Finnish advisers criticise draft central gambling exclusion register

Advisers in Finland have given feedback on a draft decision setting out how gambling companies must check players against a planned central exclusion register. The advisers raised concerns about the frequency of checks, the effect of technical failures on play and the protection of personal data. The draft decision has not been finalised; the National Police Board must still decide how the feedback will be handled and when a final decision will follow.

Under the draft, operators must check a player's exclusion status at registration, at sign-in and at a physical gambling channel, and generally during play, according to the report. Checks must also cover blocks relating to direct marketing. Operators must pass check data to the authority's logging service. The register is comparable to the Cruks register in the Netherlands, the report said.

The draft requires precautions against technical failures, but it is not yet clear how play should continue when no response is received from the register, according to the report. The Finnish gambling association said a central register is important but that it is not satisfied with the draft in its current form. The association said it is insufficiently clear how often checks must be carried out and on which legislation the obligation for repeated checks is based.

As an alternative, the association proposed a method under which the system notifies gambling companies when a player's block status changes. The association also questioned the reliability of the system and said the draft should specify exactly how operators must act when no connection to the register can be made. The Ministry of Social Affairs and Health said the register must function reliably and be up to date, and that procedures during failures must be set out so that a failure does not undermine player protection.

The advisers also addressed which data is stored from checks between the register and gambling companies, including whether there is sufficient legal basis to store all check results. Recording every check could create too detailed a log of customers' sign-in data, according to the advisers, who said storing only the sign-in data of players with a valid gambling ban is a better option. There is broad support for the central register, which is intended to help prevent gambling harm and allow licence holders to check gambling bans. The Finnish Institute for Health and Welfare stressed the importance of data protection, reliable operation and clear rules for implementation.