iGaming
%402x.svg)
.png)
Stan: Good morning, welcome again to the Data Roll initiative, season two. Today our guest is Dr. Bernadeta Lelonek-Kuleta from the John Paul II Catholic University of Lublin. Dr. Lelonek-Kuleta specializes in analyzing risky behaviors and addictions of players in the gambling industry. Could you introduce yourself to our readers, explaining what you do within your specialization and what your main areas of interest are?
Dr. Lelonek-Kuleta: Thank you very much for the introduction. I am a psychologist working at the Catholic University of Lublin in the Institute of Psychology. Practically from the beginning of my scientific work, I have been dealing with behaviors related to gambling, and particularly with gambling disorders.
For years, I have been conducting research on various groups of players, mainly adults. We have studied gamblers imprisoned in prisons, seniors, and players in the online space. The challenges of recent years have prompted me to take up topics at the intersection of gambling and gaming, because we observe aggressive expansion of gambling in the world of games available to children.
Currently, our team is conducting research dedicated to illegal gambling in Poland - those games that are offered outside of Polish licenses. We also deal with addictive elements in games and are starting a project dedicated to gambling and quasi-gambling activity, i.e., simulated gambling among youth.
In addition to scientific work, I try to popularize knowledge in the field of addictions and disorders related to gambling. I conduct training for psychologists, educators, and social workers. I also prepare informational materials for people who have gamblers in their environment. I am a member of the expert team operating at the National Center for Addiction Prevention and for 13 years I have been cooperating with the Res Humanae Foundation in organizing conferences dedicated to gambling disorders and other behavioral addictions.
Stan: Your range of interests is very broad. Touching on the Polish context - we operate in a situation where we have a partially licensed market. When it comes to bookmakers, the number of entities oscillates between 13 and 15 that offer services legally, but we also have entities offering illegally. In the case of online casinos, we theoretically have a monopoly, although reality shows that there are significantly more entities operating illegally. Are lotteries also in your area of interest?
Dr. Lelonek-Kuleta: Yes, because generally we deal with gambling research, so lotteries, as well as scratch cards - those games that are generally not considered gambling by part of society - are also gambling. Unfortunately, they can cause disorders. I have encountered people in my therapeutic work who have lost control over buying scratch cards or lottery tickets.
Indeed, this is a rarer phenomenon. Games have different properties that determine how easy it is to lose control over them. Lotteries belong to games that have a weaker addictive potential, so there are fewer such people, but these are also gambling games.
Stan: So the severity is theoretically less spectacular and attracts less media attention. What would be the main challenges related to player protection, prevention and counteracting addiction in the context of our country?
Dr. Lelonek-Kuleta: I would point out several points that will not exhaust the topic but are key. First, in the act we have outlined the area of so-called responsible gambling and player protection by legal game operators. The act obliges some suppliers to implement certain rules related to player protection.
The first deficit, which we discussed in the expert team dealing with behavioral addictions, is the not very detailed definition of requirements - they are quite limited. They boil down to several activities: posting information that gambling is addictive, limiting stakes, or informational activities. These are very limited activities that protect the player to a small extent. Above all, the requirements for game providers in terms of player protection should be precisely defined and expanded.
I would also like to talk about the changing perspective on responsible gambling. Traditionally, responsible gambling assumes that the player is responsible and responsibly practices games. However, based on research, it is noted that responsibility should also be required from the gambling industry.
In June at a conference in Switzerland, there was a lot of talk about how one should rather talk about responsible gambling offering, not responsible gambling. Responsible gambling shifts all the burden of responsibility onto the player. Let's think: on one side we have an ordinary person who doesn't necessarily know about various psychological mechanisms, and on the other - a staff of specialists working to make games engaging. The goal of games is to make money, so burdening the player with all responsibility for the way they play is quite unfair.
Second thing, in Poland, player protection is required from operators offering online games and slot machines, but gambling is not just these two groups of games. All games can be addictive, so this obligation should cover all game providers. Generally, the market should not be divided like this.
Third issue, if we already properly define the requirements for player protection and extend them to all providers, it is crucial to enforce these actions. As long as this is not enforced, it is not in the operators' interest to do it. It is necessary to implement a system or create a body dedicated to controlling game providers in terms of player protection.
As of today, none of the organs like KAS (Customs and Tax Service) has in the area of their main activities settling accounts with operators for implementing activities related to player protection.
I have various experiences related to cooperation with the gambling industry. The industry does not fully understand this need, and employees of gambling points, despite training in responsible gambling, do not understand their purpose since their goals are formulated in terms of the point's income. This requires quite a revolution.
If an operator is obliged to implement certain actions and is held accountable for this cyclically, it will be in their interest to learn how to take these actions. In the West, for example in France, such a system of employee training, repeating training, and settling accounts with operators exists.
The next very big point is sealing the internet market. Here we have a real "wild west" - everything happens, especially in unlicensed games. This is fascinating, in Poland we have one legal casino, we have a monopoly, but you just need to type "casino" in the search engine and "Polish casino" links appear. An average person who sees "Polish casino" written in Polish enters and plays without awareness that this is illegal.
Sealing the internet market is crucial because operators of games outside licenses are deprived of any requirements related to player protection. There are no ethical standards there anymore.
Currently we are conducting a project - we are after qualitative research with players practicing games outside licenses. We ask them about activity and what encourages them to play. Players tell us that what makes them return to games (although they might not do it anymore) are personalized advertisements, starting bonuses, freebies, free credits. A person says: "Actually, I might not play anymore, but I get a free credit to play, well, it's a shame not to try."
These are very personalized actions. On the internet, you can use people's data, but not to protect them, but to sell goods. Let's not demonize - not everyone becomes addicted to gambling, it's a small percentage. However, part of the population has a certain susceptibility to these influences, which will cause them to lose control over behaviors. They will play, lose huge amounts of money, and no one will be interested that they play a lot.
Closing this point about the internet - something that necessarily requires taking action is the area of simulated gambling, i.e., quasi-gambling hidden in video games. This concerns roulettes in games, casinos in video games, lootboxes, skin gambling, virtual casinos without real money, sports betting without real money. These games actually resemble gambling in appearance, visualization, and mechanics, but in the light of the law they are not gambling because there is no money, no material stake.
In Poland we have a huge field for action in this area because no regulatory actions have been taken.
Stan: Certainly simulated gambling is a topic where we have room to reach a new population group that theoretically, if we talk about legal gambling, is outside the age range allowing entry to casinos or opening an account in an online casino. Returning to legislative aspects - in Poland we had a law around 2008-2009, then an update around 2015-2016. To what extent do you think the regulations keep up with the development of new technologies? Is reality starting to diverge from the legislator's expectations?
Dr. Lelonek-Kuleta: The answer is quite obvious, we are not keeping up. What can I say, we are not keeping up.
I have sad feelings and I will probably be unpopular among people associated with the gambling industry, but I have the feeling that first, we are not keeping up, and second, there is not even a full intention to keep up. I don't see actions aimed at quickly responding to what is happening in the market and introducing new regulations. This is absolutely not visible, for example in the context of simulated gambling.
Second thing, actually something happens in legislation if a scandal breaks out. In 2009 we had a political scandal, recently we also had a scandal, as a result of which a site offering trading and exchange of skins was closed and blocked. In the light of Polish law, this was not gambling, but suddenly it turned out that based on our gambling law, such a site could be blocked.
For me, this is a mishmash, complete confusion, lack of consistency and standardized solutions. I am also puzzled that, for example, representatives of game operators are invited to committees dealing with gambling, not researchers or specialists. We - both here and my team, but researchers in Poland - really produce masses of research annually.
We have had the Gambling Problem Solving Fund since the 2009 scandal, which researchers use. Every year, very interesting projects are selected based on competitions, interesting research and results are created, from which nothing results for regulation because no one is interested in them - when it comes to regulators. To close the answer - unfortunately I am convinced that we are not keeping up.
Stan: What you are saying, I see some convergence with general observations on many different levels. The rule is that when it's quiet, nothing happens, and only when some event occurs is legislation reactively adjusted. It is not planned fundamentally to have an appropriate reference point and react proactively. This seems like a different approach to law construction. You mentioned a conference in Switzerland - are there good patterns or models in other countries from which Poland could draw inspiration?
Dr. Lelonek-Kuleta: Before I answer this question, let me close the thread about the law. Our law has very old roots - the law gives examples of games that are no longer organized in Poland. This is what keeping up with reality looks like. There is some cosmetic refreshing as a result of events, but the base is very old.
Returning to the West - I cooperate with lawyer colleagues who would have more to say in this area. When it comes to solutions interesting to me as a psychologist, I am very close to France. I cooperate with the ARPEJ https://arpej.eu/ association from Paris, we conduct research together, I am often invited to association meetings.
In France we have the body L'Autorité Nationale des Jeux (ANJ), which is responsible for controlling the entire gambling market, not selected games, but the entire market. This introduces unity in thinking about gambling. ANJ conducts various research and activities, unites specialists dealing with gambling.
Current example: we are currently conducting research with the French on youth and gambling and para-gambling activity. Because we have an extensive part of the questionnaire on simulated gambling, the French cooperate very closely with ANJ. The ANJ team helps develop a comprehensive catalog of quasi-gambling games popular in France. The team is up to date with what is happening, so the French have the support of the entire body so that research brings the most helpful and adequate results.
In Poland we don't have this - neither a unit nor a body responsible for gambling that would know about it, keep up, respond to challenges, lobby for legal changes. This is a systemic solution - separating a body dedicated to gambling.
I was a listener to a presentation where an intervention for problem players was planned at one of the operators. It was tested in cooperation with the operator, ANJ, and a researcher. You can see complementary actions, the operator will be held accountable, so they need solutions, ANJ supports because that's their task, and researchers advance knowledge. Unfortunately, we don't have this.
The second example is the use of big data on player activity on the internet. In Poland we have legally required registration of data from slot machines and internet games, and that's it. This data is shrouded in secrecy, hidden in a big safe and serves no one. It certainly doesn't serve researchers - we have attempted to make it available.
In France, Canada, Norway, data is made available to researchers. Thanks to this, algorithms for identifying problem players can be constructed and appropriate interventions can be taken towards them. We conduct research on small grants, in small groups - sometimes several hundred people - and we know that somewhere there is data on millions of people that is inaccessible.
This system works well in Norway, France, and Canada, they have been improving player identification thanks to available data for years. This is another thing I would gladly lobby for - so that this data serves someone. Today there is a feeling that operators use this data only to construct increasingly engaging games. It is available on the other side of the wall, and a group of researchers who could use it for good purposes has no access to it. And it's hard to understand why this is happening.
Stan: I think business issues also matter. Making large volumes of data available requires computational resources and organizational processes. From a business point of view, this is a cost that can be avoided. Here the role of legislation and the regulator is to create a specialized institution that can work directly with operators. You mentioned the design of games by providers, especially those targeting the black market. What features influence that certain games are more addictive than others?
Dr. Lelonek-Kuleta: These are studies conducted for many years, from the beginnings of gambling and classic forms of games. This question brings a smile to my face because in the team we discussed whether addictive elements in games can be revealed, game providers could use this. Then we thought that they have known this for a long time, they have masses of data, access, and a staff of people who use it.
Starting with classic gambling, games with a shorter cycle from betting to result are more addictive. More scratch cards than lottery, because in the lottery we buy a ticket and wait for the draw, and in scratch cards we have an immediate result. More slot machines, because everything happens quickly, cycles are short and lead to impulsive actions, there is no time for decision. In Switzerland, lottery terminals stopped paying out money directly from the terminal. A change was introduced - you had to go to the window with the ticket to collect the winnings. This was time when emotions could subside and the person could leave with money.
"Near miss", a situation where out of four elements I have three, only the fourth is missing. Classically in a slot machine, I have the conviction that I must play once more because I am close. Players forget that each round is independent, the fact that there are three elements now doesn't mean there will be four later. This provokes distorted conviction.
Irregular reinforcement system, the reward is not paid out every ten rounds, but you don't know when. Learning psychology says that irregular rewarding is most effective.
Stan: In business, bonus systems work the same way, when someone doesn’t expect a raise, research shows that if it comes at irregular intervals, people don’t treat it as something expected or already built into their pay, but rather as a genuine surprise.
Dr. Lelonek-Kuleta: In newer games, time limitations are used, a certain chance or promotional package is available now or it's lost. It's hard not to take advantage. Alerts about limited product availability, only two, only three.
In simulated gambling, if there is a possibility of monetizing winnings outside the game, the law says that if someone won a skin, it's not material value, so it's not gambling. But someone will leave the game and sell the skin on a third-party site, which becomes material value. This is a very engaging element.
Loyalty programs, alerts reminding about daily activity so that something doesn't expire. This is very unethical action in video games for small children, the child must click every day so as not to lose level. This is positive reinforcement repeated daily. The more often, the more intensively the conditioning process progresses.
Possibility of character personalization, I can create it in my likeness. Being in groups - conviction about loyalty, commitment to others. Comparing yourself, social gratification, likes. Surprise mechanics, uncertainty as in lootboxes. Gifts for daily logging in. Endless game - many games don't end, especially phone games.
Various gifts, free presents, bonuses, credits, personalized reminders. "You have three days left or you lose the ability to play", everything that is supposed to build loyalty and repeatability. This is addictive because one of the theories talks about learning through repetition and stimulating the reward center. The longer the repetition continues, the more the process becomes established.
Stan: You mentioned the time distance between payout and receiving funds. We moved from the stationary world to the online world. The physical distance alone that someone had to cover to a point where they could bet was a barrier. Second thing, the world evolved towards immediacy as an expected standard. Online shopping, next-day pickup. This was impossible 10-15 years ago. To what extent do you see differences between industries and impact on non-gambling games or simulated gambling?
Dr. Lelonek-Kuleta: I think it’s simply the spirit of the times. It would be unrealistic for providers and game developers to stop at the level of 20 years ago, because no one would play those games today. We expect everything to be instant, here and now. It’s a difficult dilemma to resolve.
I remember the period when I was working with patients and online games began to spread. I remember the transition from the profile of a patient addicted to gambling - 90% was a person playing on stationary slot machines, those machines with low winnings available everywhere: on streets, in stores, passages, gas stations.
The transition to a client playing online, one example that stuck in my memory. At the beginning of the session I ask: "When did you last play a gambling game?" Someone answers: "In the car on the way to you, by phone." In the situation of stationary games, this was not possible, it was an event.
I had an interesting observation after research on seniors who told that they play in the casino once a month. They arrange in a group, take cash, don't take cards and treat it as a recreational event. Gambling is legal entertainment in Poland, so let's not demonize it. They maintain control by not taking cards and it's once a month. We see a completely different quality of stimuli, different stimulation.
When we do something from time to time that is pleasant, it doesn't mean we'll immediately become addicted. Not everyone becomes addicted to sweets. There are very many quasi-behavioral addictions.
The world has changed a lot. Similarly, simulated gambling - it seems to me to be an action from the circle of expanding recipients. A young person has become a consumer. Kids 20 years ago didn't have access to credit cards, to money to the extent that current ones do. This is an important consumer.
Often a teenager is dressed better than a parent, has a better phone. Parents buy a phone for several thousand, and they have a used one for several hundred zloty. This is a valuable client who must somehow be caught. It can't be done legally.
These are various tricks aimed at familiarizing players with the form of entertainment that betting is. Some time ago I read the results of focus groups conducted among youth on gambling. It turns out that society doesn't treat gambling as a problem for children and youth. People say: "gambling, children, youth - no, no."
Meanwhile, youth knows gambling perfectly through simulated gambling. They practice these games, recommend them to each other. Some said directly: "I started playing to have something to talk about with colleagues, to enter the group." This is really popular entertainment.
In Poland we have a white spot when it comes to activities, legal regulations, prevention. Behind this stands a huge gaming business. When ICD-11 introduced gaming disorder as a disease entity, there was strong lobbying from the gaming business not to introduce this.
Sometimes I talk with researchers at conferences and I think we are gray people against a giant with huge resources and data. Something needs to be done, even if it's a quiet voice with a saber against a monster. Not demonizing - not all children will become addicted to games, but part of the population has increased susceptibility to developing problematic behaviors.
Stan: A very interesting case you mentioned about a patient playing on the way to the office. Could you tell us about the social and economic effects of insufficient player protection? Does this differ significantly between players using illegal games and licensed operators?
Dr. Lelonek-Kuleta: The effects are serious. Gambling-related harm is one of the research priorities for the coming years. At the conference in Switzerland, a WHO representative mentioned research on addictive factors in games and developing models for predicting harm.
Some people will become addicted - not everyone, but this percentage with certain susceptibility will lose control over playing. Then social costs begin. Therapy for addicts is free, society finances it, these are long-term therapies.
Addicted people often commit acts on the border of law: embezzlement, stealing money from work. Conducting research in correctional facilities, I met people who were sentenced for gambling. One of them was a woman who had never been imprisoned before, worked honestly for years, and in middle age ended up in prison for stealing money from work.
Social costs are falling apart families. Gamblers introduce a lot of destruction into family life: huge unpredictability for family members, uncertainty about financial status. These losses are not several thousand, but hundreds of thousands. From day to day it turns out that the house is mortgaged, the life insurance saved for years doesn't exist, there are no savings, the wedding ring was pawned at a pawnshop.
Loss of trust, one of the symptoms of the disorder according to DSM is lying. Close people said: "we'll somehow manage these debts, but lying for years... I have the feeling that our relationship was fiction." This is a symptom of the disorder integrally connected with addiction - lying, scheming. Shame and fear that it will be revealed. The gambler always believes they will save the situation, they will confess when they win back the debts.
Broken relationships with friends, borrowing money based on lies, invented stories about wife's illness, accident. Then, when friends demand money back, the gambler stops answering phones, breaks social contacts.
In this disorder there is one of the higher percentages of suicide attempts due to the feeling that debts are no longer payable, the illusion of winning back bursts, and the vision of confessing is terrifying. Patients said in the office: "the only thing that stopped me was that I would leave the family with all this." These effects are very diverse.
When it comes to legal versus illegal gambling, we don't have such research in Poland. Currently we are implementing a project on illegal gambling, four studies are planned. We are waiting for results after December.
Intuition suggests that harm may be greater in illegal gambling due to lack of brakes - ethics, norms, player protection. These games serve only profit purposes, theoretically they should be more engaging.
.png)
Our respondents in qualitative research talked about personalized advertisements, invitations, reminders, credits, bonuses - everything that is supposed to attract, which doesn't exist in legal gambling. Even if a person would stop legal gambling, illegal won't stop because they will get a bonus, credit - an element sustaining activity, leading to loss of control.
Legal problems, respondents who gave up illegal gambling, after calculating profits and losses. They talked about too much stress, risk, uncertainty associated with doing something illegal.
Interesting are the profits, many illegal players say these games are more profitable, profitable. One player said they are advertised as more profitable because they are not taxed. "Instead of winning 200 PLN in legal, I will win 300 PLN." This is an illusion, players are fed through the message that these games are very profitable. People who stopped this activity see from distance that the balance is not necessarily in favor.
Stan: Often these are stories painful not only for the addicted person, but for the entire environment. DSM-5 describes using credit cards, debt spiral... We are fortunate that it's about 8% of players who will be problematic, including 1-2% is the most pathological stage. The rest are distributed roughly as follows: about 45% of players treat it completely as gameplay, and the rest are engaged players, but still at a safe stage. We're talking about high severity, but relatively low frequency.
Dr. Lelonek-Kuleta: Yes, exactly.
Stan: How to identify and prevent before a player develops addiction to such a degree that severity suddenly increases? How can data and analytics help in identifying players and selecting appropriate measures? On the other hand, we know that the neurological problem is "false positive" - people falsely flagged by the model. How to balance this so that it doesn't turn out that half the players need to be sent for prevention?
Dr. Lelonek-Kuleta: Here scientific research based on large data sets serves. What has been happening for years in the West. My first contact with such projects is cooperation with French and Canadians. I have been cooperating for years with Concordia University, which cooperates with the French team.
Canadians started by using big data to develop a model for predicting problem players. They had consent and cooperation with game operators, without this it can't be done. Operators distribute screening surveys among players. This objective behavioral data is correlated with screening data to most accurately catch problem players.
This is not about blocking and preventing play, but about gentle prevention - telephone interventions, as happens in France, Norway, Canada. In May I was at a conference in Canada where the Concordia team presented a model that evolved over years and is currently being improved through artificial intelligence.
Technology can greatly support identification of players requiring intervention. However, this requires willingness from game providers. If data is secret and you can't do simple screening for players so as not to scare them - and I heard such opinions from operators - then little can be done.
This is our future that regulators should notice. This is already happening, we have a resource in the form of data, so it's worth using it for protective purposes. Strategies like "information, remember you can become addicted" or addiction counseling address on a card in sports betting points is too little. The future lies in cooperation with analysts and working with data.
Stan: We already had examples of cooperation in Poland - STS published a paper on implementing a model for predicting player behaviors. Paula Murphy from Mindway AI was a podcast guest, and her business model focuses on providing predictive models for player profiling.
In cooperation with one of the Swiss operators, we implemented such a model based on DSM-5 criteria. We saw that such models can significantly reduce the percentage of false positives and well detect truly problematic players.
This is an interesting matter, there are guidelines that the regulator imposes regarding procedures for preventing addictions. The way they are implemented in reality we proved that the rules imposed and approved by the regulator let through half the people. Half of the people ultimately blocked passed through the sieve.
This shows great potential for technology. Our model correctly qualified 85% of people instead of half. There will always be someone who gets through the sieves, but there is space for building effectiveness.
Operators themselves are starting to ask about such things. We saw an initiative by Tipico – the ‘Trusted Partner’ certification for game providers who direct their offering exclusively to legal sites. In Germany the illegal market is huge with large legal market regulations. Such grassroots initiatives help shape a sense of responsibility.
Is there space for various initiatives to help move toward greater social responsibility for the effects of participating in gambling?
Dr. Lelonek-Kuleta: Maybe I'll be brutal, but I have the impression that sometimes a stick is needed - requirements. What you're talking about, that in Poland there are already such initiatives, that individual operators undertake actions to detect problem players, I see this as an image action to show responsibility.
If no one will supervise, control, enforce, check this, then I don't see the operator having an interest in solid and responsible engagement. I hope - and so thinks the team I work in, and the behavioral addictions team of the National Center for Addiction Prevention - to take more pressing actions, formulate positions.
A lot of knowledge flows from research, but it doesn't break through, doesn't find reflection in regulations. We hope that it will go in this direction.
I can't answer whether this will change. I can say that I would like it to change and it should change. This is a financial, material, business, political matter - too many interest groups for it to be simple. Maybe there will be some scandal, or maybe a certain interest group will strengthen.
I have a wish for this to change, I think it should change, and what will happen, we'll see.
Stan: We will keep our fingers crossed for further evolution of legal, institutional and ethical frameworks in the gambling industry. Thank you very much, Doctor, for today's interview.
Dr. Lelonek-Kuleta: Thank you very much.
Stan: I think very interesting material that we will share with recipients soon. We will cheer and keep our fingers crossed for interesting projects, maybe we can talk at the next edition.
Dr. Lelonek-Kuleta: I hope so. Thank you very much.
The interview was conducted as part of the DataRoll initiative, season two. Dr. Bernadette Lelonek-Kuleta is a psychologist working at the Institute of Psychology of the John Paul II Catholic University of Lublin, specializing in research on risky behaviors and addictions in the gambling industry.
