ICO’s provisional green light of Gambling Commission’s Single Customer View raises important issues for gambling operators, their officers, and bettors
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The Gambling Commission is participating in the ICO's Regulatory Sandbox. The ICO gave the commission the green light for the Single Customer View (SCV). SCV would allow data gathered by gambling operators regarding individual player behaviours to be aggregated and shared with other operators.
ICO's Sandbox service is intended to support organisations developing products or services that use personal data in innovative and safe ways. ICO and the Gambling Commission will work together to establish if there is an appropriate lawful basis under Article 6 of the UK General Data Protection Regulation (UK GDPR) for sharing of behavioural data between online gambling operators via SCV.
ICO’s provisional green light of Gambling Commission's Single Customer View raises important issues for gambling operators, their officers, and bettors. ICO will consider the application of Article 6 of the UK General Data Protection Regulation (UK GDPR) and the processing of special category personal data.
ICO has given the go ahead to Gambling Commission’s Single Customer View. SCV aims to drive better decision making, actions and evaluation to reduce gambling related harms across all online gambling operators. The exact data set and datapoints that online betting operators will be expected to provide is still to be confirmed.
ICO’s provisional green light of Gambling Commission's Single Customer View raises important issues for gambling operators, their officers, and bettors.
The ICO concluded that the processing and sharing of behavioural data between gambling operators may be lawful under Article 6 (1)(e) (Public Task) or Article (6 (f) (Legitimate Interests). Both legal bases provide a discretionary gateway to the data processing. ICO’s provisional green light of Gambling Commission's Single Customer View raises important issues for gambling operator, their officers and bettors.
The ICO considers that some elements of the data proposed to be processed via the SCV may qualify as special category data. The UK GDPR prohibits the processing of special categories without an Article 9 processing condition.
The GC has been advised that the data protection implications of any wider data sets intended to be used or shared in the SCV should be considered separately.
ICO is clear that public task or legitimate interest may be relied on by gambling operators to share data with SCV. Right to object is not absolute, but operators need to explain this in their privacy information. If legitimate interests are to be used, a legitimate concerns assessment (LIA) will be required. ICO’s view that some elements of the data processed by SCVs may also be special category data. It will require careful consideration and analysis by all industry participants to ensure lawful processing conditions are satisfied. In an industry where successful gamblers regularly face account restrictions, it will also need careful documentation.
The Gambling Commission’s Single Customer View raises important issues for gambling operators, their officers, and bettors. ICO”s steers apply only to behavioural data. The SCV software underpinning the solution is well-advanced. It will be vital that the final software undergoes thorough testing and is closely monitored. If non-compliance could be met with significant fines under the UK GDPR. . .. In the Gabbling Act, an offence committed by a body of persons corporate or unincorporate (other than a partnership) shall be punishable by up to three years in prison.
