Cashless play in UK bingo: Two paradoxes in the use of player surveillance tools
Cashless play in UK bingo: Two paradoxes in the use of player surveillance tools.[1
Professor Kate
Bedford, Birmingham Law School, University of Birmingham, UK.
Email:
k.bedford@bham.ac.uk
How to cite:
Bedford K. (2020). Cashless play in UK bingo: Two paradoxes in the use of player surveillance tools. Critical Gambling Studies. https://doi.org/10.29173/cgs49
Introduction
What can bingo can
add to our academic, law, and policy debates about gambling and political
economy? [2]
I have been trying, for a while now, to make the case that bingo matters to
academics - in its own right (it is a globally-significant, popular, though under-researched
form of play that has historically been central to the development of gambling
law and policy) - and because it offers a new lens on broader concerns about
diverse economies, and the ways in which they are shaped by law. Like many
other authors interested in this new journal, I spend much of my time arguing that
the concerns of mainstream gambling studies are too narrow.
In this blog post, however, I want to share some thoughts about an issue
that is absolutely central to mainstream gambling studies: responsible gambling
(RG). In particular, I want to think about the role of cash use in responsible
gambling, given the widespread claim that registered play, associated with card
use, can be an effective harm reduction tool.[3] In
a shortened version of an argument that I make in my book, Bingo Capitalism, I suggest that critical gambling
scholars need to think carefully about player tracking as a solution to
excessive gambling. The short
version of my argument is this: I am worried about the fact that states and
academics – not just businesses - are increasingly motivated to gather, and
extract value from, gambling data, and I am unconvinced that it will help
matters. Because cash use helps players to limit spending, account-based play may
even be counterproductive, undercutting
long-established mechanisms for regulating excessive play. Specifically, I identify two paradoxes
that emerge from consideration of bingo in the UK, both of which under-cut the
promise of account-based play to foster responsible play: 1. the safety of
cash, and 2. the additional risks posed by online play.
The Broader Academic and Policy Debate
 |
| Image from https://www.basisonline.org/2 1 |
Some academics are very supportive of player
tracking.[4] However, others are more sceptical, on the
grounds that surveillance technologies to monitor and shape the habits of players
have a dual, and arguably inherently conflictual role: to enable more effective
marketing so as to accelerate consumption, while also promising to increase
safety.[5]
In my research on the UK bingo sector, I seek to
further dampen the ‘hype and hope’ (Rieder & Simon, 2016, p. 4) about how
technology will resolve problematic gambling, by troubling the joint
state/researcher faith in algorithms on which it rests. This faith rests on the
promise that player tracking technologies will provide real-time feedback, find
patterns that cannot be detected by human cognition, distil them into
predictive analytics, and generate new policy solutions (van Dijck,
2014; Yeung, 2017a, 2017b). I draw instead on more critical accounts of big
data that doubt the ability of algorithms to access truths about social life,
and that question the desirability of subsequent measures to identify or
pre-empt risk (Rieder & Simon, 2016; Yeung, 2017a, 2017b; Scholz, 2012). One
key insight from these accounts is that big data is not just of interest to
companies. Data produced by consumers can also be a resource for employers,
police (Andrejevic, 2012, p. 160), regulators, and academics (Boyd &
Crawford, 2012; van Dijck, 2014). For many critics, it is the ‘inextricable
knot’ of commercial, state, and researcher interests in metadata that explains
the proliferation of tracking, and associated efforts to convince the general
public that continuous surveillance is in our collective interests (van Dijck
2014, p. 203). Applying these insights to gambling studies should lead us to pause
in our embrace of cashless play as a SR mechanism.
Social Responsibility
in UK Commercial Bingo Halls and the growing emphasis on Player Tracking.
 |
Photo by Alison
Turner
Almost unanimously, when interviewees from the
UK’s licensed bingo sector were asked about problem gambling, they said that it
was rare, and mostly concerned gambling machines. Generally, staff tended to be cautious about
intervening, because they feared offending customers. However, they did
intervene, often because they genuinely cared about helping people to get
better, and sometimes, also, because the distress manifest was upsetting other
customers, and/or causing complaints from family members. In the past, before
SR had become a regulatory priority in the UK, informal but regularized
mechanisms included ‘having
a chat’;
telling someone to go home or to only come in with family or friends; refusing
to serve alcohol to someone with a gambling problem; and ‘letting someone know
you are keeping an eye’. Staff also used measures equivalent to ‘imposed
self-exclusion’ (where players with problems are identified by staff and barred)
and ‘third party self-exclusion’
(where family members request that a player be barred and cut off from
marketing).[6]
The reliance on informal measures that gave hall
managers considerable discretion to design solutions in negotiation with
players and their families has now given way to formal procedures mandated by
legally binding codes. Since the 2005 Gambling
Act came into effect
in the UK, in September 2007, SR has become a key regulatory priority impacting the gambling
industry as a whole.[7] The
same approaches to SR are being rolled out across different gambling sectors,
and practices are increasingly standardized.
Moreover, the growing regulatory concern with SR
has led to efforts to track players at an individual and aggregate level, via
new technologies. In 2014, the national regulator, the Gambling Commission,
launched a research initiative using loyalty card and anonymous transactional
machine data, to see if there were technology driven measures that could
minimize harmful play without impacting on those who do not exhibit harmful
behaviours (see Department for Culture, Media and Sport 2014, and
discussion in Miers 2015). The government also placed a requirement on larger
betting shop operators to offer account based play. The move was welcomed by
many observers, including some academics. The
Responsible Gambling Trust funded further research into the topic (Forrest &
McHale, 2016).
In turn, cashless play is now being recommended
in all sectors by the Gambling Commission, as part of the joint state and
researcher faith that algorithms can access truths about gambling much more
accurately than people can. Specifically, ‘anonymous play’ (with cash) is now
framed as a SR problem, in part because it makes sector-wide
self-exclusion policies harder to implement. In 2015, a Commission document
announcing stricter SR codes for licensees opened with a foreword from
organization’s then-chair, Philip Graf, which laid out the case against cash on
money laundering and harm prevention grounds:
“the anonymity currently
inherent in cash-based gambling makes identifying and reducing harm much more
challenging than it otherwise might be. It hampers research into the causes of
harm and cost effective ways of mitigating it. And it makes more advanced
player protection measures, such as feedback from patterns of play over time
and associated operator action, virtually impossible to introduce effectively.
It is also important to recognise that for some customers—those engaged in the
disposal of criminal assets or fruits of the black economy—anonymity is highly
attractive. Added to this, we are now in a world where new forms of harm
reduction, based on data analytics, are becoming possible….Account-based or
registered play—with the ability to link play to identified players over
time—offers opportunities to identify those who potentially might be at risk of
harm.” (Gambling Commission 2015a: 3)
Although Graf noted opposition to player
tracking, stemming from concerns about privacy and the personal freedom to
dispose of funds that have been acquired legitimately, he stated that
these are for Parliament, not the regulator, to address (2015, p. 4).
As a result, ‘anonymous’ (cash-based) play was identified
as a problem to be managed, in part due to the faith that player tracking—at
both the aggregate and individual level—will reduce harmful gambling and
prevent money laundering. The gambling industry was warned
that unless they voluntarily engaged with the regulator to address this
problem, in the way proposed by the regulator (player-tracking), even stricter
technological solutions may be imposed (Gambling Commission, 2015, p. 5). In 2018, GambleAware invited bids for a new
research package on consumer vulnerability that is reliant on player tracking,
and—in turn—on cashless play (Responsible Gambling Strategy Board, 2018). The Gambling Commission’s current
website guidance on Cashless payment technologies in gambling premises reiterates that new technologies for player tracking
provide new opportunities for harm reduction.
Paradox 1: Cash may be safer, and/or less anonymous.
The first problem with this framing is that,
broadly speaking, cash can be a useful technology for limiting spending in
gambling: once it is gone it is not topped up. Conversely card use speeds up
play and induces automaticity, in part by reducing interruptions. When cash
money is turned into credit, it is more likely to get psychically separated off
into a non-fungible form considered only viable for use in the exchange zone of
the machine (Schüll, 2012, p. 56). This is perhaps why the casino sector has
tried to encourage card use, or creation of credits, and why some problem
gambling treatment providers recommend reliance on cash as a harm minimization
measure. GambleAware’s
own leaflet ‘Staying in control’ advises:
Don’t take your bank card with you. This is a
good way to safeguard your money limit and not let being ‘in the moment’ warp your judgement.
Similarly, the Gambling Commission’s webpage on
cashless payments mentions research showing “that non-cash payment methods in
gambling can lead to consumers over-spending, as such methods require less
thinking about the actual cost and affordability implications of a
transaction…compared to cash payments” (2019). Earlier this year, the Commission announced a ban on the use of credit cards for all forms of remote
gambling, and for non-remote betting (the conditions for non-remote bingo and
adult gaming centre licenses already prevented operators from accepting
payments by credit card). This awareness of the risks of credit card use
sits awkwardly with the enthusiasm for account-based play expressed by the same
organizations.
Moving from gambling in general to bingo specifically,
it becomes clear that in this sector cash-using players are not anonymous. In
contrast, they may be well-known regulars. Their play may be opaque to data
tracking systems, and central regulators, but it is easily legible within the
hall, and staff are able to monitor it; they know precisely who is calling them
over to change notes for coins to feed into side games, for example. In this
regard staff hope that their cash-related interactions with bingo hall members
can guide them as to whether people are experiencing problems. They have no
such faith in player tracking technologies. Indeed, many interviewees were
critical of moves to player tracking, given the low-risks associated with
bingo, and the fact that its distinctive player demographic has a strong
attachment to cash. As scholars exploring the demographics of the ‘unbanked’
have noted, cash is accessible for otherwise financially marginalized groups,[8] including older people, women, and people on
low incomes – precisely the demographic that dominates bingo. Indeed, many
bingo players come with set amounts of cash for the session, leaving coins out
for their side games or machine play for example. The idea that these are
especially risky players, from a money laundering or problem gambling point of
view, struck many in the bingo sector as absurd.
Paradox 2: Online
bingo becomes the model for social responsibility.
Many land-based bingo staff in the UK point
resentfully to the inverse relationship between the lower levels of harm caused
by their products, and the freer rein given to online operators who are able to
offer product mixes prohibited in brick and mortar halls (including card games
such as poker, and online roulette). Moreover, online bingo is seen as more
risky in part because players can easily lose track of spending. These concerns have made their way into
political debate: for example, MPs have spoken in Westminster’s
Parliament of constituents who had struggled with online bingo addictions, criticizing
the lack of spending limits, the difficulty of closing accounts, and the
continued marketing directed at people who had tried to stop playing.[9]
Despite these concerns, due to the regulatory
embrace of player tracking solutions to SR a paradox has emerged whereby online
bingo—long seen as more risky than land-based play—is being (re)positioned as
safe, because its technologies enable greater surveillance. Regulators and
land-based bingo operators are at odds here, with the latter sometimes
incredulous that the online sector is being seen to offer SR lessons. One land-based
bingo expert insisted that underage players would ‘last five minutes’ if they
tried to enter a hall, ‘Coz somebody would spot them and they would be removed’
(Interview A29), whereas with access to a payment card they could play online. Hence
in a Q&A session with the Gambling
Commission at a 2015 bingo industry meeting, one irritated land-based operator
challenged the regulator on the failure to control online play, stating ‘The
problem is online! Not the bricks and mortar.’ The answer from the Commission
was that ‘Online is traceable. Every single transaction.’ The fact that the
online player is completely transparent—far more so than their land-based
counterpart—is a ‘very valuable asset for regulatory interventions’
(fieldnotes). For online operators and regulators, traceability through
centralized player tracking systems is key; for halls, what matters is other
ways of ‘seeing’.
Conclusion
Put bluntly, I agree with the hall managers that
players are probably safer in halls, and that technologies being heralded as SR
aids may make problematic gambling worse. The danger is that people will be
ported into cashless, account based forms of play that purport to be safer, but
that actually undermine existing mechanisms for regulating spending.
More broadly, however, these measures are of concern
because they further entrench governmental and researcher faith in algorithmic
approaches, and the online technologies of which they are a part, to resolve
social problems. In this regard the promotion of cashless, account-based play
reflects the broader capture of the regulator (and some gambling academics) by technological imaginaries about perfect
surveillance via electronic payments. In this respect, the embrace of player tracking
technologies within bingo offers a compelling example of the multiple
investments being made in metadata.
In this, wider, sense, while I am concerned
about measures being proposed to track bingo players because of what they mean
for bingo players, I am also worried about the more general implications of the
faith in algorithms to protect us from harm. That faith is not only misplaced,
but also counterproductive. The power of algorithmic approaches is in part that
they eclipse alternative regulatory solutions, and it is for this reason that
the joint state/researcher interests in player tracking technologies need to be
critically interrogated—because they may well lead to further exploitation, while
problematizing the everyday behaviours of already marginalized, stigmatized
groups of consumers. These approaches are also fundamentally opposed to the
epistemological values that should inform qualitative approaches to gambling, such as the need for
contextualized data, deep immersion in the field of enquiry, and listening
carefully to people with most on-the-ground experience. In this respect the
desire to port bingo players away from cash is important beyond bingo. Those
with deep insider knowledge tell us that cash use helps regulate spending, and
that online play is more harmful. But the embrace of data-driven solutions
leads to regulatory recommendations for opposite approaches. At issue here is
not just a way of playing bingo, but also an orientation to knowledge that
links together the state, researchers, and dominant sectors of the gambling
industry in new and potentially harmful ways.
References
Andrejevic, M. (2012). ‘Estranged Free
Labor’. In Digital Labor, edited by
Trebor Scholz, 150–64. New York: Routledge.
Bagnall, J., & Flood, D. (2011). Cash Use in Australia: New Survey Evidence (pp.
55-62). Bulletin, September: Reserve Bank of Australia.
Bedford, K. (2015). Regulating Volunteers:
Lessons from the Bingo Halls. Law and
Social Inquiry, 40(2), 461-490.
Bedford, K. (2018). Regulation and Resistance
in Canadian Bingo: A Socio-Legal Account. Journal
of Law and Social Policy, 30,
11-35.
Bedford, K. (2019). Bingo Capitalism: The Law and Political Economy of Everyday Gambling.
Oxford: Oxford University Press, Law and Society series.
Bedford, K., & Shieber, A. (2018b).
Regulating Everyday Gambling: A Photo-essay. Feminists@law 8(1), 1-12.
Boyd, D., & Crawford, K.
(2012). Critical questions for big data. Information, Communication &
Society, 15(5), 662-679.
Forrest, D., & McHale, I. G. (2016). Tracked Play on B1 Gaming Machines in
British Casinos. The Responsible Gambling Trust Machines Research Programme
(June). Available here: https://about.gambleaware.org/media/1300/tracked-play-revision-26–6-16.pdf
Fung, B., Huynh, K. P., & Stuber, G. (2015).
‘The Use of Cash in Canada’. Bank of
Canada Review, (spring), 45-56.
Gainsbury, S. (2011). Player
account-based gambling: potentials for behaviour-based research methodologies. International
Gambling Studies, 11(2), 153-171.
Gambling Commission (2015). Proposed Amendments to Licence Conditions
and Codes of Practice for All Operators in Relation to the Prevention of Crime
Associated with Gambling. Consultation (September). Department for Culture,
Media and Sport. London: Stationery Office.
Gambling Commission (2019). Cashless payment technologies in gambling
premises. Retrieved from https://www.gamblingcommission.gov.uk/for-gambling-businesses/Compliance/General-compliance/Social-responsibility/Cashless-payment-technologies.aspx.
Last accessed November 2019.
Griffiths, M. (2014). The
use of behavioural tracking methodologies in the study of online
gambling. SAGE Research Methods Cases.doi:10.4135/978144627305013517480
Miers, D. (2015). Regulation and
the management of risk in commercial gambling in Great Britain. International
Gambling Studies, 15(3), 422-434.
Parke, J., Rigbye, J., & Parke, A. (2008).
Cashless and Card-Based Technologies in
Gambling: A Review of the Literature. Salford: University of Salford.
Available at:
http://usir.salford.ac.uk/18206/1/Review_Cashless_Card_Technology_Gambling_Parke_2008.pdf
Reith, G. (2016). “Gambling 2”: A Political Economy of Mobile and Social Gambling.
Paper presented at the conference All Bets Are Off: Reflecting Critically on
Gambling Regulation Within and Across Borders, University of Kent, Canterbury.
23 June.
Reith, G., & the Scottish Centre for
Social Research (ScotCen). (2006). Research
on the Social Impacts of Gambling: Final Report. Edinburgh: Scottish
Government.
Responsible Gambling Strategy Board (2018). Research Brief: Using industry data to
understand patterns of play. Revised version. Available here: https://about.gambleaware.org/media/1749/3-patterns-of-playfinalresearchbrief22062018rgsb.pdf
Rieder, G., & Simon, J.
(2016). Datatrust: Or, the political quest for numerical evidence and the
epistemologies of Big Data. Big Data & Society, 3(1), 1-6.
Scholz, T. (2012a). Digital Labor. New York: Routledge
Schüll, N. (2012). Addiction by Design: Machine Gambling in Las Vegas. Princeton:
Princeton University Press.
Squires, G. (2009). ‘Inequality and Access to
Financial Services’. In Consumer Credit,
Debt and Bankruptcy: Comparative and International Perspectivedited by
Johanna Niemi, Iain Ramsay, and William C. Whitford, 11–30. Oxford: Hart.
The Bingo Project (2016). The Bingo Project: Final Report.
Available at https://www.kent.ac.uk/thebingoproject/resources/Bingo_Project_report_final.pdf.
Van Dijck, J. (2014). Datafication, dataism
and dataveillance: Big data between scientific paradigm and ideology. Surveillance & Society 12(2),
197–208.
Yeung, K. (2017a). Algorithmic Regulation: A Critical Interrogation. Social Science
Research Network SSRN Scholarly Paper ID 2972505 26
https://papers.ssrn.com/abstract=2972505.
Yeung, K. (2017b). “Hypernudge”: Big data as
a mode of regulation by design. Information,
Communication & Society, 20(1), 118–36.
[1] This blog post is an
expanded version of an argument about player tracking and cash use that I first
published in Bedford 2018 (b). A longer version of the argument is contained in
Bedford 2019.
[2] See e.g. Bedford, K.
2015; 2018. For the relevance of bingo to law and policy debates, see Bingo
Project 2016.
[3] In other work I have
explored other dimensions of cash use, including the requirement for workers
(paid and unpaid) to show ‘clean hands’ after touching cash in B.C. bingo
halls. See Bedford, K. 2018.
[4] E.g. Gainsbury 2011; Griffiths 2014; Parke et al. 2008.
[5] E.g. Schüll 2012: 276. On personalized
advertising as a feature of mobile gaming platforms, shaped by algorithms that
learn from the time, place, and type of play, see Reith 2016.
[6] Within gambling
studies, such measures are considered to be at the extreme end of interventions
designed to protect adults from themselves; see Reith and Scottish Centre for
Social Research
(ScotCen) 2006: 71; Hancock 2011: 149, 226.
[7] I discuss the
legislative, regulatory, and case law dimensions of this shift in some depth in
the book.
[8] See e.g. Squires 2009:
22; Fung Huynh and Stuber 2015; Bagnall and Flood 2011.
[9] See Hansard reports including Jessica Morden in
574 Parl. Deb. HC (6th ser.) (30 January 2014) col. 1001; see also 492 Parl.
Deb. HC (6th ser.) (13 May 2009) cols.
964–83.
Comments
Post a Comment