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DETAILS OF ADR PROCESS

What Gambling complaints can be taken to ADR?

The ADR Regulations require only certain types of complaints to be taken to ADR. The Gambling Commission call these ‘disputes’. The European ADR Directive states that it applies to “disputes between consumers and businesses concerning contractual obligations in sales or services contracts, both online and offline”

In the gambling sector, the Gambling Commission has defined complaints and disputes as follows:

Gambling-related complaint

An expression of dissatisfaction made to the gambling business by any means, about any aspect of the way the business conducts the activities for which they hold a GB licence. For example, a complaint:

•  about the outcome of a gambling transaction/contract
• about the way a gambling transaction has been managed
• that concerns the way the licence holder carries out its business in relation to the three licensing objectives.

Gambling businesses have to take specific actions and meet certain standards when they handle gambling related complaints. This is a requirement of their gambling licence.

What is a Dispute?

A dispute is a particular type of gambling-related complaint. It is a complaint about contractual obligations in sales or services contracts or about the customer’s gambling transaction (including management of the transaction and related customer accounts) that has not been resolved through the gambling business’s complaints procedure.

For example, a dispute might be an unresolved complaint:

•  linked to the terms of a bonus offer that the consumer has taken up, or to other terms and conditions
• about the consumer’s ability to manage his or her account
• about the consumer’s ability to access his or her deposited funds or winnings.

Disputes are the only type of complaints that may be taken to ADR under this policy.

Non-gambling (non-contractual) complaint

An expression of dissatisfaction made to the gambling business by any means about any matter that is not related to the gambling activities. Such complaints, which do not pose a risk to the licensing objectives, do not fall under the scope of this policy. For example, a complaint about the:

• quality of food available on the premises
• range of products offered in the premises or online
• dress code of a member of staff.

Non-gambling complaints, although important to consumers and to businesses, do not link to the requirements of the gambling licence. Gambling businesses have to decide for themselves how they should resolve such complaints.

Sometimes it can be difficult to tell whether a complaint is gambling-related. For example, a complaint about poor customer service or poorly trained staff manning a telephone or online chat may not appear to be gambling-related. However, it might be gambling-related if the poor service makes it difficult or impossible for the consumer to promptly raise concerns or make a complaint about a contractual matter. Where the type of complaint is unclear, it is generally better to at least initially treat it as a gambling-related complaint.

Transparency

The Gambling Commission requires us as an ADR body which make decisions to provide copies of evidence relied upon to the complainant:

As an ADR provider we will determine what method(s) of dispute resolution to use during a dispute. We identify the key issues and seek additional information from either party to the dispute to clarify information they have already supplied.

For example, if the provider identifies a gap in the evidence it is acceptable to ask either party to the dispute about the gap and for information that fills it. As an ADR provider does not have an investigatory role beyond this. It would not be acceptable for us as an ADR provider to undertake an investigation that went beyond clarifying the information supplied by the parties to the dispute.

The outcome of the ADR process will not supersede the gambling consumer’s right to refer a dispute about a gambling transaction to court if the consumer does not agree with the gambling business or the provider’s decision. This right originates with the Gambling Act 2005 and is also contained in the ADR Regulations (Schedule 3, 8(c)).

ADR Regulations – requirements for ADR providers to disclose evidence

The ADR Regulations require an ADR provider to disclose to a party to a dispute on request the arguments, evidence, documents and facts put forward by the other party (ADR Regulations Schedule 3, 7(b)) as part of the requirements under fairness.

In the gambling industry, we as an ADR provider have to ensure consumers are made aware of this right so that they can consider whether to exercise it.

Please note the following:

• other legislation such as the General Data Protection Regulation (GDPR) would prevent disclosure of certain information, in which case, the provider may redact the information (see also paragraph 2.22 below).
• neither party to the dispute is obliged to provide information to the provider.However, any information they do provide could be disclosed.
• if either party refuses to provide information, then the ADR provider should attemptto resolve the dispute based on the information that it has.
• Providers are also obliged to follow other relevant regulations, for example, the GDPR and Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Player) Regulations 2017 (Money laundering regulations) where appropriate. Providers can find some general information on GDPR on our website. More information is available from the Information Commissioner’s Office (ICO), which is responsible for enforcing data protection legislation and issuing guidance on it.

Grounds for Refusal to Deal with A Dispute

• The Grounds for refusing to deal with a gambling dispute are set out here:

Binding Outcomes

• The outcome of the dispute process is binding on both parties if the consumer agrees with the outcome for disputes which would otherwise be taken to the small claims court (disputes of not more than £10,000). The ADR procedure is not binding for disputes over £10,000. This will allow, for example, for mediation to be employed for larger figures, or for adjudication decisions to be non-binding.
• If the consumer does not agree with the outcome, they may choose to take the matter to an appropriate court.

Reconsidering the outcome of the dispute resolution process

• We recognise that there may be times when we may receive information relevant to the outcome of a dispute after the outcome has been issued. For example, the consumer may provide an email that we as the ADR provider have not seen before. The existence of a new email in itself would not necessarily be grounds to reopen a dispute. But if the email contained new information that impacted on the dispute, then we will consider whether the dispute should be reopened.

• Summary of Commission and ADR Regulation requirements for updating consumers during a dispute.

  ADR Regulations’ Life of dispute Commission’s Requirements requirements

  Under the new standards we are expected by the GC  to:

  • acknowledge receipt of the consumer’s initial contact within 3 working days. This may be done as part of the requirement to notify the consumer of their right to withdraw, and of their rights around independent legal advice, as per the requirements of the ADR Regulations.

  • The ADR Regulations require us as an ADR providers to provide parties to a dispute with certain information during the course of the dispute. We must:

    • notify all parties to a dispute as soon as we have received all of the information that makes up the complete complaint file .  The Commission’s guidance to gambling businesses recommends that businesses ensure that they respond to requests from ADR providers for information about disputes in full and within ten working days (though businesses can choose what information they provide). Businesses should not unnecessarily delay providing the information that we as an ADR provider request. Where the business delays in providing information without reasonable explanation, we as the ADR provider should consider reporting the matter to the Commission.
    • before the ADR procedure begins, informs the customer that they have the right to withdraw from the procedure at any stage
    • inform the parties that they are not obliged to have a legal adviser, but that they may seek independent advice or be represented or assisted by a third party at any stage of the alternative dispute resolution process
    • notify the parties with the outcome of the dispute within 90 days from the date on which the provider received the complete complaint file. Where the case is highly complex, the body may extend this period, but must inform the parties of this extension and how long it expects the process to take.provide an update to the consumer at the end of each 30 days that the dispute is ongoing (once the ADR provider has received all the documents that make up the

      Under the ADR Regulations (5(n)), information that ADR providers must make publicly available includes the legal effect of the outcome of the dispute resolution process, including whether the outcome is enforceable and the penalties for non-compliance with the outcome, if any.

      We therefore expect ADR providers to make available to consumers information on:

      • whether they will reconsider the outcome of a dispute after the outcome has been issued
      • the circumstances or grounds for such reconsideration to take place
      • time-limits for requesting such reconsideration, and the process that it will follow
      • what will happen at the end of the process.

      Independence, transparency, consistency and quality

      Requirements of the ADR Regulations

      1. 4.1  The ADR Regulations require the ADR provider and officials to be independent of the parties to a dispute. This includes:
         • ADR officials must be appointed for a term of office sufficient to ensure the independence of the person’s actions, and provides that no official can be relieved of their duties without just cause (Schedule 3, 3(b))
         • ADR officials must not be remunerated in a way that is linked to the outcome of the dispute resolution process (Schedule 3, 3(d))
         • where ADR officials are employed or remunerated by a professional organisation or business association, the entity must have a ring-fenced budget to enable it to carry out its functions as an ADR entity (Schedule 3, 3(g))
         • where the ADR provider operates a dispute resolution model that is a collegiate body of representatives of both professional organisations/business associations and consumer organisations, ADR officials must comprise an equal number of representatives of consumer interests and trader interests (Schedule 3, 3(h)).
      2. 4.2  The ADR Regulations also set out criteria that ADR providers must meet in terms of expertise, impartiality, effectiveness and fairness. These include:
         • ensuring that an ADR official possesses a general understanding of the law and the necessary knowledge and skills relating to the out-of-court or judicial resolution of consumer disputes (ADR Regulations Schedule 3, 3(a)).
         • ensuring that no ADR official discharges his or her duties in a way that is biased as regards a part to a dispute, or the representative of a party (ADR Regulations Schedule 3, 3(c)).
         • ensuring that parties to a dispute may express their points of view, and may request sight of, and opportunity to comment on, evidence, documents, arguments and facts put forward by the other party to the dispute. (ADR Regulations Schedule 3, 7(a) – (c)).

      The Ombudsman Association’s six principles of good governance

      We abide by The Ombudsman Association (OA)’s six principles of good governance:

      Independence

      Ensuring and demonstrating the freedom of the office holder from interference in decision making:

      • Freedom from interference in decision making on complaints• Appropriate and proportionate structure and financial arrangements• Appointment, re-appointment and remuneration of the office holder consistent with ensuring independence• Governance arrangements which ensure and safeguard the independence of the office holder and scheme• Those involved in the governance of the scheme to conduct themselves at all best times in the best interest of the scheme

      Openness and transparency

      Ensuring openness and transparency in order that stakeholders can have confidence in the decision-making and management processes of the scheme:

      • Clear explanation of legal constitution, governance and funding arrangements• Open and clear policies and procedures, and clear criteria for decision making• Clear and proper recording of decisions and actions• Free availability of information and publication of decisions, consistent with statute, contract and good practice• Clear delegation arrangements, including levels of authority• Register of interests, to apply to the office holder, appropriate staff members and members of any governing body

      Accountability

      Ensuring that all members of the scheme, including the office holder staff members and members of any governing body are seen to be responsible and accountable for their decisions and actions, including the stewardship of funds (with due regard to the independence of the office holder)• Subject to appropriate public or external scrutiny• Accountable to stakeholders for the operation of the scheme• Financial accountability, and appropriate internal controls to demonstrate the highest standards of financial probity• Robust mechanism for review of service quality • Clear ‘whistle-blowing’ policy

      Integrity

      Ensuring straightforward dealing and completeness, based on honesty, selflessness and objectivity, and ensuring high standards of probity and propriety in the conduct of the scheme’s affairs and complaint decision making.• Impartiality in all activities• Identify, declare and deal with conflicts of interest (Including office-holder, staff members and members of any governing body)• Compliance of all those involved in the governance or operation of the scheme with relevant principles of public conduct• Arrangements for dealing with conflicts about governance issues

      Clarity of Purpose

      Ensuring that stakeholders know why the scheme exists, what it does, and what to expect from it

      • Explanation of the purpose of the scheme and who it serves• Clear status and mandate of the scheme• Clarity of extent of jurisdiction• Governance arrangements which are clear in relation to the office holder’s adjudication role

      Effectiveness

      Ensuring that the scheme delivers quality outcomes efficiently and represents good value for money• Leadership which defines and promotes the values of the scheme• Keeping to commitments• Good internal planning and review processes• Quality assurance and a process for review of service• Quality outcomes for complainant, organisation complained about, scheme and all other stakeholders• Recommendations accepted by bodies in jurisdiction• Effective risk management controls• Cost effectiveness for money

      We expect that the outcome of the dispute process should be binding on both parties if the consumer agrees with the outcome for disputes which would otherwise be taken to the small claims court (disputes of not more than £10,000). The ADR procedure need not be binding for disputes over £10,000. This will allow, for example, for mediation to be employed for larger figures, or for adjudication decisions to be non-binding.

      If the consumer does not agree with the outcome, they may choose to take the matter to an appropriate court.

      Reconsidering the outcome of the dispute resolution process

      There may be times when we may receive information relevant to the outcome of a dispute after the outcome has been issued. For example, the consumer may provide an email that we have not seen before. The existence of a new email in itself would not necessarily be grounds to reopen a dispute. But if the email contained new information that impacted on the dispute, then we will consider whether the dispute should be reopened.

      Under the ADR Regulations (5(n)), information that we must make publicly available includes the legal effect of the outcome of the dispute resolution process, including whether the outcome is enforceable and the penalties for non-compliance with the outcome, if any.

      We therefore make available to consumers information on:• whether they will reconsider the outcome of a dispute after the outcome has beenissued• the circumstances or grounds for such reconsideration to take place• time-limits for requesting such reconsideration, and the process that it will follow• what will happen at the end of the process.

      We will reconsider the case on the same basis as previously, if the complainant asks us to reconsider within 3 months of the outcome.

      Independence, transparency, consistency and quality

      Requirements of the ADR Regulations

      The ADR Regulations require us and our officials to be independent of the parties to a dispute. This includes:• ADR officials must be appointed for a term of office sufficient to ensure the independence of the person’s actions, and provides that no official can be relieved of their duties without just cause (Schedule 3, 3(b))• ADR officials must not be remunerated in a way that is linked to the outcome of the dispute resolution process (Schedule 3, 3(d))• where ADR officials are employed or remunerated by a professional organisation or business association, the entity must have a ring-fenced budget to enable it to carry out its functions as an ADR entity (Schedule 3, 3(g))• where the ADR provider operates a dispute resolution model that is a collegiate body of representatives of both professional organisations/business associations and consumer organisations, ADR officials must comprise an equal number of representatives of consumer interests and trader interests (Schedule 3, 3(h)).4.2 The ADR Regulations also set out criteria that ADR providers must meet in terms of expertise, impartiality, effectiveness and fairness. These include:• ensuring that an ADR official possesses a general understanding of the law and the necessary knowledge and skills relating to the out-of-court or judicial resolution of consumer disputes (ADR Regulations Schedule 3, 3(a)).• ensuring that no ADR official discharges his or her duties in a way that is biased as regards a part to a dispute, or the representative of a party (ADR Regulations Schedule 3, 3(c)).• ensuring that parties to a dispute may express their points of view, and may request sight of, and opportunity to comment on, evidence, documents, arguments and facts put forward by the other party to the dispute. (ADR Regulations Schedule 3, 7(a) – (c)).

      We are transparent and are:•  transparent about and make public information on how we are funded, and how we areindependent• provide clear information about the purpose of the scheme• publish clear criteria to gambling businesses and customers about its methods andmanner of, and timescales for, handling disputes• At least annually, implement a robust review or audit of dispute outcomes, servicestandards and service quality as well as governance arrangements.

      The GC expects providers’ policies and procedures for decision making to take account of the balance of power within a dispute. Some consumers (such as those with health problems, literacy problems, or those who are unfamiliar with gambling) may find it particularly difficult to state their case or understand arguments advanced by the other party. The GC expects providers to take account of the consumer’s needs when requesting or sharing information. This includes providing information clearly, tailored to the consumer’s level of understanding and asking the right questions to elicit information.

      The GC expect’s providers to ensure that parties to a dispute are made aware of their right to request the information put forward by the other party as soon as possible in the dispute process. All such information should be provided to them in a timely manner.

      The only exception to this requirement is where sharing evidence or information may result in a conflict with other law or regulations. For example, where sharing personal information may contravene the GDPR, or sharing information that alerts a customer that they are being investigated for money laundering concerns may constitute a criminal offence under the Money Laundering Regulations.

      The GC expects ADR providers to publish performance data to help demonstrate to consumers that their procedures are transparent and independent. This may be in the form of key performance indicators (KPIs) measuring certain metrics of the ADR process. For example:• numbers of disputes received• average time taken to handle disputes• number/ percentage of disputes that took over 90 days to resolve from the date theprovider received the complete complaint file• percentage of disputes formally resolved in favour of the customer• percentage of disputes formally resolved in favour of the gambling business• percentage of disputes resolved informally with agreement from both parties• numbers of disputes refused• metrics that the provider may collect related to customer satisfaction (for example,on clarity of information provided, ease of process, time taken to respond, final outcome).

      The GC expects providers to publish this information at regular intervals to supplement/ feed into the information in the provider’s annual report, as required by the ADR Regulations.

      Conflicts of interests

      A conflict of interest may arise if an ADR official is involved in a dispute in which they have an interest, whether this interest is personal, financial or another interest. Both the ADR Regulations and the OA principles of good governance require arrangements to be put in place to safeguard against conflicts of interests.

      The obligation to disclose a conflict of interest remains a continuing obligation throughout the alternative dispute resolution procedure (ADR Regulations Schedule 3, 3(f)).

      As a minimum, the ADR Regulations (Schedule 3, 4) require ADR providers to have in place the following procedure in the event of a conflict of interest:• where possible, the ADR official is replaced by another official to handle the particular dispute• if the ADR official cannot be replaced, the official must refrain from conducting the alternative dispute resolution procedure and the provider must, where possible, propose to the parties that they submit the dispute to another ADR provider that is competent to deal with it.• If the dispute cannot be transferred to another ADR provider, the provider must inform the parties to the dispute of the circumstances of the conflict of interest and that they have the right to object to the conflicted person continuing to handle the dispute, and can only continue with the dispute if no party objects.

      We expect ADR providers to ensure that parties to the dispute understand that where the dispute is transferred to another provider, the terms and conditions of that provider will apply to both parties for that dispute.

      Where ADR officials work part-time for the ADR provider and part-time in another capacity (eg, as gambling trade association official), providers must ensure that the official is not conflicted by their non-ADR duties. Any such conflicts must be reported and dealt with in accordance with the above policy.

      To meet both the requirements of the ADR Regulations and our standards, providers will need to demonstrate that the official is not conflicted. Such demonstration could include, but is not limited to:• a published statement of how the ADR official’s duties are not in conflict with other duties not related to ADR• a published statement demonstrating how financial remuneration for the ADR official is not linked to any other duties

      Decision quality standards

      The GC expects the ADR provider to carry out its duties based on the following quality standards.

      Before reaching an outcome, the ADR provider:• examines thoroughly all of the evidence presented• decides the key issues, establishes the relevant facts, and identifies all necessaryenquiries• asks the right questions, in the right way, to enable all the relevant facts to beidentified• provides information to the parties to the dispute in such a way that clarifies the keyissues, the facts that are known, and any information still required.

      In reaching an outcome, the provider:• takes full account of the relevant information provided in the dispute• correctly interprets and applies the law, including consumer protection legislation• ensures the rules of natural justice are met – that the parties know the case theymust answer, have had fair opportunity to make their own case, and that there has been no bias

      • reaches an outcome that is reasonable in all the circumstances of the case (taking account of whether the outcome is reached through mediation or adjudication)• tailors each communication and outcome notification to the case, ensuring that theconsumer’s perceived level of understanding is respected.

      The ADR provider will also need to reach the outcome of the disputes within certain timescales, as laid out in the ADR Regulations. Further information about this is contained within the Customer Service and Information section.

      Customer service and information to consumers

      The ADR process can be lengthy, and in some cases quite complex. It is important that ADR providers communicate with consumers in a way that helps to manage their expectations and increase their understanding of the process. Consumers need to understand where their dispute is within the process, how long it might take, and what their options are at any given time. This will help to improve the transparency of and consumer trust in the process.

      Providers should consider the best way to communicate with consumers. For example, it may be appropriate to communicate with some consumers by telephone rather than by email or in writing. However, if communicating with a consumer by telephone, it may still be appropriate to provide a summary of the telephone conversation by email or in writing to maintain an agreed record of the process.

      ADR Regulations – information to be displayed on the ADR provider’s website

      The ADR Regulations require providers to provide certain information on their websites. This includes information about processes operated, including:• contact details, postal and email addresses• a list of ADR officials, the method of their appointment and the duration of theirappointment• a statement that the provider is approved by the relevant competent authority• the types of disputes it is competent to deal with, including any financial thresholdsthat apply• procedural rules of the ADR procedure it operates, including grounds for refusing adispute• the language in which it is prepared to receive initial dispute submissions, and inwhich the procedure can be conducted• the principles it applies and the main considerations when seeking to resolve a dispute• any requirements that a party to a dispute needs to have met before the ADR procedure can begin• a statement as to whether a party to a dispute can withdraw from the ADR procedure once it has started• any costs to parties to a dispute, including any rules on costs awarded by the body at the end of the ADR procedure3• average length of each ADR procedure• the legal effect of the outcome of the ADR process, including whether the outcome is enforceable and any penalties for non-compliance with the outcome• a statement as to whether the ADR procedure it operates can be conducted by oral or written means, or both• The annual activity report as required by the ADR Regulations Schedule 3, 11(2).

      The Online Dispute Resolution (ODR) platform

      ADR providers must comply with the EU Regulation on Online Dispute Resolution (ODR). The ODR platform is a requirement of the EU Regulations for consumer disputes. The platform is an automated online tool that will allow consumers to make a complaint against a trader where goods or services have been bought online. The platform provides translations in all EU languages.

      In LCCP, we go beyond the ADR Regulations and require gambling businesses to provide ADR free of charge for consumers

      All gambling businesses that sell goods or services to consumers online must provide on their websites a link to the ODR platform.

      ADR Regulations – the ODR platform

      Under the ADR Regulations (Schedule 3, 17 – 19, as amended), when an ADR provider receives a dispute via the ODR platform, it must:• notify the parties to the dispute without delay whether they agree or refuse to deal with the dispute, and transmits any refusal to the ODR platform• inform the parties of the provider’s procedural rules, and of any costs incurred• not require the physical presence of the parties, unless its procedural rules providefor this and parties agree• provide the following information to the ODR platform:• the date it receives all the information making up the complete complaint file• the subject matter of the dispute• the date the ADR procedure concludes• the result of the ADR procedures

      Providing consumers with information about ongoing disputes

      The ADR Regulations require ADR providers to provide parties to a dispute with certain information during the course of the dispute. The provider must:• notify all parties to a dispute as soon as it has received all of the information that makes up the complete complaint file (see definition at para 3.3 and in glossary) ADR providers should note that the Commission’s guidance to gambling businesses recommends that businesses ensure that they respond to requests from ADR providers for information about disputes in full and within ten working days (though businesses can choose what information they provide). Businesses should not unnecessarily delay providing the information that the ADR provider requests. Where the business delays in providing information without reasonable explanation, the ADR provider should consider reporting the matter to the Commission.• before the ADR procedure begins, informs the customer that they have the right to withdraw from the procedure at any stage• inform the parties that they are not obliged to have a legal adviser, but that they may seek independent advice or be represented or assisted by a third party at any stage of the alternative dispute resolution process• notify the parties with the outcome of the dispute within 90 days from the date on which the provider received the complete complaint file. Where the case is highly complex, the body may extend this period, but must inform the parties of this extension and how long it expects the process to take.

      We expect ADR providers to provide parties to a dispute with some additional information during the lifetime of the dispute. This will help to keep the process transparent to all parties.

      In summary, under the new standards we expect ADR providers to:• acknowledge receipt of the consumer’s initial contact within 3 working days. Thismay be done as part of the requirement to notify the consumer of their right to withdraw, and of their rights around independent legal advice, as per the requirements of the ADR Regulations.• provide an update to the consumer at the end of each 30 days that the dispute is ongoing (once the ADR provider has received all the documents that make up the complete complaint file), where the consumer has not received any other update from the ADR provider during the preceding 30 days. This update might explain to the consumer the point in the dispute procedure that the complaint has reached, the reason for any delays (where appropriate), and confirm to the consumer that the dispute process is continuing.• provide further updates at the end of each 30 days that the dispute is ongoing if the dispute takes longer than 90 days to complete (and where the consumer has not received any other update from the provider within the preceding 30 days).

      The ADR provider will also need to communicate with the consumer at other times outside of this process. For example, the provider will need to ensure that parties to the dispute are aware of their right to see and comment on evidence advanced by the other parties and may also need to contact parties to clarify evidence that has been put forward (see section 4, paragraph 4.6-4.7).

      Other information – appealing the outcome of the dispute

      5.11 Paragraphs 3.20 – 3.21 of this document discuss information that we expect providers to give to parties to the dispute about whether the parties can appeal the outcome of the dispute. ADR providers should ensure their policy for accepting any appeals is clear and accessible.

      Other information – complaining about the ADR provider

      Parties to a dispute may wish to complain about the ADR provider’s service. For example:• no information received from the ADR provider• delays in the dispute process• unsatisfactory treatment by staff• systems difficult to use.

      Under our standards, we expect providers to put in place and publish on their websites an effective procedure to handle complaints received about their service. The information in this procedure must include:• how complaints may be made• the types of complaints that can be raised (that is, complaints about service ratherthan about the outcomes of decisions, which should be signposted to theinformation on how to appeal)• a brief explanation of the process for reviewing the complaint• how long the process is expected to take• the communication the complainant can expect to receive (for example, whenreceipt of the complaint will be acknowledged, whether requests for further information will be made, how long it will take to advise of final outcome).

      Vulnerable consumers

      As part of our standards, providers will need to consider if the language the consumer has used in raising their dispute, or in any of their other communication, indicates that they might be vulnerable or need additional support to understand the ADR process. If so, then the provider may need to consider:• accessibility – ensuring that communication is tailored to the needs of the individual as far as is possible. Providers may also need to consider whether, for example, the consumer needs additional support or alternative means to contact them.• risk of harm from gambling – whether there are indications that the consumer’s gambling behaviour puts them at risk of being harmed by their gambling, or presents a risk that others (such as family members) may be harmed.• People at risk of harm from gambling are not always aware that they are at risk, so providers should use sensitivity and discretion when communicating with them. Providers should consider whether it is appropriate to sign-post customers to gambling management tools, self-exclusion from gambling, or an organisation that may be able to provide support. Providers are not expected to be experts in gambling-related harm and should exercise caution in any approaches.

      For more information, the Commission’s website has a dedicated section on safer gambling.

      Information on customer service performance

      ADR providers should put information on their websites about their performance against the customer service requirements outlined above.

      Providers may need to consider ‘pausing’ a dispute if the customer takes a significant amount of time to respond to requests for information or engage with the dispute resolution process. Providers should explain when this ‘pause’ is triggered within their dispute process. Providers will also need to establish and explain their procedure for closing a dispute when no contact is received from the customer.

      Evaluating customer satisfaction

      ADR providers may wish to consider measuring customer satisfaction with their service, such as post-decision surveys, and make the results of this available on their websites. Such action is at the discretion of the provider.

6 Complaints and disputes

Complaints Handling Procedure

Introduction

1. This section provides information about Commission’s handling of Complaints procedure. The Commission is responsible for the supervision of the operation of the casinos licensed to Integrated Casino Resorts Cyprus Ltd, the persons responsible for the same and the conduct of gaming in it.  As such, it is authorized to (a) receive and investigate complaints from casino customers concerning the conduct of gaming in the temporary casino, the integrated casino resort (ICR) and the satellite casinos (collectively “casinos”) and (b) act as an arbitrator for any unresolved disputes in relation to alleged winnings or losses and/or the manner in which a game is conducted.
2. The Commission has no jurisdiction to investigate complaints that may be concerned with non- gaming related aspects of the operator’s business or non- gaming facilities offered at the casinos, for example, the quality of the food or service in the restaurant or parking availability. It also has no jurisdiction to investigate any complaint in relation to an online casino or online betting services as the jurisdiction of the Commission is solely to regulate and supervise land- based casino gaming in Cyprus.
3. How the Commission handles a complaint depends on the nature of the complaint. For most of the complaints received, the Commission expects the complainant to have first raised their concerns with the operator and follow the operator’s complaints and disputes procedure. The exception to this may be concerns relating to operator’s running of the casino business.
4. Τhe Commission notifies the complainant of its decision within 30 days from the submission of the complaint. If it is deemed necessary to extend complaint’s investigations, the complainant is informed accordingly.

Language of submission of complaints

1. All complaints required to be made to the Commission in writing either in English or Greek. 

Anonymous Complaints

1. The Commission accepts anonymous complaints in written form only.

Data processing

1. In investigating complaints, the Commission normally requires information from both parties (complainant and operator) and may need to share information, provided by the complainant, with the operator. The Commission takes necessary measures to proceed with legal processing of the information under the General Data Protection Regulation, EU 2016/679.

Types of complaints

1. There are three (3) main subsets of complaints that the Commission is likely to receive and may investigate. These can be described as a general complaint, a dispute, or a concern. 
2. A general complaint is normally about services received in relation to the gaming facilities offered or matters not directly related to the outcome of a casino game whether it be a table game, or a game played on a slot machine. For, example a general complaint may be about ID verification, Loyalty/Reward Scheme offered by the casino, Self-Exclusion/time out, availability of unapproved games, conduct of a casino employee or casino key employee etc.
3. Disputes specifically relate to the outcome of a casino customer’s gambling transaction and usually include for example complaints about fairness of the game, outcome of the game, winnings paid, losses, bonuses and side bets, return to player etc.
4. Concerns are complaints about how the operator may be running its business and may suggest possible breaches of their license conditions, non- compliance with the Law, Regulations or Directions or cast doubt on the operator’s continued suitability. They may include concerns about money laundering, underage access or responsible gaming issues, illegal or criminal activity within the casino, content of advertisements or promotions and accessibility to same, cheating, collusion etc.
5. You can submit the Complaints Form as following: 

• by downloading the relevant “Complaints Form” which is uploaded on Commission’s website, complete and email it at complaints@cgc.org.cy; or
• through Commission’s website at www.cgc.org.cy; or
• by post at: 3 Thaleias Str, 1st  Floor, 3011 Limassol, Cyprus  or
• by hand at: 3 Thaleias Str, 1st Floor, 3011 Limassol, Cyprus  

Download Complaints Form