SOCIAL GAMES CONSUMER PROTECTION GUIDELINES

Social games with casino themes are among the fastest growing segments of the game industry. Yet significant uncertainly remains about the definitions and risks. Indeed, many social game developers and operators, including major gaming companies, argue that social games do not meet the definition of gambling and therefore requires no regulation. NCPG does not take an opinion on the legality of social games or whether they should be regulated.

NCPG believes that consumer protection standards are important as it is likely that some users of social games with casino themes may experience negative consequences. Operators benefit by protecting a significant source of revenue, providing good customer service and engaging with regulators and legislators in a positive manner. Regulators have an obligation under the “precautionary principle” to protect the public especially when faced with a brand new and fast-growing gambling-like activity. Organizations like the National Council have a duty to advocate for consumer protection.

Many social games with casino themes utilize features that are regulated, prohibited or not possible in regulated gaming environments. Some of these features are argued by some to contribute to greater risk of problem gambling. They include high frequency and speed of play, lack of minimum age policy and enforcement, “opaque” game mechanics, no specific oversight or consumer protection, unclear differentiation between social and “real money” games, among others.

The intent of the standards is to facilitate discussions about consumer protection among operators, regulators, legislators, consumer advocates and the public. While it is likely that many social games encourage lengthy play, our focus is placed on social games with casino themes that are free-to-play but have ways in which the consumer can spend real money. As noted, some argue that it is likely that some users are currently or at-risk for gambling addiction, and that as a result they may spend excessive amounts of time and money on social games with casino themes, leading to negative consequences.

As with internet gambling, the graphical and interactive structure of the social media provides an opportunity to create informed consumers with access to a variety of information designed to encourage safe choices and discourage unsafe behavior. Some game features could be utilized to promote responsible play, such as granting coins for setting voluntary limits, or for reading through the educational information.

These guidelines are a work in progress as social gambling continues to rapidly. As we collect more information on actual player behavior we will be able to further determine what, if any, consumer protection and regulation is necessary. We encourage the social game developers and operators to work with NCPG to provide this data. We encourage feedback and comment and believe all stakeholders have an interest in reducing possible harms from social games with casino themes.