processing
your personal data.
How do I complain?
The contact details for the data controller’s
Data Protection Officer (DPO) are:
Data Protection Officer
The Department for Culture,
Media & Sport
100 Parliament Street
London
SW1A 2BQ
Email: dpo@dcms.uk
If you’re
unhappy with the way we have handled your personal data and want to make a complaint,
please write to the department’s Data Protection Officer using the details above.
If
you believe that your personal data has been misused or mishandled, you may make a
complaint to the Information Commissioner, who is an independent regulator. You may
also contact them to seek independent advice about data protection, privacy and data
sharing.
Information Commissioner's Office
Wycliffe House Water
Lane
Wilmslow
Cheshire
SK9 5AF
Website: ico.uk
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