In Focus Series: Prevention By Design Report

PREVENTION
BY DESIGN
Putting Consumer Safety at the
Heart of Gambling Brands’ Online
Campaigns & Media Buying

FOREWORD
Simon Mukerjee, Global Partnerships Director, Genius Sports Media
ABOUT THE EVENT
In this, the first event of the new Genius Sports Media In Focus Series, experts
discussed how the betting and gaming sector can prevent an inevitable backlash
against online marketing by addressing the consumer protection challenges –
including media buying at scale – head on.
SPEAKERS
Christie Dennehy-Neil
Head of Policy and Regulatory Affairs,
Internet Advertising Bureau (IAB)
Fiona Palmer
CEO,
GAMSTOP
Gambling – and the marketing services industry
that supports it – finds itself in the middle of a
perfect storm of political, media and public scrutiny
across the world. Problem gambling is a matter
being treated with increasing seriousness by
governments and for marketers and their suppliers,
this is compounded by a broader concern over
digital platforms and their effect on social and
individual wellbeing. So it is not an easy time to
promote a pastime which for the vast majority
of its consumers provides harmless excitement,
entertainment and enjoyment.
opportunity for brands and digital marketing
partners like Genius Sports Media to act together
and promote best practices in responsible
marketing – before the spotlight falls on us.
The first event of our new In Focus series sought
to highlight the reality that creating a safe and
sustainable digital advertising ecosystem for
the vast majority that enjoy gambling, but that
mitigates against exposure to vulnerable audiences
and minors, is not only the right thing to do but is
simply good business.
Christie Dennehy-Neil is Head of Policy &
Regulatory Affairs at IAB UK – the industry
body for digital advertising with over 1,200
members engaged in all forms of online and
mobile advertising, including media owners
and advertising technology businesses.
She works with the sector, both in the UK
and at EU level, to achieve the optimal
policy environment to support a sustainable
future for digital advertising and to help
boost the understanding of digital media
and its benefits within regulatory and
political circles.
Fiona Palmer is CEO of GAMSTOP, the
UK’s national online self-exclusion scheme
which has been running as a multi-operator
solution since April 2018. She has worked
in the online gambling industry for the past
10 years, most recently as Director of Social
Responsibility at the RGA.
Previously she headed up the Compliance
Team at Sky Betting & Gaming where her
passion for social responsibility led her to
become a leading advocate of a number of
cross industry steering groups.
Restrictions on gambling advertising are almost
inevitable, but the extent to which it impacts our
sector remains within our control to some degree.
But only if we can demonstrate collectively that
self-regulation can work and that tightening
regulations or banning certain types of advertising
is unnecessary.
Public and regulatory scrutiny has, to date, largely
focused on TV campaigns and brand sponsorships.
Yet digital marketing is by no means immune.
We need to recognise we have a window of
In the age of data-driven personalisation, we must
harness the tools, technology and expertise at our
disposal to ensure, as far as possible, that online
campaigns are not served to minors or problem
gamblers and that appropriate imagery and
language are used at all times.
A self-regulated and proactive approach to
protecting these demographics, and the reputation
of our sector, is key. As our expert panel rightly
pointed out, it is incumbent on us all as an industry
to demonstrate we can achieve that goal.
Leanda Trethewey
Head of Marketing,
Sky Betting & Gaming
Leanda Trethewey is responsible for driving
the marketing strategy of one of Europe’s
largest betting operators in an increasingly
competitive and regulated market.
Head of Marketing for Sky Betting &
Gaming since 2017, Leanda has over 15
years’ experience in digital marketing,
communications and branding across a
variety of sectors.
Samit Dutta
Head of Digital,
PlayOJO
Samit Dutta is an experienced digital
marketing professional with over 15 years’
experience working across a variety of
industries.
He is currently Head of Digital at PlayOJO,
the fair casino, where he has been since its
launch at the beginning of 2017.
Simon.Mukerjee@geniussportsmedia.com
PAGE 2 PAGE 3

Why is responsible digital advertising
such a big issue for the gambling sector?
Christie: Interest in gambling advertising is to some extent a
microcosm of the increased scrutiny of digital advertising more
broadly. Regulators are extremely interested in it. There is strict
guidance already for gambling advertising, which was updated
earlier this year to give marketers much clearer direction to ensure
that they’re targeting more responsibly and that the creative and
messaging is also appropriate.
We know the UK government is looking at issues relating to gambling
in general and advertising goes hand in hand with that. There’s a
new House of Lords committee looking at gambling harms and I’m
sure advertising will fall under that. It’s often on the political radar
because it’s an issue where you
get a lot of cross-party agreement
about potential risks and harms.
I think there’s a really good
opportunity for marketers and
brands to show that they take these
issues seriously and that they are
taking action to ensure that their
marketing is responsible.
Leanda: This issue isn’t going to
go away. It’s inevitable that more
regulation will come at some point.
As operators we have to think
innovatively about how we operate
differently in that context, so there’s definitely a need for innovation that
allows us to get ahead of future regulation.
We have to think differently about advertising and how we talk to
consumers. They want their bookmaker to act and they want to be able
to trust them. So I think that will encourage all operators to behave
differently in terms of how they communicate and advertise.
‘This issue isn’t going to
go away. It’s inevitable
that more regulation will
come at some point. As
operators we have to
think innovatively about
how we operate.’
5% – growth in
online advertising
spend in 2018 in
the UK
Source: IAB UK
2018 IAB/PwC Digital Adspend
Study
PAGE 4 PAGE 5

ASA Report: Harnessing new technology
to tackle irresponsible gambling ads
targeted at children – April 2019
Using new monitoring technology in the form
of child ‘avatars’ - (online profiles which simulate
children’s browsing activity) - to identify ads that
children see online, the ASA collected data on
the 10,754 times that ads were served to the
child avatars (ad impressions) across 24 children’s
websites and 20 open-access YouTube channels.
In total, it found:
Gambling ads were served to the child avatars on 11 of
the children’s websites monitored
23 individual gambling ads were seen by the child
avatars on those 11 children’s websites a total of 151
times – 1.4% of the total ad impressions
No gambling ads were served on any of the openaccess
YouTube channels included in the research
https://www.asa.org.uk/news/harnessing-new-technology-gambling-ads-children.html
PAGE 6 PAGE 7

How are you approaching the issue
of responsible online marketing?
Samit: The three things that I can boil it down to are restriction,
verification and messaging. We are trying to restrict players through
ad tech and analysing player behaviour to prevent us from marketing to
at risk players or younger players. With verification, we want to be able
to completely prevent any form of marketing to the wrong audiences,
which includes working with providers and platforms in particular. In
terms of messaging, instead of being a tick-box exercise, it has become
one of the first things we look at when we
launch a campaign, so that safer gambling
messaging is embedded throughout.
Fiona: GAMSTOP has proven that
the industry can come together, work
collaboratively and deliver uniformity.
We have well over 97,000 users
registered within the scheme right now. They are being actively
blocked from being able to gamble, so the next natural step is to use
this collaboration to take it to the next level – we need a more holistic,
uniformed approach which includes marketing. The individuals
registered on GAMSTOP don’t want to see marketing from gambling
operators and they shouldn’t be seeing it from those operators who
are integrated with us. However if operators don’t know someone’s
on the register because they’re not a customer of the operator, how
do they know not to market to them?
‘The three things I can boil
it down to are restriction,
verification and messaging.’
97,000+ – no. of
users registered
with GAMSTOP
today
Source: Fiona Palmer, CEO,
GAMSTOP
September 2018
Leanda: For us, it’s about starting with the consumer. We have a
responsibility to take care of people in a vulnerable position, ensuring that
we don’t target or talk to those people in the wrong way. We’ve invested
a lot of time and effort in integrating a system we call ‘Signal’. This gives
us the ability to automatically feed self-exclusion lists through to big ad
platforms, so that people administering the campaigns know that they’re
not going to target self-excluded customers. Now we’re making an active
choice about which platforms we work with on that basis, so ideally we
want to work with digital platforms where we can have first-party data
integration and know that we have confidence around self-exclusion.
The other thing is just about being stringent around age-gating. There are
varying degrees of confidence with the platforms around not targeting
teens. We’ve actually stopped working with some platforms based on a
low level of confidence because we’re not comfortable, and when we’ve
restarted we’ve actually started at +24 because we’re still not wholly
comfortable about the +18 targeting.
PAGE 8 PAGE 9

What are some of the proactive steps
we could be taking as an industry?
Samit: From a player safety point of view, up until a year ago we were
using blacklists which were manually checked every four weeks or
so. We actually got called up by the ASA and I’m extremely glad we
did because it changed the way we operate. At the time I believed
we were advertising in the safest way possible, but it turns out we
weren’t. So what we’ve done now is move to a complete whitelist
model whereby we use category restrictions and then we do manual
checking on all of the sites that get moved onto that whitelist. We’ve
really reduced the amount of inventory discovery we do so we can
keep a handle on what’s happening and it prevents us from getting
onto unsafe sites.
Another major thing we’re trying to do is embed player safety
knowledge across multiple functions. So take the development team
and the marketing team – they might be completely different skillsets
but both teams need to know what is responsible and what isn’t,
so that safety checks are made at every step.
Fiona: Over the past year, we’ve been learning from the data we’ve
received from the consumers who register with us and the data we
receive from thousands of websites to see how we can positively identify
an individual but at the same time enable operators. Currently we have
about 20% of operators integrated, they cleanse their data on a regular
basis to proactively block marketing. We are improving our systems to
enable all operators to be able to do that in
an efficient manner. It’s our intention that by
1st April 2020, all operators will be checking
their databases against our register in order
to proactively prevent marketing to all
registrants of GAMSTOP.
Leanda: In general, the way we advertise will
evolve, we’ve seen some of it already, it’s
moving more towards brand-led space rather
than promos and offers space. A lot of the
time in this sector it’s a race to the bottom in
terms of promotions. It’s pleasing to see that
people connect with consumers in a different way on more of a brand
responsibility level and I think that’s something that will definitely grow.
‘It’s pleasing to see that
people connect with
consumers in a different
way on more of a brand
responsibility level and I
think that’s something that
will definitely grow.’
24% – increase
from 2015 to
2018 in spend of
gambling ‘paid for
advertising’
Source: Interim Synthesis
Report, July 2019
‘The effect of gambling marketing
and advertising on children,
young people and vulnerable
adults.’
PAGE 10 PAGE 11

Does the industry need to
start collaborating more?
What role can the major online platforms
like Facebook and Google play?
Fiona: Our next target is to look at how we can enable responsible advertisers to actually
stop advertising to self-excluded customers. As I say the big challenge for our team is
we’re dealing with licensed entities by having operators integrated with us. Broadening it
to the plethora of advertisers means we need to learn how we do that securely. Are there
other sectors that we can learn from? I don’t think it’s efficient or will help consumers if
we do it on a one-by-one basis. We need to do
this collaboratively, taking a holistic approach,
working with people from outside of our industry
learning from them and their best practices.
Leanda: I think there’s a real opportunity for
collaboration with digital marketing. We’re
all ploughing our own furrow but we have to
come together as a group of operators to tackle
these things together. It’s easy to see this as a
big issue and a huge challenge when actually
there’s a really big opportunity for us to work
‘There’s never been a better
opportunity to say “we’re
acting responsibly to tackle
this”, so we have to see
this as an opportunity to be
proactive, working together
to find solutions.’
collectively together to demonstrate what’s happening in this space. There’s never been
a better opportunity to say ‘we’re acting responsibly’ to tackle this, so we have to see it as
an opportunity to be proactive, working together to find solutions instead of waiting for
things to happen to us. Sharing data around vulnerable customers is vital and there should
definitely be a stronger culture of ‘test and learn’, and sharing those learnings amongst
operators so that we operate more effectively for the benefit of the consumer.
Christie: We all understand that in order for our industry to survive, we need to deal with
challenges collaboratively to get the right solutions. The government aren’t experts in this
area. They don’t know a lot about digital advertising and they don’t understand it because
that’s not their background or area of expertise. The more that we can explain to them what
we’re doing and demonstrate that it’s effective, by talking to them about measures like
whitelists and age-gating, it demonstrates that we’re managing it properly. It’s important
that if there are going to be regulatory interventions, they’re evidence led, which in lots of
aspects of digital advertising there is quite a high risk that they aren’t. Don’t underestimate
the value of educating regulators and governments so that the factors are properly
understood. The risks for people who struggle with gambling are high, but that’s not the
majority of the population, so it means that you need to design your solutions proportionally.
Samit: When I moved into this industry I found it refreshing that there
were open conversations with the ad platforms - rather than being
dictated to. You’re involved and can have adult conversations about
what’s happening and you have the ability to dictate your own future.
For us, we get face time with Google and they’re receptive to what we
have to say. With Facebook we struggle because our spend might be
lower, but if we act collectively, as an industry, it would allow smaller
operators to have their opinions heard.
Leanda: With Facebook, they’ve been slightly behind the curve in
understanding how they respond to this stuff. We’ve been helping
them with how they approach responsible gambling – not just from an
educational perspective but from what we need the platform to be able
to do to give us the confidence to be able to keep using it. The challenge
is we’re all doing that separately as businesses which puts pressure
on limited resources so it’s about how we have a joint approach.
Collectively we’re spending a lot on these platforms so we have a lot of
weight if we do it together rather than us working in silos.
Christie: From my experience, these platforms are well aware of this
regulatory scrutiny; I think we’re pushing at an open door, as clients it’s
absolutely right that you guys are driving this. You need to be confident
advertising on these platforms and if you’re not, you don’t spend there
and that’s exactly how it should be. That’s what governments and
regulators want to see – you being a responsible brand. There’s an
interesting challenge to work out how you can use data responsibly and
securely, because on the one hand you’re trying to do the right thing,
but also there’s challenges around how you’re permitted to use data.
Even using data for exclusion can inadvertently become problematic and
potentially not comply with the law.
‘Collectively we’re spending a
lot on these platforms so we
have a lot of weight if we do it
together from a commercial
perspective, rather than us
working in silos.’
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FOR MORE INFORMATION
Simon.Mukerjee@geniussportsmedia.com
@geniussportsmedia
geniussportsmedia.com
contactus@geniussportsmedia.com