8.2.1 Remote Loading via Debit Card and Problem Gambling
In Great Britain, some venues offer the option to pay for bets or to play gaming machines by using a debit card. However, it is important to note that using a debit card directly at the gaming machine terminal is it is prohibited by the Gambling Act, 2006. Instead, debit card payments must be made remotely from the shop counter by a member of staff; this is a process referred to as ‘remote loading’. Remote loading can either be done using cash or debit card. Like Automated Teller Machines (ATMs) and some forms of electronic funds transfer, remote loading using debit card (RLDC) offers access to additional funds direct from a bank account.
There is currently little empirical research which directly examines the link between RLDC and problem gambling. White et al., (2006), in an international stakeholder consultation study, reported that direct electronic fund transfers at a gaming machine was identified as a likely contributor to problem gambling. This payment mode was one of the highest ranked game characteristics that experts viewed as most likely to contribute to problem gambling. Furthermore, out of 76 potential game modifications, experts rated the removal of this payment method as most the important machine modification for reducing problem.
More recently, in Great Britain, there have been suggestions that the short break in play and staff interaction required in RLDC transactions could facilitate self-control, improve
that the requirement to remote load payments for all stakes of £50 or more (see Section 7.1.8 for a detailed description) were in part driven by this rationale (p. 8, DCMS, 2015):
“The intended effect of the policy is that customers will benefit from improved interaction and more conscious decision-making and therefore greater control. Making staff interaction a component of high staking machine play ensures greater opportunities for intervention where patterns of
behaviour indicate that someone may be at risk of harm from their gambling, or for other reasons, such as preventing crime. Stakeholders have indicated regular interaction can give players a reality check.” Further, in a stakeholder consultation reported by Parke et al., (p. 61, 2008), the Association for British Bookmakers (ABB) concluded in their submission that: “...where debit cards are used, there is no greater ‘reality check’ than, having lost your money, to revisit the counter to ask a human to allow you to spend more”.
Further explanation of the theoretical and empirical bases of the claims are required in order to adequately justify this position. Presently, there appears to be a lack of the following:
• Clear guidance in licensing conditions about how and when staff should ‘interact’ with customers who appear to be experiencing gambling problems;
• Valid and reliable evidence that staff are indeed interacting in a timely and effective way and;
• Valid and reliable evidence that staff interaction is having sufficient impact through reducing associated risks and harms, and promoting responsible gambling.
Without further justification, it is not clear that RLDC interactions would necessarily have the harm minimisation impact being suggested. Moving across the shop floor to hand staff a debit card seems unlikely to be sufficient on its own to promote awareness and facilitate self-control among customers.
8.2.2 Remote Loading and Access to Additional Funds
There is a growing body of evidence suggesting that providing access to additional funds in a gambling venue is a potential risk factor for problem gambling. Further, problem gamblers are more likely to use an ATM to withdraw additional funds to continue gambling which may lead to overspending (Blaszczynski, Parke, Rigbye & Parke, 2014; Ladouceur,
Blaszczynski & Moodie, 2008; McMillen, Marshall & Murphy, 2004; White et al., 2006); and withdrawals were also found to be larger and recurrent among problem gamblers
(McMillen, Marshall & Murphy, 2004; Productivity Commission, 1999).
Problem gamblers report that the removal of ATMs from gambling venues is one of the most effective harm minimisation options available (Caraniche Pty Ltd., 2005; Alberta Gaming and Liquor Commission, 2007: as cited in Williams, West and Simpson, 2012). Consistent with this finding, a large-scale evaluation of ATM restrictions has demonstrated a range of initial positive impacts on problem gambling. Specifically, in Victoria, Australia, a ban was reported to be effective in reducing the amount time and money spent, and improving control among moderate and problem gamblers (Thomas, Pfeifer, Moore, Meyer, Yap & Armstrong, 2013). Theoretically, it is argued that without immediate access to additional funds to continue gambling, individuals would need to forward plan spending intentions; a concept comparable to a pre-commitment responsible gambling strategy (Blaszczynski et al., 2014). Gamblers seeking additional funds to continue gambling would need to access an ATM outside the venue; a situation which, depending on proximity, may constitute a break in play (Productivity Commission, 2010). This ‘break-in-play’ argument does have some empirical support. Interviews with problem gamblers in Australia have suggested that the
necessity to leave a venue to get additional funds to continue gambling provides a ‘cooling- off period’ which may allow gamblers the opportunity to consider the implications of their gambling (McMillen et al., 2004; Thomas et al., 2013). One participant stated: “When I’m away from the club I can see the stupidity of it all. In my lucid moments I’m determined not to do it again but it’s all too easy, the way the whole system is set up” (McMillen, et al., 2004, p.168). It should be noted, however, that player interviews revealed that a minority of participants felt that severe problem gambling would persist with less convenient means to obtain more funds for gambling: “Whether the [ATM] machines are there or not is ‘irrelevant’ for serious gamblers who would find other ways of obtaining money if they needed to” (McMillan et al, 2004, p. 168).