There are a myriad of strategies that have been identified through this project that are currently in place or being considered. However a key finding has been that there does not seem to be any research undertaken by government or independent parties to measure the impact of any responsible gambling and harm minimisation measures, particularly in relation to ATM and EFTPOS initiatives. In addition, the preliminary impact analysis regarding cost and customer service would indicate that there are substantial implications in these areas associated with various strategies.
As such we have not sought to recommend to substantially increase the range of strategies in place, but rather for the government to consider the development of a framework within which to guide decisions within this arena, in particular, mechanisms to assess appropriateness and effectiveness of strategies.
The following recommendations focus on the development of a national approach to harm minimisation strategies regarding access to cash and credit. The recommendations focus on harm reduction and prevention of further harm, incorporating strategies that encourage and support the industry segments to share responsibility for problem gambling, including the curtailment of further deployment of new technologies, access to credit facilities and a range of educational and self help strategies. It is important that the strategies are not seen in isolation as each area of recommendation builds on the previous.
10.1 Development of a national operational approach
With the establishment of appropriate parameters there will be substantial capacity for governments to make informed choices on the array of potential options and arrangements. The establishment of a national operational approach would provide a foundation on which to base the way forward for the government response in this area. As such the subsequent recommendations provide opportunities for more immediate action at relatively low cost to stakeholders and minimum disruption to consumers at a wider level.
A national operational approach should constitute an advisory document that helps states/territories determine which strategies are most appropriate. Such an approach would provide guidance with regard to:
- 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;
- guidance regarding effective cost benefit analysis;
- guidance regarding appropriate monitoring and review mechanisms;
- structures for sharing information across jurisdictions; and
- identification of accountability for compliance.
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.
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
- identification of accountability for compliance.
All stakeholders agree that legislation particular to device types can at best only have a limited short-term impact. As new gaming and financial services technology emerges government would be faced with continually needing to adopt new legislation. As such it is recommended that the focus shift away from the control of problem gambling through device focussed strategies towards a broader focus on access to accounts for the means of securing cash.
Recommendation 3: That the 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.
Recommendation 4: Within the approach in recommendation 3 there needs to be the development of a strategy in relation to access to cash 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 accessibility within the gaming environment; and
- technology around gaming.
The approach needs to recognise that all providers are not covered by the same governing bodies – eg, bankers and non banking operators and that amongst financial institutions there is a marked difference in the scale of operation between the top four banks and the other financial institutions.
Technically, the potential solutions put forward as part of the research can be implemented with varying degrees of ease and capacity. For example the tracking and monitoring of transactions may appear an effective measure to minimise access, however it would be premature to recommend the implementation of any such measures given the significant investment required and the lack of empirical evidence indicating the likely success. Therefore the recommendations below provide opportunities for more immediate action or enhancement of existing capacities.
Within this context the recommendations focus on two key areas, further prevention of problem gambling and harm reduction strategies to minimise harm to those already with a problem.
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10.2 Prevention – curtailment of deployment of new technologies
Within the context of a more holistic approach to problem gambling there is scope to implement strategies that curtail the deployment of new technologies that could be seen as problematic and providing extended opportunities unnecessarily to either increase access to cash and gaming as well as potential implications for providers, devices and facilities. For example poker machines with inbuilt EFTPOS facilities and ATMs with inbuilt gaming capability substantially increase a person’s access to funds for the direct purpose of gaming. It is therefore proposed that regulation and/or policy be implemented that identifies these technologies and severely curtails or prohibits their introduction into the wider gaming environment. Specifically such regulation should apply to:
- the use of Smart cards and 3G mobile phone technology; - clubs are developing loyalty schemes given the potential of smart card technology to support these schemes. The ramifications are significant for regulators seeking to control access to funds.
- poker machines with in built EFTPOS;
- E bank;
- Wireless technologies such as Bluetooth;
- M.bank/m.commerce; and
- ATMs with inbuilt gaming capacity.
Recommendation 5: That the Commonwealth move to negotiate with the states/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 technologies such as Bluetooth; and
- ATMs with in built gaming capacity.
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10.3 Harm reduction – shared responsibility
There is no real clarity with regard to the roles and responsibilities of the various stakeholders across the sectors and as such the application of changes and the introduction of strategies have fallen on various stakeholders to differing degrees. It is clear that all relevant stakeholders need to take accountability for the development, implementation and ongoing maintenance of harm minimisation strategies within and external to gaming locations. All stakeholders have expressed a willingness to participate in the development of strategies and believe it is important for them to partake in establishing a reform agenda. A starting point would be to consider the following as a part of the shared responsibility mandate:
- hoteliers to ensure the responsible use by patrons of gaming facilities. This includes ensuring monitoring and controlling access not only to cash on the premises but also to the gaming devices themselves. This is fully in line with current responsibilities for the sale and consumption of alcohol on the premises;
- banks to take on increased responsibilities with regard to targeted marketing information, both around the use of ATMs in the gaming environments and through messaging on receipts and leaflets; and
- poker machine operators/owners – a percentage of the revenues generated from the machines could be deployed into cash access strategies, equally sharing responsibility with the banks. This could operate on similar lines to liquor license arrangements.
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 could occur as to the most appropriate strategies the various stakeholders should take primary responsibility for.
10.3.1 ATM functionality
Current legislation requires that banks do not locate ATMs in designated gaming areas. In reality ATMs are often to be found at the entrance to, or in close proximity to gaming areas. Clearly this is in keeping with the law, however not potentially with the intent or spirit of the law. This policy needs to be reviewed as the purpose of the legislation was to remove ready access in and around gaming locations and there is a strong view that this is not being achieved. Current legislation is not clear as to who has direct day-to-day responsibility for the location of the machine. Consideration should be given to strategies that place ATMs at a defined distance away, and not in line of sight to the gaming area.
Recommendation 7: That the Commonwealth government, in conjunction with the states and territories, 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.
10.3.2 Removing access to credit facilities
As part of the commitment to responsible lending in the community financial service providers as a general principle do not make available the credit card functions on ATMs located within gaming areas. There are anomalies whereby retailers insist on the credit function being available to customers. There is already in place a national policy not to provide cash advances through EFTPOS. It is therefore recommended that credit facilities be turned off in all gaming locations. Credit is defined as credit accounts and the ability to raise credit facilities eg, loans, further credit cards. It does not include overdrafts or redraw facilities as discussed previously. It is considered that established daily cash withdrawal limits already cover access to overdrafts and redraw facilities.
This recommendation builds on established industry practices.
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.
10.3.3 Education strategies
There is clear opportunity for more specific and targeted education of consumers around ATM/EFTPOS facilities. Given the current technology this can take the form of ATM screen messaging including presentation of help numbers and warning messages. Messages could also inform the customer around transactions, for example cash limits and the length of time they have been in the gaming venue.
ATMs could dispense information leaflets in the form of vouchers as part of the cash transactions. This could carry similar information/messages as above. Similarly, the EFTPOS could print receipts with help numbers and messages.
In addition, specific education could be undertaken by the banks with regard to the use of ATM and EFTPOS machines in gaming locations that educates the community on ATM and EFTPOS provisions and why they may be different within the gaming environment. This could be marketed within the context of social responsibility and responsiveness to problem gambling.
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.
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10.3.4 Self Help strategies
Ultimately the problem gambler is required to share some responsibility in dealing with their gambling behaviour. There are ranges of strategies in this area that are being implemented overseas and could be considered here. They include the individual implementing a self-exclusion deed whereby the individual excludes themselves from the ATMs in all casinos and gaming environments. Further, there is already capacity for individuals to place withdrawal limits on specific accounts. This allows people some capacity to address their own behaviour whilst not negatively impacting on the broader community group.
It is therefore recommended that these capacities form part of the discussions with the industry and be considered in the full range of educational strategies.
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.