Online Based Lottery – Jurisdictional Review

Dr. Nassim Tabri, Postdoctoral Research Fellow Department of Psychology, Carleton University [email protected]

An online search was conducted to identify: 1. The major lottery corporations that offer their customers the opportunity to purchase local lottery tickets online (via a website and/or gaming application), the lottery operators that provide people the opportunity to purchase international lottery tickets, and associated responsible gambling (RG) features. 2. The lottery corporations in different jurisdictions that provide customers with the option to participate in a second chance lottery (i.e., scratch/lotto tickets purchased at a physical storefront and that gives players a second chance at winning via an online lottery), and RG features in place related to these second chance lotteries.

Findings

1) Purchase of lottery tickets online (via website and/or gaming application) and responsible gambling features.

An online search was conducted to identify the major lottery corporations that offer their customers the opportunity to purchase local lottery tickets online (via a website and/or gaming application) in North America (Canada and the US), Australasia (Australia and New Zealand), and the United Kingdom. The summary also includes a review of the lottery operators that provide people the opportunity to purchase international lottery tickets (i.e., international jurisdiction). For each jurisdiction, a description of any responsible gambling (RG) features associated with purchasing lottery tickets online (via website and/or gaming application) are described.

Canada. All jurisdictions (except Alberta, Saskatchewan, Nunavut, Northwest Territories, and Yukon Territory) provide customers with the opportunity to purchase lottery tickets online. Below is a summary of each jurisdiction that provides its residents with the option to purchase lottery tickets online and any related responsible gambling (RG) features.

In Manitoba and British Columbia, people can purchase lottery tickets online via PlayNow.com. Note that PlayNow.com does not offer a gaming application with which to purchase online lottery tickets via a mobile device. In terms of RG features, customers must be 19 years of age to open an account with Playnow.com. Playnow.com verifies age and residency information by having their customers input their name and contact information, and a valid credit card (see here). Customers also have the option of viewing information on responsible gambling via GameSense (see here)—a website that contains information on how different games work (to enhance gambling literacy) and information on resources for problem gambling (e.g., voluntary self-exclusion).

Likewise, in Ontario, people have the option to purchase lottery tickets online (see here). In terms of RG features, customers must register with the Ontario Lottery and Gaming Corporation (OLG) to obtain an account. OLG vets all applicants using several criteria

Dr. Nassim Tabri, Postdoctoral Research Fellow Department of Psychology, Carleton University [email protected] including age (must be at least 18) and exclusion status (must not be an excluded individual) among other eligibility criteria (see Terms and Conditions point 4 here). For customers that successfully register with OLG, they are required to indicate that they are eligible to play and are responsible for their own actions (see here) each time they log into the OLG website. Of note, taking responsibility for one’s actions is a key feature of responsible gambling and positive play (see here). In addition, customers can only fund their online gambling activities using a credit or debit card and OLG has the discretion to limit customers’ ability to fund their gambling activities (see point 5.3 in Terms and Conditions here). Although this not a responsible gambling feature per se, OLG has the discretion to curtail the gambling activities of customers who are using multiple credit cards to fund their online gambling activities—a possible indicator of disordered gambling. Moreover, OLG provides its customers (and other people visiting their website) with information on responsible gambling and resources for problem gambling via PlaySmart.com (see here).

In Quebec and the Atlantic Provinces (Newfoundland and Labrador, Nova Scotia, Prince Edward Island, and New Brunswick), people have the option of purchasing lottery tickets online via a website (for QC, see here, for Atlantic, see here) and/or via an online gaming application (for QC, see here, for Atlantic, see here). Like Ontario, Quebec residents who want to purchase lottery tickets online must first register with Lotto-Quebec (see here). To register, customers must be at least 18 years of age, be a resident of QC, and “Not currently registered in a self-exclusion program from Québec gaming halls and/or casinos, or not self-excluded from the Site” (see section 4 in the regulations here). Lotto-Quebec verifies this information using a third party before an account is activated (see section 5.1 in the regulations here). In terms of RG strategies, Lotto-Quebec provides customers with regular reminders of the time spent playing and amounts bet or spent, and a permanent clock to keep track of time (see here). As well, Lotto-Quebec provides customers the ability to customize their deposit and spending limits as well as their time spent gambling, and to monitor their financial transactions and gaming over time (see here). Moreover, Lotto-Quebec provides information on responsible gambling (e.g., how games work; see here) and offers customers the opportunity to self- exclude (see here).

A similar procedure exists for residents of the Atlantic Provinces. That is, residents of the Atlantic Provinces must first register with the Atlantic Lottery Corporation (ALC) to open an account to purchase lottery tickets online (via the website and gamming app). To register, customers must be at least 19 years of age and be a resident of one of the Atlantic Provinces (see points 3.1 and 3.2 in Terms and Conditions here). They must also undergo a verification procedure that will examine the accuracy of their personal information (e.g., bank or other financial institution and related account information; see point 3.3 in in Terms and Conditions here). It is unclear from the Terms and Conditions whether ALC verifies whether customers are currently on a self-exclusion list prior to account registration, but it might be safe to assume that they do. In terms of RG features, ALC provides information on responsible gambling (e.g., how games work via PlayWise; see here), the opportunity to use self-assessment tools to evaluate their play behaviour using the Problem Gambling Severity Index (PGSI), the opportunity to self-exclude, literature on risks of youth gambling, and access to GamTalk—an online forum for anyone who wants to discuss gambling-related issues (for links to these RG features, see here).

Dr. Nassim Tabri, Postdoctoral Research Fellow Department of Psychology, Carleton University [email protected]

Furthermore, the Canadian lotteries that provide customers the ability to purchase online lotto tickets (i.e., ALC, BCLC, Loto-Quebec, Manitoba Lotteries Corporation, and OLG) have all been awarded a Level 4 World Lottery Association Responsible Gambling Certification for their high standards of corporate and social responsibility (see here). To achieve Level 4, lotteries should have (1) integrated specific RG programs into their day-to-day operations and decision- making, (2) integrated stakeholder feedback and considered their expectations regarding RG program development, (3) their submission accuracy and reliability assured by an external independent assessor, and should have(4) established formal internal and external reporting mechanisms on their RG commitments, actions (see here).

United States of America. Illinois, Georgia, and Kentucky are the only states to allow online purchases of individual lottery tickets (Minnesota formerly allowed the sale of lotto tickets online; see here). Thus, the summary of RG features of online purchase of lotto tickets will be restricted to these three states:

For residents of Illinois, they have the opportunity to purchase online tickets via the Illinois Lottery website (see here) or gaming app (see here). In terms of RG features, the Illinois Lottery may verify customers’ age and identity via third parties (see section V “Actions We May Take” in Terms and Conditions here). The website also provides customers with information on responsible play, the self-exclusion program, and resources to identify and help problem gambling (see here). In 2013, the Illinois Lottery was awarded a Level 3 World Lottery Association Responsible Gambling Certification for its high standards of corporate and social responsibility (see here). To achieve Level 3 certification, lotteries are required to have (1) allocated sufficient resources to support the implementation of specific RG programs, (2) Initiated the development of internal and external communications activities to inform relevant stakeholders of the lottery’s RG commitments, and (3) initiated the implementation of engagement processes that support the development of a RG program (see here).

For residents of Georgia they have the opportunity to purchase online tickets via the Georgia Lottery website (see here) or gaming app (see here). In order to purchase tickets online, all customers must have an iHope prepaid debit card (see here)—this is a bank account to hold deposited funds for online gambling as well as any winnings, and players can add money to their iHope account for online purchase of tickets. Importantly, to open an iHope account, customers need to input their personal information (age, name, address) as well as their social security number (see here). This information allows the Georgia Lottery to verify their customers’ age and identity. The website also provides customers with information on responsible play, the self-exclusion program, and tips on how to identify problem gambling, and resources for problem gambling (see here).

For residents of Kentucky, people can purchase tickets online via the Kentucky Lottery website (see here) or via a gaming app (see here). RG features include age and identity verification to open an account for purchasing tickets online (see FAQ here). As well, on the website, there is a link to information on RG, information on how to recognize problem gambling, and resources for problem gambling (see “Play Responsibly” here) as well as information on how to self- exclude. The online lottery also provides customers with information on how to set limits to

Dr. Nassim Tabri, Postdoctoral Research Fellow Department of Psychology, Carleton University [email protected] their time and money spent on gambling, how different games work, and how to play responsibly, which are all key RG features.

United Kingdom (UK). The National Lottery in the UK is operated by Camelot UK Lotteries Limited (see here). Residents of the UK have the opportunity to purchase lottery tickets from the National Lottery online (for website, see here; for the app see here). To open an account, customers must be at least 16 years of age and be a resident of the UK or Isle of Man (see point 1 in “Rules for Draw-Based Games Played Online” here). Camelot verifies this information via an application process (see point 3 in “Rules for Draw-Based Games Played Online” here). Customers can only play if they have a bank account via Direct Debit. In terms of RG features, the National Lottery has received certification from GamCare—an organization that provides certification to operators of gambling and information on RG. GamCare also has Player Protection Codes of Practice, which include age verification, socially responsible advertising and promotion, tools for the customer to set limits on their spending, ability for the customer to self-exclude, content on responsible gambling, reality checks, account controls, free play, and staff training on social responsibility and problem gambling. Note that there are a number of other online lotteries in the UK and the rest of Europe that have received GamCare certification (for a list, see here). A summary of the code of conduct is also provided in several other languages at the end of the brochure.

Residents of Wales are also able to purchase lottery tickets online (see here). To play the lottery, customers have to set up an account and register online (see section 6 in Terms and Conditions here). Identity (e.g., name, contact info, address) and age (16 or older) verification checks are carried out on a random sample basis using a credit reference agency (see section 6.7 in Terms and Conditions). Players can only purchase tickets online (via the website or gaming app) using the Registered Payment Method (debit card) to deposit funds into their e- wallet (see section 7 of the Terms and Conditions). There is a minimum amount of £5 in a single transaction and a maximum of £250 may be deposited in the e-wallet on a single day. The value of deposits is monitored and for player safety and to encourage responsible gaming, the lottery organization may impose limits on how much players can add funds to their account (see point 7.6 in Terms and Conditions). Other RG features include making RG information publically available on the main website (see “Play Responsibly” at the bottom of the page here). The “Play Responsibly” page includes information on tools to help customers play responsibly, such as the ability to set deposit and spending limits, to take a time out from playing, and to self-exclude (see here). The “Play Responsibly” page also provides information on how to identify problem gambling and resources for problem gambling. Moreover, the “Play Responsibly” page includes information on third party software that can be used to block access to online gambling.

As well, residents of the UK can purchase lotto tickets online for the Health Lottery (see here). Note that the Health Lottery is not a national lottery, but includes “51 local society lotteries each one representing one or more local authority areas across Great Britain. Each society lottery is licensed by the Gambling Commission and will raise money for health related good causes within their respective areas. Each local society lottery takes turns at participating in the draw so that every area in England, Scotland and Wales gets an appropriate share of the monies raised.” According to the Terms and Conditions (see here), players should be at least

Dr. Nassim Tabri, Postdoctoral Research Fellow Department of Psychology, Carleton University [email protected]

16 years old and a resident of the UK, which the Health Lottery verifies, but it is unclear how (e.g., third party credit check agency). The odds of winning are included in the Terms and Conditions. However, there was no other RG information, such as ways to limit time and money spent on tickets and resources of problem gambling.

Australia. The Lott is the largest lottery provider with online lotteries in almost all Australian jurisdictions as well as international jurisdictions (see here). Customers must register to become a member with “Tatts Online” to gain access to lotteries in Australian and international jurisdictions (see point 5 of Terms and Conditions here). Customers should be at least 18 years old (or older if so required by any jurisdiction-based laws in place of residence), not be excluded, and where opening an account does not contravene any law application to one’s place of residence. All information provided by customers is verified via a third party (see point 5.6 of Terms and Conditions here). In terms of RG features, the Lott is committed to RG (see section 14 in Terms of Conditions here). That is, they provide customers with information on responsible and problem gambling on their websites (e.g., see here). As well, they engage in “Predictive Monitoring” to identify customers who may be experiencing problems with their gambling and to provide them with support. They also offer customers the opportunity to self- exclude (see section 14 in Terms and Conditions). In addition, the Lott provides information on resources for problem gambling (e.g., counseling services) and self-exclusion. Players also have the ability to set a weekly limit for online purchases, self-monitor their gambling expenditures (using an online calculator, see here), and to check their level of risk for disordered gambling using the Problem Gambling Severity Index online (see here).

Other RG features include corporate social responsibility. In particular, the Lott has developed an RG Code of Conduct for each Australian state and territory that is publically available (e.g., for New South Wales, see here). The Lott Responsible Play Program uses a responsible gambling message, “HAVE FUN & PLAY RESPONSIBLY,” which is displayed on the “Have Fun & Play Responsibly” brochure (for a copy see here). Briefly, this brochure includes information to educate customers on how different games work and the odds of winning, on the amount of time and money spent gambling, on feelings related to one’s gambling outcomes, and information to help with problem gambling. Lastly, the Lott has received a Level 3 World Lottery Association Responsible Gambling Certification for its high standards of corporate and social responsibility (see here).

New Zealand. Lotto New Zealand provides customers with the opportunity to purchase lottery tickets online (see here). To do so, people must register an account online using a New Zealand issued credits card (see FAQ here). If a customer does not have a credit card, then they can use their New Zealand bank account with two pieces of government issued identification (e.g., passport, driver’s licence) to register an account. Note that there is no age limit for playing lotto in New Zealand (see FAQ).

Lotto New Zealand was awarded a Level 4 World Lottery Association Responsible Gambling Certification for their high standards of corporate and social responsibility (see here). In terms of RG features offered, at the bottom of the main website, there link to information on the rules, odds, and information about different games (see here). Moreover, at the bottom of the main website, there link to information on how to play responsibly (see here). This webpage

Dr. Nassim Tabri, Postdoctoral Research Fellow Department of Psychology, Carleton University [email protected] contains information on several RG tools to help players stay in control of their gambling and to play responsibly, which are pasted below from the website:

“Spending limits: Our online games have spending limits of $150 per week or $500 per month, set in conjunction with the Department of Internal Affairs and the Ministry of Health.

Lower your spending limits: You can set your own personal spending limits. When you’re logged into your account just click on My Account, then Spending Limits.

Enforced delay: To help prevent spontaneous decisions to increase your spending, once you have lowered your limits there’s a stand down period before any increase will be made active.

Block yourself from games: You can block yourself from playing any of our games on MyLotto for a time period of your choice, preventing you from purchasing tickets online during that time. Once set this cannot be cancelled or adjusted. When you’re logged into your account just click on My Account, then Spending Limits. When you block yourself from a game we will automatically stop any subscription for that game.

Exclusion from email reminders: When you block yourself from our games we automatically remove you from our email communications for that game, for the duration of your self- exclusion. You can also unsubscribe from our email reminders at any time.

Maximum account balances: You cannot deposit funds to the credit of your account in excess of $999. If your account balance is higher than $999 due to prizes credited to your account you cannot purchase tickets until you have reduced the balance of your account to under $999.

Blocking yourself from our retail stores: You can also exclude yourself from our retail stores. Email [email protected] for more information.

Know the odds: The odds of all our games are available to help you make informed choices based on the facts and keep your chances of winning in perspective.

Know the warning signs and where to get help: Our Have fun and play responsibly brochure provides information on the warning signs of potential problem gambling and provides information on where to get help.”

International. Online lottery agents enable people to participate in lotteries played around the world via the internet, barring that no local law prohibits a player’s involvement (for a recent list of websites, see here). The basic idea is that when an international customer purchases a ticket, an agent from the online lotto operator physically goes to a local certified lottery agent and purchases the ticket for the international customer. The name of the customer is printed on the ticket to confirm that s/he is indeed the owner. There are many international online lotto organizations (for a list, see here) and RG features vary little between organizations with most having few RG features. For instance, the oldest online lottery agent is the Lotter in the UK (see here). The Lotter has an RG policy that can be viewed here (see section 43 in Terms of Use). Briefly, the policy indicates that customers must be at least 18 years of age to open an

Dr. Nassim Tabri, Postdoctoral Research Fellow Department of Psychology, Carleton University [email protected] account, but it is unclear how this information is verified by the Lotter (e.g., through a third party). The policy also indicates that the Lotter recommends not to use the lottery as a source of income and that all customers establish limits for their play. The point about setting limits is important because of the easy access to numerous international lotteries with a few clicks, but it is unclear whether the Lotter provides customers with the ability to monitor and limit their play. In their Terms of Use, the Lotter also provides a link to information and resources on problem gambling (see here). This information is intended for customers who are concerned about their participation in lotteries. However, apart from the Terms of Use, there is no visible RG information on the main page of the Lotter website. As well, people can easily register an account with the Lotter with little or no verification of key customer information that may be important in terms of RG, such as age verification (see here). Likewise, another international online lottery—“PlayHuge Lottos.com”—has few, if any RG features on the main page of their website (see here) or in their Terms of Use (see here).

2) Online second chance lottery and responsible gambling features An online search was conducted to identify lottery corporations in different jurisdictions that provide customers with the option to participate in a second chance lottery (i.e., scratch/lotto tickets purchased at a physical storefront and that gives players a second chance at winning via an online lottery). Responsible gambling features in place related to second chance lotteries will be documented.

Canada. The ALC has provided residents of the Atlantic Provinces who play Scratch ‘N Win the opportunity to play a second chance lottery (see here). Although the second chance lottery has ended in February (2017; see here), ALC is planning another second chance lottery (see here). To play ALC’s second chance lottery, players must have purchased eligible Scratch ‘N Win tickets at a storefront retailer for a second chance at winning various prizes. The player has to enter their eligible ticket information online via a website (see here) and thus has to have an account with ALC. Players must be 19 years of age or older at the time of entry and be a resident of one of the Atlantic Provinces, and have their account be in good standing with ALC. Eligibility requirements (e.g., age, identity, residence) are only verified among potential winners prior to awarding prizes (see Rules here). Players can access RG information on the main website (see “PLAY RESPONSIBLY” at the bottom of the main webpage here). Clicking on “PLAY RESPONSIBLY” redirects to ALC’s PlayWise RG website (see here). As mentioned in the prior section, PlayWise provides the general public with RG information (e.g., how games work, odds of winning), the ability to assess their gambling behaviour using the Problem Gambling Severity Index (see here), the ability to self-exclude, and resources for support (e.g., GamTalk forum). However, there is no RG feature specifically in place for second chance lotteries.

In Ontario, OLG has offered its customers the opportunity to play second chance lotteries. For instance, as part of a promotion in 2016 (see here), customers who purchased a ticket for the Canadian Triple Crown instant game for cash prizes were also entered in a second chance lottery to win one of 10 VIP prize packages to the 2017 Queen’s Plate. Likewise, in 2016, customers who purchased an eligible OLG Instant Bingo Game Ticket were given the opportunity to enter the Bingo 2nd Chance Internet Contest using a code on their scratch ticket (see here). To enter online, customers had to open an account on the contest website. They

Dr. Nassim Tabri, Postdoctoral Research Fellow Department of Psychology, Carleton University [email protected] also had to complete a registration form, submitting their name, address, email address, phone number, and date of birth (see “How to Enter” here). To be eligible for entry into these second chance lotteries, customers have to be at least 18 years, residing in Ontario, and not on a self- excluded list. It is unclear whether or not OLG screens the second chance lottery customers using the eligibility criteria unless they are declared a winner.

Likewise, Lotto-Quebec recently offered its customers the opportunity to play a second chance lottery in the context of a promotion for Cirque du Soleil (see here). To be eligible, players have to be at least 18 years of age and a resident of Quebec, and must hold an instant lottery ticket for the promotion (see promotion rules here). They have to open an online account and provide their first and last names, postal code, telephone number with area code, e-mail address, and the code indicated on their instant ticket for the promotion. Only winners of the second chance lottery are assessed for eligibility (see 2.1 in promotion rules here). The website for the Cirque du Soleil second chance lottery did not contain any link or information related to RG.

United States of America. Lotteries are available in 47 jurisdictions: 44 states, District of Columbia, Puerto Rico, and the US Virgin Islands (see here). Only six states (Alabama, Alaska, Hawaii, Mississippi, Nevada, and Utah) do not have state-run lotteries (see here). Of the 47 Jurisdictions that have lotteries, 44 also offer online second chance lotteries for cash/prize drawings. These jurisdictions are Arizona, Arkansas, California, Colorado, Connecticut, Delaware, District of Columbia, Florida, Georgia, Idaho, Illinois, Indiana, Iowa, Kansas, Kentucky, Louisiana, Maine, Maryland, Massachusetts, Michigan, Minnesota, Missouri, Montana, Nebraska, New Hampshire, New Jersey, New Mexico, New York, North Carolina, Ohio, Oklahoma, Oregon, Pennsylvania, , Rhode Island, South Carolina, South Dakota, Tennessee, Texas, US Virgin Islands, Vermont, Virginia, Washington, West Virginia, and Wisconsin. Puerto Rico offers instant scratch-off games, but the online search did not suggest that Puerto Rico offers a second-chance lottery. In North Dakota and Wyoming, second chance lotteries do not exist because both states do not offer instant scratch-off games (see here). The RG features for second chance lotteries vary little by jurisdiction. That is, most, if not all, lottery websites provide links to general information on RG (e.g., how games work, the odds of winning) and resources for problem gambling. As well, in the context of second chance lotteries, the players’ eligibility criteria (i.e., age, residency, and identity) are verified only for winners.

United Kingdom (UK). Second chance lotteries are not common in the UK. The online search indicated that players of the weekly lottery system in Wales are automatically including (winners and losers) into a second chance lottery at the end of the month (see here). To play the second chance lottery, players must already have an account, and their age and identity verified. Beyond the RG features covered in the previous section for purchasing online lotto tickets, there were no RG features specifically for the second chance lottery.

Likewise, customers of the Health Lottery with losing tickets are automatically entered into a second chance lottery without having to sign up or register (see here; players do not have to enter online). The odds of winning the second chance lottery are reported in the Terms and Conditions (see “Game Rules & Terms and Conditions Specific to the Health Lottery Second

Dr. Nassim Tabri, Postdoctoral Research Fellow Department of Psychology, Carleton University [email protected]

Chance Guaranteed Winner Promotion” here). There were no other RG features that were specific to the second chance lottery.

Australia. The Lott offers customers the opportunity to purchase instant tickets at a storefront (or online) and to enter their non-winning instant tickets in a second chance lottery (see here). To enter the second chance lottery, customers must create an account with “Scratch eClub” (see here). According to the Terms and Conditions, Customers have to manually enter second chance lotteries (see point 9.2 in Terms and Conditions here) online (see here). Other than the general RG features of the Lott reviewed above, there were no RG features specific to the second chance lottery or detailed RG information on the “Scratch eClub” website (see here).

New Zealand. New Zealand lotto introduced a second chance lottery where players could win $1000 cash with non-winning Instant Kiwi tickets (see here). Players can enter second chance lottoes by scanning their non-winning Instant Kiwi ticket using the Lotto NZ App, or by manually entering the ticket serial number online via the website. The RG features for online purchase of lotto tickets were reviewed in the previous section. In short, to enter the second chance lottery, customers must have a registered account with New Zealand Lotto and there were no RG features specific to the second chance lottery.