Compliance

The purpose of this document is to provide information on the advertising casino related products to UK customers with regard to acceptable marketing and advertising procedures.

As a UK customer facing website, moveyourmoney.org.uk aim is to ensure that all advertising is done in responsible manner and according to the rules and regulations issued by the relevant authorities.

Table of contents

Legislation we comply with

All the content on moveyourmoney.org.uk website complies with:

  1. The Gambling Act 2005
  2. The Licence Conditions and Codes of Practice (LCCP),issued by the UK Gambling Commission (UKGC)
  3. The CAP Code, issued by the Advertising Standards Authority (ASA)
  4. The Industry Code for Socially Responsible Gambling, issued by the Industry Group for Responsible Gambling (IGRG)
  5. ThePrivacyandElectronicCommunicationsRegulations(PECR),issued by the Information Commissioner’s Office (ICO)

Regulators

The advertising of gambling products is strictly regulated within the UK. That is why, we make sure that all materials are fully compliant and unchanged as provided by the online casino operator.

UK Gambling commission

The UKGC was set up under the Gambling Act 2005 to regulate gambling and issue licenses to casino operators.

Advertising Standards Authority (ASA)

The ASA is the UK advertising regulator. Its sister organization Comitee of Advertising practice (CAP).

Information Commissioners Officers (ICO)

ICO’s aim is to protect data privacy for individuals while promoting openness for public bodies. The ICO will ensure that all applicable legislation is complied with, those of particular applicability for online casino sites are:

  1. The Data Protection Act 2018
  2. The Privacy and Electronic Communications Regulations (PECR) 2018
  3. The Electronic Identification and Trust Services for Electronic

Transactions in the Internal Market and Repealing Directive (eIDAS) 2014

  1. The Network and Information Systems Regulations 2018
  2. The Freedom of Information and Data Protection Regulations 2004
  3. The General Data Protection Regulation (GDPR) 2018
  4. The Re-use of Public Sector Information Regulations 2015

Industry Group for Responsible Gambling (IGRG)

The IGRG organization main goal is to in to promote socially responsible gambling across all gambling sectors in the UK

Content / Marketing communications compliance

As a UK audience facing website, moveyourmoney.org.uk publishes content that is fully compliant with the applicable legislation. Particular attention is given to:

  1. Illegal content (copyrighted content)

Gambling Marketing materials not placed on any pages / microsites, promoting “piracy” services such as illegal downloading of copyrighted content such as music and films. No such content is published on our site.

  1. Responsible gambling pages

No advertising material is placed on any primary pages / microsites providing advice or information on responsible gambling.

  1. Key Terms and Conditions

a) The word “Free” – When anything “Free” is advertised (i.e. Free spins, free play etc.), the main terms and conditions and the commitments that customers must make to take advantage of such an offer must be stated in the advertisement itself.

b) Full T&C on one click away – Online marketing directs the customers to a source where all terms and conditions of the offer are stated, which is no further than one click away from the marketing material.

c) Significant limitations in case of space limitations – If the marketing material is limited by space, all significant terms are listed.

d) Significant Limitations – All significant limitations and qualifications are clearly visible. Qualifications can clarify but must not contradict the claims that they qualify.

4. Marketing communications

Moveyourmoney website DOES NOT send emails, sms, push notifications or engage in ANY form of direct marketing as defined by Regulation 22 of the ICO’s PECR.

The only source of traffic (website visitors) is Google Organic search where customers search for keywords and Google offers pages from our sites to visitors to click thru.

5. Key Content Information

a) Social Responsibility and Harm

All gambling advertising must be socially responsible. Advertisers must respect the need to protect children, young persons and other vulnerable persons from being harmed or exploited by advertising that features or promotes gambling.

b) Children and Young People

Marketing communications for gambling products must be socially responsible, with regards to the need to protect children, young persons and other vulnerable persons.

Moveyourmoney.org.uk does not have any materials that appeal to underage persons including but not limited to:

  • Free casino games;
  • Pictures of people that seem to be under 25 years old;
  • Pictures of toys related to games;
  • Any content appealing to underage or vulnerable audience

An example of a content appealing to vunreable audience is a page about “Casinos not on Gamstop”. Such type of content is strictly prohibited for publishing on our site.

All the content on moveyourmoney.org.uk website does not in any way not exploit the susceptibilities, aspirations, credulity, inexperience or lack of knowledge of children, young persons or other vulnerable person

Marketing communications must not include a child or young person. No-one who is or seems to be under 25 years old may be featured gambling. No-one may behave in an adolescent, juvenile or loutish way.

c) Seduction, Sexual Success, Enhance Attractiveness and Personal Qualities

Marketing must never link gambling with seduction, sexual success or enhanced attractiveness. It is acceptable to feature attractive people in marketing collateral as long as the advert does not link gambling with seduction, sexual success or enhanced attractiveness.

Where characters in promotional material are treated with admiration by others as a result of their gambling, this can breach regulations by linking gambling and enhanced attractiveness, improved self-image or self-esteem.

d) Problem Gambling Behaviour, Taking Priority

Suggesting that gambling is a solution to debt and financial concerns or an alternative to employment is socially irresponsible and a breach of social responsibility codes.

Therefore, all the content on our website will never suggest such statements or appeal to vulnerable audience such as unemployed, poor people. A list of “negative” statements is constantly monitored and updated to make sure, none of them is ever used in any marketing communications. Some of these statements are: “You will make money”, “You will win”, “You will earn income” and many others.

e) Misleadingness

Marketing communications must state all significant limitations and qualifications. These must always be prominently displayed with an advertised offer. Marketing communications that are limited by time/space must include as much information about significant terms as practicable; online ads must also direct consumers to a source where the full terms are stated, which must be no further than one click away from the ad. See 3. Key Terms and Conditions

f) Vulnerability

We consider if marketing campaigns might affect vulnerable groups and ensure that communications do not contain content likely to cause harm. For instance, the evidence strongly suggests that younger men, aged 18-34, are at heightened risk of irresponsible gambling behaviour.

g) Erroneous Perception of Risk and Control

All Marketing communications on our websites avoid approaches that give erroneous perceptions of the level of risk involved or the extent of a gambler’s control over a bet or gambling in general.

Implying that an activity is without risk, portrayals of risk that are unrepresentative or placing undue emphasis on the extent of control afforded by a facility like ‘cash-out’ are likely to encourage irresponsible  gambling behaviour.

h) Impulsiveness and Urgency

In order not to encourage irresponsible gambling behaviour, marketing communications must not unduly pressure the audience to gamble, especially when gambling opportunities offered are subject to a significant time limitation.

Therefore we ensure that the following keywords are NOT used in our marketing communications:

  • Play Now
  • Limited offer
  • Offer expires today
  • And other terms that suggest urgency

i) Trivialisation

We avoid approaches that trivialise gambling and DO NOT suggest that the decision to gamble should be taken lightly. For example, we:

  • Do not encourage repetitive or frequent participation;
  • Do not encourage people to gamble more than they otherwise would;
  • Do exercise caution when encouraging people to take advantage of promotions or opening accounts; and
  • Do not encourage people to spend more than they can afford.

j) Problem Gambling Behaviour and Other Indicators

We DO NOT publish any marketing communications that display problem gambling behaviours such as:

  • Protacted play;
  • Chasing loses;
  • Losing track of time;
  • mood swings (including, highs and lows, irritability and shortness of temper);
  • manipulative, dishonest, disruptive, secretive or evasive behaviour;
  • detachment from surroundings;
  • preoccupation with gambling; and
  • isolating oneself from others or avoiding other activities to spend more time gambling.
  • And any others that suggest problem gambling behaviour

Significant Terms applying to ALL promotions

  • How to participate, including any costs or factors likely to influence consumers’ understanding of the promotion;
  • An explanation of any ‘Free Route’ entry;
  • Applicable start and closing dates;
  • Any proof of purchase requirements;
  • The nature and number of any prizes or gifts, or a reasonable estimate if the number cannot be determined;
  • The existence of any restrictions or limitations, e.g. age, date or geographical restrictions
  • Any limitations of availability;
  • Unless obvious, the promoter’s name and address.

Our Methodology

To ensure that all content is compliant at all times we have implemented the following process:

Content creation -> Content compliance -> Content Publishing

Content creation

Our online casino authors write the content according to the above standards and principles. Before eligible for writing each author passes a questionnaire for compliance which includes examples of both compliant and non-compliant marketing communications. Content writers are encouraged to contact our compliance manager if in doubt.

Content Compliance  

After the content is written, it is sent to our compliance manager who carefully checks for ALL points under Moveyourmoney compliance above. Namely: Illegal content (copyrighted content), Responsible gambling pages, Key Terms and Conditions, Social Responsibility and Harm, Children and Young People, Seduction, Sexual Success, Enhance Attractiveness and Personal Qualities, Problem Gambling Behaviour, Taking Priority, Misleadingness, Vulnerability, Erroneous Perception of Risk and Control, Impulsiveness and Urgency, Trivialisation, Problem Gambling Behaviour and Other Indicators.

Content Publishing

After all content and marketing communications are approved by our compliance manager, content publishers upload the content to our site and inform the team by completing the task in our project management software. This way, all team members are aware that the content is published.

Examples

1) Targeted players

Examples: New players only / Existing players only / Selected players only

2) Deposit info

Examples: No deposit required / Min deposit £xx etc

3) Information about offer and promotion codes

Examples: 100% match on 1st deposit up to £xx etc / 1 Free Spin for every £1 deposited up to 50 / 10% cashback on losses up to £50 / Use code: xxxx

4) Wagering requirements

Examples: 35x Wagering requirement / No wagering on Free Spins

5) Expiry information

Examples: 3-day expiry on Free Spins / Offer expires on xx.xx.2017 etc.

6) Info about bet limitations

Examples: Min bet £xx / Max bet £xx when playing with a bonus etc

7) Deposit and withdrawal info

Examples: £10 min deposit + 2.5% fee (min 50p) / £20 min withdrawal + £2.50 fee

8) Game restrictions

Examples: Free spins on Starburst / selected games only etc

9) Info about additional terms

Examples: Full terms apply

 

Sources

A full list of all codes, guidelines, legislation and regulatory bodies mentioned in this guide. This is not an exhaustive list of applicable legislation or regulations and should not be used as such. All links correct at time of publishing.

Industry Codes and Guidelines

The Licence Conditions and Codes of Practice (LCCP)

https://www.gamblingcommission.gov.uk/PDF/LCCP/Licence-conditions-and-codes-

of-practice.pdf

The CAP Code

https://www.asa.org.uk/uploads/assets/uploaded/c981689d-505e-4edf-

848bf469eb67198e.pdf

  1. The Industry Code for Socially Responsible Gambling

http://igrg.org.uk/wp/wp-content/uploads/2019/01/Gambling-Industry-Code-for- Socially-Responsible-Advertising-5th-Edition.pdf

General Applicable Legislation

  1. The Gambling Act 2005

http://www.legislation.gov.uk/ukpga/2005/19/pdfs/ukpga_20050019_en.pdf

  1. The Data Protection Act 2018

http://www.legislation.gov.uk/ukpga/2018/12/contents/enacted

  1. The Privacy and Electronic Communications Regulations (PECR)

https://ico.org.uk/media/for-organisations/guide-to-pecr-2-4.pdf

  1. The Electronic Identification and Trust Services for Electronic Transactions in the Internal Market and Repealing Directive (eIDAS) 2014 http://www.legislation.gov.uk/uksi/2019/89/made
  2. The Freedom of Information and Data Protection Regulations 2004

http://www.legislation.gov.uk/uksi/2018/506/made

  1. The General Data Protection Regulation (GDPR) 2018

http://www.legislation.gov.uk/ukpga/2018/12/pdfs/ukpga_20180012_en.pdf

  1. The Re-use of Public Sector Information Regulations 2015

http://www.legislation.gov.uk/uksi/2015/1415/contents/made

Regulatory bodies

  1. The UK Gambling Commission (UKGC)

https://www.gamblingcommission.gov.uk/home.aspx

  1. The Advertising Standards Authority (ASA)

https://www.asa.org.uk/

  1. The Information Commissioner’s Office (ICO)

https://ico.org.uk/

  1. The Industry Group for Responsible Gambling

http://igrg.org.uk/