eGAP Player Protection Guidelines

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The eGAP guidelines were formulated by eCOGRA so as to enable transparency and rigorousness in the certification process for online gambling operators. Player protection is a vital issue and the eGAP guidelines cover player protection in two different areas. The first is player information and the second is player funds.

The player information protection has two parts. It begins with privacy and unnecessary disclosure of information like name, gender, age, address, bank account details, credit card details, details of wagering done and so on. The specific eGAP objective in this regard is that online casino operators should “ensure that the privacy and confidentiality of all player information submitted at any point in time is maintained and protected from unauthorized or unnecessary disclosure”. This implies that there could be circumstances when the operator has to disclose the information. These would mainly cover legal or third party investigations against the player.

Therefore, the online casino has to formulate a privacy policy and display it on its website. The policy should give details of the information that would be sought, the purpose for information collection, the conditions under which the information may be disclosed and the controls in place to prevent unauthorized or unnecessary disclosure. The player’s consent of the privacy policy should be specifically acquired before registration. There are two other requirements in player information protection. Player credit card numbers stored on the system shall be secured from unauthorized use. How this should be done is not specified. The employee contracts shall contain a “confidentiality” clause prohibiting the unauthorized or unnecessary disclosure of player information.

The protection of player funds is a multidimensional area. The core is the prompt and accurate processing of deposits, winnings and payment requests, subject to appropriate and necessary checks and verification. What constitutes “prompt” is however not defined in the eGAP guidelines. The guidelines emphasize that the financial transactions are conducted on the basis of a documented process, so as to eliminate error and subjectivity. The guidelines also require logging of all transactions so that the trail is available during audit and dispute resolution. The players have to be clearly informed all procedures and conditions and their queries are to be promptly addressed. The eGAP guidelines for player fund protection also require the online casino operator to put in place preventive and detective controls for excluding players from jurisdictions where online gambling is illegal.

An important aspect of the protection of player funds is the ability of the online casino operator to pay back uncontested deposits as and when required. This is covered under the guidelines for operator liquidity. The clause for this states, “The operator’s liability for player balances, pending cash-ins and guaranteed prizes shall be separately identifiable at any point in time, and operators shall demonstrate sufficient cash and cash equivalents to settle these balances.” Again, specific requirements have not been spelt out. There is an increasing demand for online casino operators to fence player deposits in a separate account and not use them for operating expenses so that all the funds are always available on call.

While registering at an online casino the player should make sure that all the information required to be provided under the eGAP guidelines is included in the various terms and conditions. For the rest he has to accept that if eCOGRA has given its seal of approval then the online casino is in compliance with eGAP.

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