When aimm and members introduced the potential for Society Lotteries to utilise a shortcode based call-to-action and mobile-bill payment for lottery tickets, we identified 5 Guidance documents, 2 Special Conditions requirements and one notice document that providers of Society Lotteries needed to be aware of as a result of introducing premium rate as well as the PSA Code of Practice. Society Lotteries are already heavily regulated by the Gambling Commission under the 2005 Gambling Act.
To improve regularity simplicity, PSA and aimm collaborated on condensing some of the distributed PSA requirements into a single guidance document and to review the necessity of Special Conditions for this product as the regulatory environment created by the Gambling Commission already protects consumers regardless of payment mechanism.
PSA’s proposal is that Special Conditions must exist and in addition they added excessive requirements to promotional material that go over and above the Gambling Commissions requirements for promotion. This will damage the simplicity of the shortcode based call-to-action that we already experience on television, radio and posters for charity donations and other products. Certain key information needs to be available to consumers on promotions but PSA’s proposals add clutter, causing rather than preventing consumer confusion.
We also believe that PSA has taken an overly cautionary line using experiences from affiliate promoted online competitions to push through additional conditions for Society Lotteries without a sufficient risk assessment that takes into consideration the predominantly blue-chip brands that will promote their fundraising lotteries and raffles.
aimm’s final response is linked here.
We welcome any member comments or queries on our response.
