Department of Justice Victoria Pre-commitment Discussion Paper Response Document Contact details: Karen Franks General Manager Worldsmart Technology (08) 8373 6477 or [email protected]
Department of Justice Victoria
Pre-commitment Discussion Paper
Response Document
Contact details:
Karen Franks
General Manager
Worldsmart Technology
(08) 8373 6477 or [email protected]
Department of Justice Victoria
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
Department of Justice Victoria
Pre-commitment Discussion Paper Response Page 2
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).
Department of Justice Victoria
Pre-commitment Discussion Paper Response Page 3
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.
Department of Justice Victoria
Pre-commitment Discussion Paper Response Page 4
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
Department of Justice Victoria
Pre-commitment Discussion Paper Response Page 5
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
Department of Justice Victoria
Pre-commitment Discussion Paper Response Page 6
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.
Department of Justice Victoria
Pre-commitment Discussion Paper Response Page 7
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
Department of Justice Victoria
Pre-commitment Discussion Paper Response Page 8
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
Department of Justice Victoria
Pre-commitment Discussion Paper Response Page 9
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
Department of Justice Victoria
Pre-commitment Discussion Paper Response Page 10
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.
Department of Justice Victoria
Pre-commitment Discussion Paper Response Page 11
Attachment A: Application Form
Department of Justice Victoria
Pre-commitment Discussion Paper Response Page 12
Attachment B: Activity Statements
Department of Justice Victoria
Pre-commitment Discussion Paper Response Page 14
Attachment D: Merchandising
Department of Justice Victoria
Pre-commitment Discussion Paper Response Page 15
Attachment E: Minister’s Press Release