department of justice victoria pre-commitment discussion

Department of Justice Victoria

Pre-commitment Discussion Paper

Response Document

Contact details:

Karen Franks

General Manager

Worldsmart Technology

(08) 8373 6477 or [email protected]


Pre-commitment Discussion Paper Response Page 1

Contents:

1 Overview ....................................................................................... 2

2 Playsmart Pre-commitment ........................................................... 3

3 Technical Data ............................................................................... 4

3.1 G2S™ protocol ......................................................................................................................... 4

3.2 Real Time communications ..................................................................................................... 5

3.3 Separate Network Infrastructure ............................................................................................ 6

3.4 Network or Non-Networked .................................................................................................... 7

3.5 Pre-commitment Process ........................................................................................................ 7

3.6 Smart Cards ............................................................................................................................. 8

3.6.1 Smart Card Specification ................................................................................................. 8

3.6.2 Card Security ................................................................................................................... 8

4 Independent Trial ........................................................................ 9

Attachments:

Attachment A: Application Form ..................................................... 11

Attachment B: Activity Statements ................................................. 12

Attachment C: Setup ..................................................................... 13

Attachment D: Merchandising ....................................................... 14

Attachment E: Minister’s Press Release ............................................ 15



1 Overview

Worldsmart Technology (WST) is a research and development company with a particular focus on

hospitality, retail, loyalty and stored value systems. We provide creative and affordable smartcard

solutions to a variety of retailers, clubs, hoteliers and organizations around Australia. The business

has a wide range of products and customers with over half a million cards in circulation

WST Parent Company RD Jones Group encompasses a diverse range of 25 companies employing over

1,200 people with holdings in hospitality, gaming and the technology industries including

• Worldsmart Technology http://www.worldsmart.com.au/

• Worldsmart Retail http://www.worldsmartretail.com.au/

• Worldsmart Future http://www.worldsmartfuture.com.au/

• Orion Satellite http://www.orionsat.com.au

• Jackpot Club http://www.jackpotclub.com.au/

• Hotels in QLD and SA http://www.rdjones.com.au/

WST developed Playsmart™ voluntary gaming pre-commitment system in 2008 which is now currently

operating in 76 venues across South Australia and is under trial in 4 venues in Queensland.

Playsmart™ is a card-based pre-commitment system with onscreen warnings to remind players when

they have reached their spending limit or time limit. Playsmart™ can run in conjunction with the

Worldsmart Smart Game™ loyalty system, or independently if required. Playsmart™ is available on

Worldsmart SmartGame™ machine or pole mount card readers as a solution that is completely

independent of the EGM.

On 29th September 2010, Minister for Gambling – Hon Tom Koutsantonis publically released the

findings of a 14 month study of the Worldsmart Playsmart™ system managed by the South Australian

Responsible Gambling Working Party through the Department of Treasury and Finance and funded by

the Commonwealth Government through the Department of Families, Housing, Community Services

and Indigenous Affairs. The minister endorsed the launch of the Worldsmart Technology Playsmart

solution as an effective pre-commitment system and the only Wide Area Network pre-commitment

system available in Australia today (see Attachment E).



2 Playsmart™ Pre-commitment

Playsmart™ is a cost effective, secure and simple system that provides an easy to understand

mechanism for players to monitor their expenditure and behaviour while not significantly

disadvantaging the gaming venue or diminishing the player’s right to play.

Playsmart™ delivers player pre-set notices in a discreet and enabling manner that reminds the player

to take a break in play or of their pre-set spending limit. These reminders are displayed via a text

display on the Worldsmart SmartGame™ reader accompanied by 3 audible beeps. Players will also

receive a text warning message and three audible beeps as they reach 75% of their set limit. Once a

player has reached their limit, a message is also delivered to the Gaming Cashier, who is then

required to go to the EGM to physically reset the SmartGame™ reader at the gaming machine. Whilst

the cashier resets the reader, they also discreetly ask the player if they have received their ‘message’.

Playsmart™ incorporates the following features:-

Enables a card holder to set personal limits when playing gaming machines

Is voluntary, simple to use and confidential

Does not control or interfere with gaming machines in any way

Allows players to set the following limits:

Daily, Weekly, Fortnightly or Monthly

Spend Limit

Breaks in play

Advanced Options include:

Players can approve dual access to Player Activity

Statements and Playsmart settings e.g. Counselor via a Third Party Access Code.

Disable play on nominated paydays

Select Lockout periods - days or hours

Players can register for Playsmart™ on line via Worldsmart’s cardholder access portal, or at

Worldsmart SmartHub™ (kiosk) in the venue. Examples of registration screens are shown in

Attachments A and B.

Each player can access an activity report via Worldsmart’s cardholder access portal, or at a

Worldsmart SmartHub™ in the venue. An example of a player activity report is given in Attachment

C.

To encourage participation, a variety of supporting merchandising is usually displayed in the venue,

one example of which can be found in Attachment D.



3 Technical Data

The pre-commitment discussion paper raises some specific key issues/problems which are discussed

further below by WST Research Director, Peter Buchanan.

3.1 G2S™ protocol

The Game-to-System protocol, or G2S™, is a standardized communications protocol

developed by members of the Gaming Standards Association:-

http://www.gamingstandards.com

The G2S protocol allows an EGM to communicate with multiple host systems. The list of

hosts with which an EGM may communicate using the G2S protocol is part of the EGM’s

initial configuration information1.

The meters class is used to collect meter information from an EGM. Meter information can

be queried by a host in real-time or a host may set a periodic meter subscription to cause the

EGM to send selected meters at predetermined intervals. The meters class is a multi-device

class. Each registered host may own a single meters device. Each host owns its meter

subscriptions and is the only host that can set or clear that subscription

1 Gaming Standards Association, G2S Technical Committee, March 2011. ‘G2S™ MESSAGE PROTOCOL V1.1 Game To

System.’ Document ID: gsa-p0075.024.00



Statement 52

A separate pre-commitment network would require gaming machines to have two

communication ports.

Response

A Pre-commitment and/or Loyalty Host would connect to the G2S Ethernet backbone, not

directly to the gaming machine and as such a second port would not be required.

3.2 Real Time Communications

Statement 46

The gaming machine retrieves information about a player’s limits and gambling activity from

the central pre-commitment system in real-time via the network. The player’s information

and gambling activity is also updated directly to the central pre-commitment system in real-

time.

Response

Worldsmart gaming terminals communicate real-time over Telstra’s Enterprise/Government

grade IP Metropolitan Area Network (IP MAN) Ethernet on fiber service with a CISCO 3G/4G

VPN router located at each site. Regional outages are more frequent on a wired ADSL, DSL

than on 3G/4G.

Intralot2 have stated that:

a. The operational requirements allow for continuation of gaming up to 24 hours when the

link from the site to the central system is not operational.

b. ADSL or DSL with minimum 512kbps uplink/downlink

Telecom Router to be provide by Intralot.

Pre-commitment should also offer 24 hour redundancy and not rely on an unrealistic 100%

uptime to a central pre-commitment system.

The WST solution was to store pre-commitment rules on a smartcard so it can be used

offline, infrequent rule changes must be online to our central pre-commitment system.

2 Intralot October 19, 2011. ‘Monitoring System for Victoria’ presentation for the Victorian Gaming Industry



3.3 Separate Network Infrastructure

Statement 51

This option involves connecting gaming machines to two separate networks – the monitoring

network and a pre-commitment network with its own local area network and wide area

network infrastructure.

Response

Nationally, most Loyalty/Pre-commitment card readers are prohibited from connecting

directly to the EGM monitoring network (with exception of LMO’s in Queensland).

A Loyalty/Pre-commitment Host is required to obtain metering data directly from the

government site controller (SA), or by ‘sniffing’ the EGM communication network (QLD, NT).

Each card reader is networked back to the site Loyalty/Pre-commitment Host (LAN)

independently from the monitoring network.

The G2S™ Network would allow bi-directional communications between an authorised

Loyalty/Pre-commitment Host and each EGM, for the purpose of displaying messages on the

EGM, disable play and collect metering data.

An open secure bi-directional WAN communication protocol to the Victorian or National Pre-

commitment Server would be preferable to a possible industry monopoly.

It would allow competition for the development of Pre-commitment kiosks and allow club

owners to select their preferred Loyalty/Pre-commitment system.



3.4 Network or Non-Networked

Clarification

Almost all existing Loyalty/Pre-commitment card readers are networked to a site

Loyalty/Pre-commitment Host.

All session data is stored real-time on the Loyalty/Pre-commitment Host not on the device

This is true for Smartcards as well as magnetic or RFID systems.

For example, most bankcards are chip enabled, however the chip does not store transaction

details for subsequent download as this would be un-auditable and highly impractical.

The Worldsmart system transfers data between the Site and Central Database via Microsoft

SQL Service Broker, it is an external process which can send and receive encrypted, secure,

guaranteed, asynchronous messages to another SQL Server instance. Messages cannot be

lost; they sit in a queue until 3G VPN connection is re-established. Microsoft SQL Server

certificates comply with the IETF X.509v3 certificate standard (used by SSL).

3.5 Pre-commitment Process

• Pre-commitment rules are entered online to the Central Worldsmart Pre-

commitment server by the cashier when card is issued.

• A card holder may change rules online via the card holder portal.

• Pre-commitment rules are downloaded onto the smartcard when inserted into any

EGM smartcard reader.

• During play, the current values such as spend, break in play etc are updated in the

smartcard via the EGM smartcard reader at 30 second intervals.

• On a limit event or card removal, session data is immediately sent from the EGM

smartcard reader to the Site Loyalty/Pre-commitment Host. The Host immediately

sends session data to the Central Worldsmart Pre-commitment server. Typically

this process takes between 3 to 14 seconds

COMMERCIAL IN CONFIDENCE



3.6 Smart Cards

3.6.1 Smart Card Specification

• Cards printed 4 colours front 1 colour reverse • 800 micron card body according to ISO Standards • Module StarDC 8K Gold • Milling and Embedding of chip module • Chip and Magnetic Personalisation

• HiCo Three Track Signature Panel

• Credit Card Numbering in accordance with ISO/IEC 7812-1:1993 and ANSI X4.13

• High Coercive 3 track Magnetic Stripe encoded in accordance with ISO/IEC

7813:2001(E) and ISO 7811-6

3.6.2 Card Security

• StarDC V Version 3.00

• 8 Kbyte SDA EEPROM Platform (Microprocessor Chip Card)

• Same Chip and operating system as used by MasterCard and Visa Credit/Debit cards

• Tested and approved by MasterCard International against the M/Chip Lite

specification V2.1

• SDA with 1024 bit certificate length

• Enhanced triple DES and RSA, DPA resistant

• Personalisation by Giesecke & Devrient, who also print banknotes and personalize

Visa and MasterCard cards for major banks



4 Independent Trial In July 2008, Playsmart ™ was accepted for trial by the Minister for Gambling (see Attachment E). The

Trial was conducted by Worldsmart Technology with the evaluation managed by the South Australian

Responsible Gambling Working Party through the Department of Treasury and Finance, South Australia

and commenced in August 2008. The evaluation was funded by the Commonwealth Government

through the Department of Families, Housing, Community Services and Indigenous Affairs. Data was

collected until October 2009 and data analysis commenced in January 2010.

The trial had three key aims for evaluation3:-

1 Is there value for consumers in the industry proponent’s trial?

2 Is the behavioural impact of the trial consistent with the Working Party’s goal of customer’s

gambling responsibly?

3 If the trial is extended to full operation, is on-going operation of a pre-commitment and player

tracking system cost-effective to the gaming venue?

The following conclusions were drawn from each of the key aims:-

Is there value for consumers in the industry proponent’s trial?

“While only a small proportion of consumers trialled PlaySmart, the product is seen by users to offer a

range of distinct benefits. Being able to set expenditure limits is seen as the core benefit.” (page 10)

Is the behavioural impact of the trial consistent with the Working Party’s goal of customer’s gambling

responsibly?

“Findings of the evaluation suggest that PlaySmart and messaging about limits may encourage

precommitment activity, better money management and more informed decision making about EGM

spending. Cognitions, attitudes and play data support this conclusion.” (Page 18)

If the trial is extended to full operation, is on-going operation of a pre-commitment and player tracking

system cost-effective to the gaming venue?

“Findings of the evaluation suggest that venues see PlaySmart as operationally efficient and posing

minimal impacts on the venue.” (Page 22)

A full copy of the Worldsmart pre-commitment trial can be found at:-

www.treasury.sa.gov.au/public/download.jsp?id=3188

3 Schottler Consulting, August 2010. Major findings and implications: Player tracking and pre-commitment trial



Worldsmart still provide data to the Department of Treasury and Finance on a monthly basis as the

take-up of Playsmart™ is recorded and evaluated. The latest chart showing cumulative Playsmart ™

enrolments as at September 2011 continues to show a steady take-up curve.

Playsmart™ is successfully operating in 76 venues across South Australia and trialling in 4 Queensland

venues. Our product has been independently trialled and found to encourage pre-commitment

activity and offer distinct consumer benefit in a manner that does not financially disadvantage

participating venues. As such, Playsmart™ should be considered as the pre-commitment product of

choice for Victorian gaming venues.



Attachment A: Application Form



Attachment B: Activity Statements



Attachment C: Setup



Attachment D: Merchandising



Attachment E: Minister’s Press Release



Attachment E (cont.)

department of justice victoria pre-commitment discussion

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