Learning from the Vulnerability Guidance Review: How firms can step up their support for customers experiencing gambling harms

Last week, the FCA published a review of the 2021 Vulnerability Guidance, an important paper outlining how firms are meeting the needs of consumers in vulnerable circumstances.

This review is a crucial update for all of us, shedding light on how firms can better support all customers in vulnerable circumstances, including those facing gambling harms, which can encompass poor mental health, financial difficulty, relationship breakdown, and job loss.

The Gambling Commission’s Gambling Survey for Great Britain (GSGB) 2023 estimated that 2.5% of the adult population were experiencing ‘problem gambling’, and a further 11.9% were ‘at risk’ of problem gambling. 

Yet, rates of access to support are woefully low. Just one in seven people experiencing problem gambling access gambling support services; and for people ‘at risk’ of gambling harms, access to support was even lower, with less than one in twenty accessing gambling support services.

Given low rates of access to support and treatment, current account providers have a crucial role to play in identifying customers at risk of or experiencing gambling harm and providing supportive tools and pathways to support services.

Many people experiencing gambling harms find it difficult to disclose their circumstances to their current account provider. As a result, millions of people are missing out on support from firms that could make a big difference in helping them manage their gambling. Yet, the review found that just four in ten (42%) vulnerable customers had disclosed their needs to their financial services provider, with reasons for not disclosing, including embarrassment and worries about getting a worse deal if they did. 

One in five respondents who hadn’t disclosed reported not doing so because they didn’t know their firm would help. Since 2018, most UK banks have introduced a Bank Gambling Block, which customers can apply to their accounts to block gambling transactions. Many firms we’re working with are also developing new and improved gambling tools and processes to support customers better. 

But in too many cases, firms have processes and support in place, but customers don’t know that their bank can help them. When this happens, a huge opportunity is missed to signal to customers that they understand and support their needs and, in turn, lay the foundations that encourage customers to disclose their needs. 

In the case of gambling, firms must also consider the shame and stigma that surround gambling difficulties, which can bury people in silence. Understanding and acknowledging these societal factors is crucial for creating a supportive environment where customers feel comfortable seeking help.

Disclosing to your bank against this backdrop of fear and judgement is incredibly hard; the more firms can do to explicitly signal to customers that they’re there to support them and that they have the tools to do so, the better.

Reflecting on the review’s findings and implications for supporting customers experiencing gambling harm, we focus on two key actions firms can take to improve customer support. 

1) Create good disclosure environments: as a minimum, firms should ensure all staff are trained to know how to respond when a customer discloses gambling harms. Yet, ensuring staff are equipped to respond to explicit disclosures is only part of the solution. Firms must go further and create good disclosure environments that send customers implicit and explicit signals that disclosing their needs is safe. 

This can be achieved partly by firms promoting the gambling harm support tools available and ensuring staff have the confidence to talk to people experiencing gambling harms and know support services to refer customers to. However, firms can go beyond this by developing processes and systems to spot indicators of gambling harms on customers’ accounts and targeting messages about tools and support to those who might benefit. This has the twofold benefit of signalling to customers that their bank cares about gambling harms and has tools to support them. 

2) Building an understanding of customer vulnerability into the design of products and services: a key area for improvement from the review was the need to embed consumer needs into product and service design. Firms’ provision of apps and features designed to block gambling transactions is an example of this, which was highlighted as an area of good practice. Embedding the needs of customers experiencing gambling harms into product and service design is central to our work at the Gambling Harms Action Lab. 

We’re working with seven firms, Barclays, first direct, HSBC UK, Nationwide, Monzo, Starling, and Virgin Money, to develop new and improved tools to support customers at risk of or experiencing gambling harm. 

You can learn more about the Gambling Harms Action Lab, as well as our previous work, written in collaboration with the Money Advice Trust, on creating good disclosure environments.