Privacy Notice
GamProtect is a project to ensure that people who tell us that they are at high risk from gambling related harm to their health are protected. To do this Participating Operators that provide online gambling products will take steps to identify customers who they believe should not be gambling and share some key customer information with the GamProtect system. Participating Operators will use GamProtect to identify whether the same customer has an account with them and proceed to close their account to reduce the potential for harm.
This privacy notice explains how Participating Operators in the GamProtect trial project use your personal data. You can see which operators are participating in the GamProtect trial project by going to the Participating Operators section of this notice.
There are 3 key stakeholders in this process that are defined below:
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The “Closing Operator”: this is the Participating Operator that closes your account and can be any of the Participating Operators.
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“GamProtect”: this is the system that allows for secure data sharing between all operators in a way that ensures privacy. They will receive customer data from the Participating Operators on a daily basis.
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The “Receiving Operators”: these are the Participating Operators who receive a match from the data that is shared by the Closing Operator to GamProtect and the Receiving Operator’s own customer database. If the Receiving Operator and the Closing Operator have the same customer, then they will take a similar action to protect their shared customer e.g., closing the customer’s account.
The Receiving Operator will not know the specific reason why the Closing Operator has shared data with them via GamProtect. If your personal data has been shared with GamProtect and you would like to find out why, please contact the Closing Operator. You will receive an email from the Closing Operator informing you that your details will be shared with GamProtect.
How does the GamProtect Trial Work?
Risk Identification
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Participating Operators will identify a player as at risk of health-related problem gambling if the player states that they:
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Have a gambling problem or addiction.
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Are seeking external support or treatment for gambling problems.
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Will harm themselves or someone else.
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Should not be gambling because they have a medical condition.
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Want to stop gambling forever due to problems with their gambling.
Initial Account Closure
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Once a Participating Operator has identified a player as at risk of health-related problem gambling, it will close all of the player’s accounts and exclude the player from all of its gambling services.
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It will also inform the player that they will be added to GamProtect due to issues with health-related problem gambling.
Registration
The Participating Operator will add the following Registration Data about the player to GamProtect:
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Full Name
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Surname
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Date of Birth
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Post Code
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Email address
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Telephone number
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Unique Customer ID set by Participating Operators
Matching
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Each Participating Operator will routinely check all their current players’ details against the details of the players previously added to GamProtect by scanning their customer database against the system.
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If a player who is playing with one Participating Operator has been previously added to GamProtect by another Participating Operator, GamProtect will provide the Participating Operator carrying out the GamProtect check with the following information about the player ():
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Status as added to GamProtect.
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A flag to indicate that the players account has been closed by the Closing Operator because it meets one of the criteria of the project.
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Name of Participating Operator that added the player to GamProtect.
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Further Account Closures
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When a Participating Operator is informed by GamProtect that a player has been identified as being at risk of issues with health-related problem gambling, it will close all the player’s accounts with the company.
Initial active Period
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A player will remain on GamProtect and subject to the matching process initially for a period of [five years] from the date they were first added by a Participating Operator. This is known as the .
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During the active period all Participating Operators will exclude the player from their gambling services.
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The player cannot remove themselves from GamProtect during the active period.
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However, if a player thinks they have been added to GamProtect incorrectly, they can follow the GamProtect redress process explained below.
Further Active Period
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At the end of the active period (if the player is not removed from GamProtect by the redress process), the player will remain on GamProtect and subject to the matching process for a further active period.
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During this further active period all the Participating Operators will continue to exclude the player from their gambling services.
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The player can remove themselves from GamProtect at any time during the further active period by contacting the Participating Operator that has prevented them from accessing gambling services using the contact details below.
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However, if the player does not remove themselves from GamProtect, the further active period will continue (and they will remain excluded from all Participating Operators’ gambling services) for a period of 35 years.
Archive Period
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Following the end of the further active period (either by request or expiry), the player’s details will be held for an archive period of seven years.
Reidentification of Risk
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If during a further active period or archive period a Participating Operator re-identifies a player as at risk of health-related problem gambling, the Participating Operator will re-add the player to GamProtect and the active period will restart.
Categories of personal data to be processed as part of the GamProtect trial
Purpose & Legal Basis
Participating Operators will process customer’s personal data for the primary purpose of identifying customers with health-related issues with problem gambling that are common to any other
Participating Operator and attempting to protect extremely vulnerable people from gambling related harm across those common Operators. This involves:
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Communicating with a customer to identify a potential harm.
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Closing, suspending or restricting the customer’s account.
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Sharing customer personal data with GamProtect.
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Searching for customers who have been registered on GamProtect.
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Evaluating the ongoing effectiveness of the GamProtect solution.
The legal basis for the purpose we have described is the Participating Operator’s legitimate interests in protecting customers from harm. Specifically, these interests are:
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To improve intervention for people suffering from health-related problem gambling issues.
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To share the identification of players who are suffering health-related problem gambling issues.
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To provide greater insight into effective ways of reducing people in the UK from suffering health-related problem gambling issues.
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A proportionate approach to the identification of people in the UK from suffering health-related problem gambling issues and protect customers without unduly infringing their rights and freedoms.
Special category personal data is personal data that can reveal health data and other sensitive information about a person. As the scheme is designed to detect and prevent health-related problem gambling the GamProtect trial data is considered to be special category personal data. Where the processing of customer data involves special category data the legal basis for the Participating Operator’s processing this data is substantial public interests. The substantial public interests are outlined in the UK Data Protection Act 2018 as: safeguarding of children and of individuals at risk.
Recipients of the data
Customer data will be shared with the GamProtect system which is owned and provided by Tutelar Limited. (“TUTELAR”) and its subcontractors The Data Shed Limited (Hippo) and Amazon Web Services. We can be compelled to share information within GamProtect with regulators and law enforcement agencies at their request. Participating Operators will also share the flag indicating a health-related problem gambling issue associated with a customer with other Participating Operators. If a Participating Operator ceases to exist, they will share the specific reasons why a customer’s data has been shared to GamProtect with another Participating Operator who will be elected at the time to hold the Closing Operators GamProtect records. Any player impacted by this action will be informed directly by the elected Operator.
We will transfer your personal data to GamProtect who will then confirm matches with the other Participating Operators. We have implemented Standard Contractual Clauses with appropriate addendums to protect the personal data during the transfer.
Data Retention
Redress process
If you believe you have been added to GamProtect incorrectly, please contact the Participating Operator that is preventing you from accessing online gambling services using the contact details below. The Participating Operator will then take you through these steps –
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If that Participating Operator added you to GamProtect, it will consider your concerns and decide whether or not to remove you from GamProtect.
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If the Participating Operator that is preventing you from accessing gambling services did add you to GamProtect, it will provide you with the contact details of the Participating Operator that did add your details to GamProtect.
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The Participating Operator that did add your details to GamProtect will then consider your concerns and decide whether or not to remove you from GamProtect.
If the company which added your details is no longer participating in GamProtect, you can instead follow the redress process with the Participating Operator whose gambling services you wish to access.
Removal from GamProtect
In addition to the redress process, following the end of the active period, you can ask to be removed from GamProtect at any time by contacting the Participating Operator that has prevented you from accessing gambling services using the contact details below.
Please note that even after your removal from GamProtect, individual Participating Operators may still independently decide to prevent you from accessing their gambling services.
Data Protection Rights
You have the following rights in respect of your personal data processed for the purposes of GamProtect –
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Access to your personal data
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Correct or update your personal data
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Object to the use of your personal data
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Erasure of your personal data
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of the use of your personal data
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Complain to the Information Commissioner’s Office
You should be aware that these rights are not absolute and do not apply in every situation. You can find out more information about these rights on the website of the Information Commissioner’s Office here.
If you would like to exercise any of these rights, please contact the Participating Operator that has prevented you from accessing gambling services using the contact details below.
If you would like to make a complaint, you can send a letter or email to the relevant address above or contact the Information Commissioner’s Office.
GamProtect does not involve processing of solely automated decisions that produce legal or similarly significant affects.
For information on the data controllers please click this link
Scope
This notice only applies to the use of personal data for GamProtect. For further information about how Participating Operators use personal data more generally, please see the privacy policies in the ‘contact’ section above.
Changes to this policy
We may need to update this notice from time to time, including as we develop GamProtect with the other Participating Operators. Where this notice changes, we will take appropriate steps to bring the change to your attention. You can also see the date of the notice along with the date of its latest update below.