Michael Golembo says operators must help affiliates avoid marketing to those who’ve opted for self-exclusion, so that a mutually beneficial relationship can thrive in the face of increasing regulatory scrutiny.
FOR YEARS, OPERATORS haven’t monitored and controlled the content that affiliates publish on their behalf as well as they might have. Now the UK’s Gambling Commission has made it clear that it holds operators ultimately responsible for any compliance-violation issues that stem from third-party marketing activity. In response, some of the largest online casino brands have closed down their affiliate programmes, including the likes of Sky Betting & Gaming.
But this is the nuclear option and, in reality, an overly drastic measure. Sure, the relationship between operator and affiliate needs to change but some simply haven’t allowed that process to take place. Operators and affiliates must understand that they are equally responsible and so work hand in hand to reach a solution.
A good place to start is in a critical area that operators and affiliates need to address: that players who have taken a ‘time out’ or have self-excluded entirely are not marketed to in any way. This is where I believe the Commission is keen to see instant and drastic change. It has been almost impossible for affiliates to know whether a player has self-excluded or not. In sharing their player databases with affiliates, operators would breach a whole host of privacy and dataprotection laws (and that was even before GDPR got thrown into the mix).
For example, SkillOnNet powers one of the most successful online-casino brands in the UK, PlayOJO. Prior to the regulatory clampdown and introduction of GDPR, we used affiliates with email and SMS traffic to drive large volumes of new players to the site. But then we saw the trouble other operators and platform providers were encountering, so to be 100% UK compliant we effectively banned the use of direct mail and SMS across our network of brands.
This had a negative (albeit expected) impact, with new-player traffic to PlayOJO dropping between 10% and 15%. We realised we had to develop a tool that would allow affiliates to remove self-excluded players from their direct-mail distribution lists. The result is our recently launched Self-Excluder Identifier API, a simple solution to a complex problem. Affiliates upload their lists of email addresses or phone numbers to the Self-Excluder Identifier, which is fully encrypted to overcome issues around data privacy and GDPR.
The tool then compares that list with the database of self-excluded players held by SkillOnNet across all of the brands that run on our technology and highlights those that have self-excluded. We realised that players self-exclude and reverse the process on a regular basis so our database updates automatically each time.
We require all of the affiliates that work with our brands to be UK and GDPR compliant. They must also submit their creatives to us for approval and, of course, run the Self-Excluder Identifier before each send-out. Because affiliates can also encrypt the data they run in the tool, it’s secure and compliant under current UK privacy laws.
This isn’t an advert for SkillOnNet and our casino brands, but rather a blueprint for other operators and platform providers to follow. Affiliates are a huge source of traffic for operators and the ability to market to players directly via email, SMS and snail mail is a powerful tool for performance marketers to drive engagement.
Operators and platform providers must help affiliates overcome the challenges they face. By doing this, the relationship between the two will continue to be mutually beneficial despite the tremendous pressure being placed on the industry by regulators and watchdogs in the UK and beyond.