As Prize Draw Groups Grow, What Changes for Players?

An Op-ed by Hayley Ashton, Compliance Manager at eGaming Integrity

When a UK prize draw business acquires another brand, the work goes beyond signing the deal. The group has to decide how its draws, customer information and support will work across the businesses. Customers will notice if entering a draw gets confusing or a complaint goes nowhere.

A larger group can share specialist people and systems across its brands. That gives it a chance to make player protection more consistent, including how free-entry routes are presented and how complaints are handled.

Each brand also needs to hold on to what its customers liked about it.

Make player protection work across every brand

Bringing prize draw brands into one group is a chance to agree on how each competition should be run. Customers should be able to find the free-entry route, understand how a winner is chosen and get an answer if they have a complaint, whichever brand they entered with.

The government’s Voluntary Code of Good Practice for Prize Draw Operators gives signatories a starting point. It covers those questions, along with age verification, spending controls and account suspension. The Code is voluntary, and existing consumer, advertising and data protection law still applies.

Within a growing group, people still have to make these measures work across different platforms and teams. If complaints are handled centrally, staff need to know which draw a customer entered and who can fix a problem. Records for each draw should show how the winner was chosen.

I would prioritise monitoring for potential harm and making sure interventions work consistently across the group. A customer may enter competitions run by more than one brand, so looking at each brand separately could miss a pattern of excessive participation or distress.

The Voluntary Code asks signatories to make reasonable efforts to monitor activity for signs of harm and to respond in a tailored and proportionate way where those signs are identified. It does not require separately branded businesses under common ownership to use one cross-brand system. A group can still agree on the signs it looks for, when staff should intervene and who takes the next step.

Flutter offers an example from the wider gambling industry. Where it can match account details, it says it takes reasonable steps to apply all-product self-exclusion across its UK brands. Prize draws operate under a different framework. Even so, I would want a growing group to consider what happens to a customer’s protection if they enter through another brand.

For me, the aim is a minimum standard across the group, with each brand putting it into practice in a way that works for its customers.

Keep customer choices intact as brands combine

A customer may have opted out of marketing, raised a complaint or asked to suspend an account. When prize draw brands bring their systems together, those records matter as much as names and contact details. The people doing the work need to understand what each record means and whether and how it can be used.

The Information Commissioner’s Office says that if an acquisition means personal data moves to a different or additional controller, the businesses must check why it was collected and their lawful basis for sharing it. They also need to consider how customers will be informed, and whether the information is accurate and secure.

This takes coordination between the people managing the systems and those dealing with customers. A support team needs the right information to pick up a complaint. Marketing staff need to know which preferences apply before contacting someone.

I’d start by checking who has asked to stop receiving marketing or take a break from draws. Those requests still need to apply when the brand moves to a new system. It's also worth reviewing spending limits and anything staff have already done because they were concerned about a customer’s participation.

Before moving the data, I would agree on a common set of customer-status fields and rules. Customer service, compliance and marketing teams need to know what each status means and what action it calls for. If someone has opted out of marketing, staff need to know which brands and communications that covers. If a customer has suspended an account or staff have intervened over their participation, the relevant team needs to see that history and know what to do.

A customer should not find that a protection has disappeared because the brands use different systems. Getting this wrong can lead to complaints and damage trust in the whole group.

Keep track of who runs each part of a draw

A prize draw group may use different partners for its websites, payments, marketing or the draws themselves. When another brand joins the group, the operator needs to know who handles each part of its competitions. Customers need to know where to turn if they have a question.

The Voluntary Code asks signatories to take reasonable steps to ensure that third parties supporting their prize draws follow the relevant requirements, including through contracts. In practice, that means knowing who keeps the draw records and who can help resolve a complaint. Those arrangements need to work for each brand in the group.

If someone asks how a winner was chosen, I’d want the group to be able to get the draw records from the partner that ran it. The contracts need to spell out who does what, including who verifies the winner and how a complaint is passed between providers. Staff need to know what to do when a customer gets in touch.

I’ve seen a prize draw business join a larger group with separate providers for its website, the draw and customer support. The group found that those providers held different parts of the customer and draw records. It mapped who held what, agreed who was responsible at each stage and set out how customer issues would be escalated.

When a customer has a problem with a draw, the group needs to know which partner can fix it. The customer should never have to chase that answer.