Problem Gambling - ATM | EFTPOS Functions and Capabilities 

• 1.1 Introduction
• 1.2 Key themes
• 1.3 Moving forward
• 1.4 Recommendations

1.1 Introduction

In 1998 the Productivity Commission was asked to undertake the first national independent inquiry into the economic and social impacts of the gambling industries and the effects of the different regulatory structures that surround those industries. One of the key recommendations of the subsequent report was the establishment of Ministerial Council on Gambling. The Commonwealth also established a National Advisory Body on Gambling to provide advice on gambling issues. In December 1999 the Prime Minister announced the establishment of the Ministerial Council on Gambling with specific accountability for:

• stopping the further expansion of gambling in Australia;
• the impacts of problem gambling on families and communities
• Internet gambling; and
• consumer protection.

The Commonwealth response to problem gambling is co-ordinated through the Department of Family and Community Services (FACS). This project commissioned by FACS is the first step in the process of investigation to inform policy development in relation to access to cash through ATM and EFTPOS facilities within gambling environments.

The purpose of the investigation undertaken by KPMG Consulting was to:

• provide comprehensive information on current and future Automatic Teller Machine (ATM) and EFTPOS functionality; and
• to inform the development of a national harm minimisation strategy on specific initiatives available or possible to limit access to cash and credit through ATM and EFTPOS in gambling environments.

The research is indicative of a more holistic approach by the Commonwealth to addressing the impacts of problem gambling in the wider community. The focus is very much on engaging all parties associated with the provision of gambling, including the ATM and EFTPOS operators, who provide facilities to service consumers within these environments.

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1.2 Key themes

• There is an increasing recognition that Governments have an obligation to protect the vulnerable through strategies to minimise the harm that arises as a result of problem gambling.
• Technological change is so rapid that it is unlikely that the focus on the device (ATMs and EFTPOS) and its associated regulation is sustainable as a strategy to minimise the harm that results from problem gambling for the individual, their families and the wider community.
• Ultimately the device (ATMs and EFTPOS and gaming machines) will become irrelevant as technology moves to cashless transactions.
• There is a lack of clear research to inform and substantiate the current array of harm minimisation strategies. Rather the strategies tend to have evolved from untested assumptions based in response to the rapidly emerging concern regarding the likely relationship between access to funds in gaming environments and problem gambling.
• Potential solutions will be multi dimensional involving a range of sectors with differing viewpoints and business objectives, and frequently in conflict.
• The needs of the social gambler need to be considered concurrently with those of the problem gambler.
• There is emerging community recognition of shared responsibility with the growing recognition of social obligations within this arena for all stakeholders.

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1.3 Moving forward

There is a substantial level of agreement across the industry¹ for the need for a national operational approach, with all stakeholders accepting they have community service obligations towards minimising problem gambling.

It is important that the next steps build on the current commitment and momentum that has been generated through this project. In addition, given the lack of evidence to support the effectiveness of strategies associated with limiting cash and access to credit, an agreed approach would provide the framework within which to track and monitor the full range of strategies.

A range of opportunities exist to build on current activities and maximise shared responsibility across the industry in responding to problem gambling within the context of access to cash and credit. These include:

• The development of a national operational approach that establishes the parameters to guide informed decisions and choices on the array of potential options and arrangements.
• A shift away from the control of problem gambling through ATM and EFTPOS device focused strategies towards a broader focus on access to accounts for the means of securing cash and/or credit.
• The development of a strategy in relation to access to cash and credit within gaming locations.
• A focus on prevention through the curtailment of the deployment of new technologies that could be seen as problematic and providing extended opportunities unnecessarily to either increase access to cash and credit and gaming as well as potential implications for providers, devices and facilities.
• Exploration of the concept of shared responsibility with all relevant stakeholders taking greater responsibility and accountability for the development, implementation and ongoing maintenance of harm minimisation strategies within gaming environments.
• Reviewing legislation that guides the location of ATMs in the gaming environment.
• Development of specific and targeted education strategies with regard to the use of ATM and EFTPOS facilities within gaming environments and the use of ATM facilities to present messaging and information with regard to problem gambling.
• The provision of a range of self-help strategies within gaming environments to assist the problem gambler to manage their behaviour.

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1.4 Recommendations

Recommendation 1: That the Commonwealth government in conjunction with the states and territories, and in consultation with the industry sectors and the community sector, establish a national operational approach to provide the context within which states develop and implement harm minimisation strategies for problem gambling within the context of access to cash and/or credit.

Recommendation 2: That such an approach provide guidance on:

• the parameters within which strategies can be considered, for example the impact of various strategies on rural communities and relationships to other government agendas and policy directions;
• key consultative mechanisms and processes including identification of critical stakeholders;
• the concept of shared responsibility;
• access to international literature, global benchmarks, research, and organisational contacts;
• identification of any current best practice;
• effective cost benefit analysis;
• appropriate monitoring and review mechanisms;
• structures for sharing information across jurisdictions; and
• the identification of accountability for compliance.

Recommendation 3: That the agreed approach shift emphasis away from the control of problem gambling through device focussed strategies towards a broader focus on the individual’s access to accounts for the means of securing cash and/or credit.

Recommendation 4: Within the approach identified in recommendation 3, there needs to be the development of a strategy in relation to access to cash and credit within gaming locations. Such a strategy should incorporate:

• customer access to funds within their accounts;
• access defined at the account and device level;
• monitoring and control of the introduction of new technologies for cash and/or credit accessibility within the gaming environment; and
• technology around gaming.

Recommendation 5: That the Commonwealth move to negotiate with the states and territories to implement policy to curtail the deployment of technologies that would be considered problematic within the context of managing the negative impacts of problem gambling in the community. That this not be exclusive of a range of technologies but specifically include:

• the use of Smart Cards and 3G mobile phone technology;
• Poker machines with in built EFTPOS;
• E.bank;
• M.bank/m.commerce;
• Wireless technology such as Bluetooth; and
• ATMs with in built gaming capacity.

Recommendation 6: That the Commonwealth government, in conjunction with the states and territories, liaise with the key stakeholder groups to establish clarity with regard to roles and responsibilities within the harm minimisation and social responsibility context. Within this context discussion should occur as to the most appropriate strategies for which the various stakeholders should take primary responsibility.

Recommendation 7: That the Commonwealth government undertake a review of the location and placement of ATMs with regard to their proximity to gaming areas to ensure that the intent of the legislation is being adhered to. Such a review may consider increasing requirements to ensure ATMs are not in visible sight of patrons in the gaming area.

Recommendation 8: That the Commonwealth government negotiate with the states and territories to ensure that all ATMs that serve gaming locations do not enable access to credit accounts.

Recommendation 9: That the Commonwealth government, in conjunction with the states and territories, negotiate with the financial services industry to generate in cooperation with other stakeholders, marketing literature specifically targeted to gaming locations including ATM screen messages, dispensing of ATM leaflets and the printing of messages on ATM and EFTPOS receipts.

Recommendation 10: That the Commonwealth government, in conjunction with the states and territories, negotiate with the financial services sector to develop an educational strategy targeted at informing the general community of ATM and EFTPOS functionality within gaming environments.

Recommendation 11: That the Commonwealth government, in conjunction with the states and territories, negotiate with the financial services sector to develop a strategy that supports self-help strategies for banking consumers who require assistance in managing finances as a result of gaming issues.

1. Industry refers to all the sectors involved in the discussion and management of problem gambling, that is the financial services sector, the community sector, the gaming industry and the regulators within the various states and territories.