Bingo and casino equipment technical requirements and related issues Consultation Paper, April 2007
Contents Introduction and layout of this document 3 Introduction 3 Background and context 3 The Commission s broad approach 4 How to read this document 5 Chapter 1: Casino technical equipment 6 Introduction 6 Game requirements 7 Random number generation 8 Electronic device and server based system requirements 9 Specific error conditions and alert requirements 13 Wireless network systems 14 Existing equipment 15 Supervision of automated and semi-automated casino games 15 Other comments 16 Chapter 2: Bingo technical equipment 17 Introduction 17 Game requirements 18 Random number generation 19 Electronic device and server based system requirements 20 Specific error conditions and alert requirements 23 Wireless network systems 25 Bingo tickets 26 Existing equipment 27 Other comments 28 Chapter 3: How to contribute to the consultation 29 Chapter 4: Consultation questions 30 2
Introduction and layout of this document Introduction i. The Gambling Act 2005 (the Act) gives the Gambling Commission (the Commission), as part of its statutory role, the power to attach conditions to any operating licence about equipment used in connection with the licensed activities. In addition, the Commission has the power to set technical standards for remote gambling systems (including software used in remote gambling systems). This document is a consultation on the requirements we intend to set for bingo and casino equipment using these two powers. The document brings together the requirements that will apply to remote bingo equipment relating to bingo made available in licensed premises (such as equipment used in the National Game), ancillary remote bingo and casino equipment (such as automated roulette wheels) and non-remote bingo and casino equipment (such as random number generators for non-remote bingo, and live roulette wheels). ii. In September 2006 the Commission published a legal and policy statement, Licensing and technical standards with regard to bingo and casino equipment, which explained the licences that will be needed under the Act in order to supply and operate various bingo and casino equipment. Operators who are not sure which licence they will need to operate or supply equipment under the Act can access this statement on our website, www.gamblingcommission.gov.uk. iii. In November 2006, the Commission published Licence Conditions and Codes of Practice Issue 1 (LCCP Issue 1). This set out that bingo and casino operating licensees would be required to comply with the Commission s specifications for bingo and casino equipment. It also stated that remote gambling and gambling software operating licences would require licensees to comply with the Commission s technical standards and requirements relating to the timing of, and procedures for, testing. This indicated our intention to use the two powers under the Act to set requirements for all types of bingo and casino equipment. iv. This document now invites comments about the requirements we intend to apply to both remote and non-remote bingo and casino equipment. It is likely to be of particular interest to those who wish to be licensed by the Commission as: remote bingo operators supplying bingo in licensed premises; ancillary remote bingo or casino operators; and manufacturers or suppliers of software used in remote bingo or casino. v. Although manufacturers and suppliers of non-remote bingo and casino equipment will not need to be licensed by the Commission, they will nevertheless be interested in this consultation, because bingo and casino operators will only be able to make available equipment which meets our requirements. vi. This document does not contain the requirements relating to forms of remote gambling that are made available outside of licensed premises, such as internet or mobile phone casino and bingo games or the requirements relating to gaming machines. We have carried out separate consultations on those standards, in the Remote Technical Standards consultation paper and Gaming Machine Technical Standards consultation paper respectively, which can be accessed on our website at www.gamblingcommission.gov.uk. vii. Information about how to respond is available in chapter 3. Background and context viii. Under the current regime the trade associations and the Commission have in place a number of agreed guidelines or voluntary codes for bingo and casino operators using this type of equipment under the existing legislation, including guidance on the use of electronic bingo terminals. They are a mixture of technical and operational guidance and they are not legally enforceable. 3
ix. Bingo clubs and casinos use a wide range of equipment that is integral to the games being played, but is not classified as gaming machines. In bingo this equipment includes random number generators (which are used in playing bingo in reliance on non-remote bingo operating licences) and electronic bingo terminals (which are covered by ancillary remote bingo operating licences). In casinos it includes roulette wheels (which are covered by non-remote casino operating licences), fully-automated casino games, and terminals linked to live casino games (which are covered by ancillary remote casino operating licences). The Commission s broad approach x. The proposals in this document are what the Commission considers necessary to meet our licensing objectives, which are to: prevent gambling from being a source of crime or disorder, being associated with crime or disorder or being used to support crime; ensure that gambling is conducted in a fair and open way; and protect children and other vulnerable persons from being harmed or exploited by gambling. xi. Other Commission documents detail separate arrangements relevant to bingo and casino technical equipment, particularly the licence conditions detailed in LCCP Issue 1 and the Permitted casino games and rules for the British casino industry document scheduled for publication in August. These proposals do not duplicate what is already required by the Commission elsewhere. Also, we do not wish to impose detailed operational requirements that are not necessary to meet our licensing objectives. Existing trade association guidance and procedural documents, which may be amended and carried forward in the new regime, are the best vehicles for more detailed operational information. Examples are the Bingo Manager s Handbook and National Game Rules. xii. In drafting the proposed requirements, we have spoken to a number of bingo and casino operators and to manufacturers of bingo and casino equipment about the equipment they produce and any new equipment that may be coming onto the market. In addition, we gathered information from other jurisdictions, looking for commonalities across different regulators that might usefully be applied here. xiii. We have paid particular attention to the work that has been done on technical standards for gaming machines and where identical or similar mechanisms or systems are being used in casino and bingo equipment, we think it sensible to apply similar requirements to those that are proposed for gaming machine technical standards. It is not our intention to impose more rigorous standards than those imposed on gaming machines. xiv. We stated in the LCCP consultation document that we would be considering the options for a testing regime for such equipment. Gambling software licences and remote bingo and casino operating licences include the condition that Licensees must comply with the Commission s technical standards and with requirements set by the Commission relating to the timing and procedures for testing. The Commission can therefore implement procedures for testing software, or equipment associated with licensed facilities provided by those holding remote and ancillary remote casino or bingo operating licences. The Commission is considering the need for testing of such equipment and will discuss this issue with the industry. xv. The final requirements following this consultation are generally intended to apply from 1 September 2007. The Commission is conscious that, although most existing equipment is likely to be able to meet these requirements immediately, some older equipment will not. We would welcome views as part of this consultation about the timetable for implementing the changes. 4
How to read this document xvi. This document sets out our proposals for requirements for casino (chapter 1) and bingo (chapter 2) equipment separately. However there are some common headings across both sets of requirements: game requirements; random number generation; server based systems; specific error conditions and alert requirements; and wireless network systems. xvii. This document is primarily aimed at a technical audience, although certain sections will have broader interest. We have included a short description of the intentions of each section and, where appropriate, explanatory text, although the specifications themselves should stand alone when the final versions are published. It will be particularly important for operators, manufacturers and suppliers to consider the draft requirements themselves, rather than rely on our short explanation. The non-technical audience may be particularly interested in the game requirements section set out in both chapters and in the section on the supervision of automatic and semiautomatic table games in casinos. 5
Chapter 1: Casino technical equipment Introduction 1.1 This chapter of the consultation on casino equipment covers: fully-automated casino games (for example, an automatic roulette wheel linked to a number of terminals); semi-automated casino games (where player terminals are linked to a live game); and other casino equipment supplied or used in the provision of facilities for gambling (for example, card shufflers). 1.2 At present, the only automated and semi-automated games offered are roulette and sic bo. However, the Act makes provision for any automated versions of manually operated casino games to be made available. 1.3 To offer fully or semi-automated casino games an operator requires both a non-remote casino operating licence and an ancillary remote casino operating licence. Section 235 of the Gambling Act sets out the definition of a gaming machine and accordingly gaming machines are bound by the requirements and technical standards relating to gaming machines. Semiautomated equipment (i.e. terminals linked to a live casino game, such as roulette) and fullyautomated casino gaming equipment (again roulette is the form of casino game most commonly available) are not defined as gaming machines provided they are used in accordance with a condition attached to a licence under section 85(2)(b) of the Act. Such a condition will be attached to ancillary remote casino operating licences and states that licensees must comply with the Commission s specifications for casino equipment. 1.4 The same condition is attached to non-remote casino operating licences, and in that licence covers other casino equipment such as roulette wheels and card shufflers. The only requirements relevant to such equipment are those set out in the Random number generation section. Therefore those operators not offering partially or fully-automated games may be primarily interested in that section. In addition gambling software licences include the condition that Licensees must comply with the Commission s technical standards and with requirements set by the Commission relating to the timing and procedures for testing. 1.5 The text in the boxes under each section sets out the Commission s proposed specifications for casino equipment. The section below sets out the legal basis for the requirements. GAMBLING COMMISSION SPECIFICATION FOR CASINO EQUIPMENT Introduction This document sets out the Commission s specification for casino equipment referred to in the licence condition attached to casino operating licences by virtue of section 85(2)(b) of the Gambling Act 2005 (the Act). In the case of any machine designed or adapted to enable individuals to play real games of chance in circumstances described in section 235(2)(i) of the Act (for example fully-automated roulette) compliance with the specification is necessary in order to avoid the machine being categorised as a gaming machine. In so far as the specification deals with the operation of gambling software (computer software used in connection with remote gambling by means of equipment to which the specification relates under the auspices of an ancillary remote casino licence) it comprises the Commission s technical standards with which, by virtue of a condition on their licences, gambling software operators are required to comply. 6
Game requirements 1.6 The Commission proposes that the speed of play of fully-automated games should be similar to that of the equivalent manually operated games. The reasoning for this is that if automated equipment operates significantly faster than its traditional game equivalent it becomes more like a gaming machine and should logically be subject to the restrictions attached to such equipment. 1.7 At present only roulette and sic bo are fully-automated in this way. However, the Act makes provision for any automated versions of real casino games to be made available. As such we are proposing speed of play limits for roulette, dice games and card games. The dice game limit is set on the basis of an average speed of play for sic bo and the card game limit is set on the basis of an average speed of play for blackjack. For a card game to be considered a fullyautomated casino game rather than a gaming machine, a physical set of cards must be used and a virtual representation of the cards would not suffice. We would expect all games to meet these speed of play requirements. However, if games are developed in the future which need a specific speed of play provision appropriate to the way in which they operate, we will consider those games on a case by case basis as the need arises. 1.8 Where electronic terminals linked to semi or fully-automated games offer the possibility of playing on more than one table, the Commission proposes that players should only be able to play on one game at a time. Some terminals are linked to more than one game at present, but players are restricted to playing one game at a time and the Commission believes that it is important that this restriction continues. This ensures that there is a natural break between games and enables customers to be fully aware of what they are spending. 1.9 The proposed display of information requirements will help make sure that the games are fair and open as customers will have access to all the relevant information on their game device. 1.0 GAME REQUIREMENTS 1.1 Speed of play An electronic terminal that gives a player the opportunity to bet on the outcome of a fullyautomated real game must ensure the game cannot be played at a speed significantly faster than the manually operated equivalent and the player must be given adequate time to place their initial and any subsequent bet(s) within the game. For fully-automated real games played using electronic terminals the following game frequencies must not be exceeded: a) games of roulette: 50 games per hour; b) games played using dice: 50 games per hour; and c) games played using cards: 30 games per hour. Where electronic terminals provide a player with the opportunity to play multiple real games on the same terminal, the terminal must limit the play to a single game at a time. That is, the player must not be given opportunity to stake on a second game until the first game is completed. 1.2 Display of information on players game devices Players must be able to access on the game device, and display screens must be capable of clearly displaying, the following: a) cost of bet(s) or stake(s) to play the game; b) prize amounts available within the game; c) players credit held on the system; d) game rules; e) information on how to gamble responsibly and help for problem gamblers; and f) alarm or fault information when needed. 7
Consultation questions Q1. Do you agree that a player should only be able to gamble on one game at a time? Q2. Do you agree that automated games should operate at a speed similar to that of the equivalent manually operated games? Q3. Do you agree with the proposed speed of play limits for each type of game? Q4. Do you agree with the proposed information that must be made available to the player on the device s display screen? Q5. Should it be permissible for the information to be available on the screen of player s gaming devices to be displayed elsewhere? Q6. Do you have any other comments on this section? Random number generation 1.10 Casino games (including automated and semi-automated games) are based on randomly generated numbers which are mechanically generated (for example, by a roulette wheel). Card shufflers can in this context be considered random number generators (RNG). In order to ensure that games are fair and open it is important that the outcomes produced are sufficiently random. The requirements proposed below are intended to ensure that they are. 1.11 Examples of generally accepted statistical tests, Marsaglia s Diehard and the National Institute of Standards and Technology (NIST) tests, are given in the requirements. Other tests could be used provided they are also appropriate and could be demonstrated to be generally accepted statistical tests. 2.0 RANDOM NUMBER GENERATION Random number generation (and game results) must be acceptably random. Acceptably random here means that the system is able to pass appropriate and generally accepted statistical tests (for example, statistical test batteries such as Marsaglia s Diehard, National Institute for Standards and Technology (NIST)) and analysis designed to give a high degree of confidence in the randomness of the output. Testing must demonstrate that: a) the output from the random number generator (RNG) is uniformly distributed over the entire output range; b) the output is unpredictable, i.e. it is computationally infeasible to predict what the next number will be, given complete knowledge of the algorithm or hardware generating the sequence, and all previously generated numbers; c) random number generation does not reproduce the same output stream (cycle), and that two instances of a RNG do not produce the same stream as each other (synchronise); d) any forms of seeding and re-seeding used do not introduce predictability; and e) any scaling applied to the random output complies with a) to d) above. 8
2.1 Mechanically based RNG games Mechanically based RNG games are games that use the laws of physics to generate the outcome of the game and must conform to the following rules: a) they must meet the requirements of Section 2.0; b) the mechanical pieces must be constructed of materials that prevent decomposition of any component over time (e.g. a ball must not disintegrate); and c) the properties of physical items used to generate the random outcome must not be altered. 2.2 Scaling algorithms If a random number with a range shorter than that provided by the RNG is required for some purpose within the gaming device, the method of re-scaling, (i.e. converting the number to the lower range), must be designed in such a way that all numbers within the lower range are equally probable. Consultation questions Q7. Do you think that these requirements are sufficient to ensure that genuinely random numbers are generated? Q8. Do you agree that card shufflers should be considered random number generators and that they should meet the same requirements as other random number generators? Q9. Do you have any other comments on this section? Electronic device and server based system requirements 1.12 More recent server based systems in the market involve a number of terminals being linked to a separate dedicated server. This section proposes requirements for such servers and will also apply to systems that don t have a dedicated server, but use one of the linked terminals as a server. The requirements are intended to ensure that the systems are secure, are able to provide an adequate audit trail to meet the operator s money laundering responsibilities, support social responsibility measures, can cope with service interruption and help to resolve any disputes. 1.13 The significant events which must be recorded are, for the purposes of these requirements, the error conditions listed in section 4, a) to q), of the requirements (see page 13). These are significant events that the terminal can automatically record. Other significant events, such as a complaint or dispute, cannot be automatically recorded by the terminal, so are not relevant here. The approach to, and recording of, complaints and disputes is dealt with in LCCP issue 1. 1.14 The proposed requirement relating to cashless play and self exclusion is intended to help operators enforce self-exclusion. It is not always possible for staff to recognise a customer and where the terminals can refuse to accept smart card payments from that customer, it can add an extra layer of protection in helping that customer implement their self-exclusion agreement. 1.15 The Commission proposes that a full audit trail should be maintained for a minimum of three months. Operators may wish to hold such data for a longer period for their own benefit. 9
3.0 ELECTRONIC DEVICE AND SERVER BASED SYSTEM REQUIREMENTS 3.1 General requirements The following must apply: a) any server used in the gaming process must be housed securely; b) a full audit trail for all financial transactions and significant events must be maintained for a minimum period of three (3) months (significant events are those listed in section 4 below, points a) to q) as applicable); and c) a data back-up must be carried out on a daily basis. 3.2 Service interruption and resumption Operators must take all reasonable steps to ensure that their policies for dealing with service interruptions are fair and do not systematically disadvantage customers. After a service interruption (e.g. power down), the system must be able to recover to the state it was in immediately prior to the interruption occurring. If a gaming device is powered down while in an error condition, and power is later restored, the device will either: a) detect that the error has been corrected, in which case play may continue; or b) if the error remains, continue to display the error message and ensure the device remains locked-up. The system must not be adversely affected by the simultaneous or sequential activation of any inputs and outputs, such as 'play buttons', which might, whether intentionally or not, cause malfunctions or invalid results. On system resumption, the following procedures must be performed as a minimum requirement: a) any communications to an external device must not begin until the program resumption routine, including self-tests, is completed successfully; b) gaming device control programs must test themselves for possible corruption due to failure of the program storage media; and c) the integrity of all critical memory must be checked. Where a peripheral device such as a note acceptor (accepting a note) or printer (printing a ticket/credit note) is in operation during a power failure, it must, where practicable, on resumption of the power either complete or restart the task successfully or display an error message indicating that such a fault has occurred. The error message must remain until the fault has been resolved by either the automatic operation of the device or by the operator. In all circumstances the metering or audit controls must be able to identify any accounting anomalies for dispute resolution purposes. 3.3 Previous game recall on electronic gaming devices Information about the current game and previous games played must always be available to view for dispute and/or complaint resolution purposes on the operation of a suitable external keyswitch, or other secure method that is not available to the player. Last play information must provide all information required to fully reconstruct the game play. All values must be displayed, including the initial credits, credits bet, credits won, and credits paid. The information must include the final game outcome, including all player choices and game features. The historic data required must be stored for a minimum of three months so that it can be called upon for evidential purposes in the event of a dispute and/or complaint. If the data is required to resolve a continuing dispute or complaint after the three months data storage period has elapsed, and the system is incapable of continuing to operate without overwriting or losing that historic data, then the system must have the facility to store the pertinent data offline until the dispute and/or complaint is satisfactorily resolved. 10
3.4 Critical memory Critical memory means computer memory used to store all data that is vital to the continued operation of the gaming device. This includes, but is not limited to, the following data: a) all electronic meters relating to audit control and security, including last bank note data; b) current value of any meters - credits and bank values; c) gaming device/game configuration data; d) information pertaining to previous games with the RNG outcome (including the current game, if incomplete); and e) software state (the last normal state the gaming device software was in before interruption). Critical memory storage must be maintained by a methodology that enables errors to be identified and corrected in most circumstances. Comprehensive checks of critical memory must be made during each gaming device restart (e.g. power up cycle). RAM and other programme storage devices that are not critical to device security (e.g. video or sound ROM) are not required to be validated. All critical data must be stored in such a way that in the event of a system or power failure, all critical data is retained and systems must be designed with sufficient redundancy to be resilient to non catastrophic faults. An un-correctable corruption of critical memory must result in an error condition. The memory must not be cleared automatically, but require a full critical memory clear to be performed by a person authorised by the operator. 3.5 System clocks Casino systems using an internal clock must use the time to provide the following: a) time stamping of all game related and financial transaction events (including CCTV footage); and b) reference clock for reporting. All clock systems within the venue must be synchronised to the current date and time (24hr format). 3.6 Cashless play If a terminal is designed for cashless play then it must be connected to a central server and in addition to the electronic device and server based system requirements, the following must also apply: a) a secure player account database must be held within the system; b) the system must allow the player to retrieve their funds at any reasonable time when the venue is open; c) a facility must be available on the premises which will show the player their current monetary balance held on the cashless medium without the requirement to transfer funds or a game having to be played. Such a facility must not offer any inducements to the player to commit money for play or further play; d) cashless systems (e.g. smartcards, ticket in-ticket out) must maintain an unbroken audit trail regardless of the number or type of gaming devices (including gaming machines) that are used between initial cash-in and the final redemption of funds from the cashless medium. If a gaming device (e.g. a gaming machine) is unable to do this and breaks the audit trail then it must be possible to reconstruct the full audit trail by other methods when needed; 11
e) the player must have the opportunity to self exclude from a gaming device at any reasonable time. A gaming device must not accept funds from a medium where the account holder has self excluded; f) during a period of self-exclusion, a device must not accept funds from a payment method which is connected to the self-excluded customer (the minimum period for self-exclusion, six months, is set out in LCCP issue 1); and g) the players must have the facility to track and/or limit the amount of money they are able to deposit onto the medium over a given period of time. The limit that the individual chooses to impose may only be set or raised once in any 24 hour period. 3.7 Printers If a gaming device is equipped with a printer that is used to make payments, it must be located in a locked area of the gaming device (e.g. require opening of the main door to access). The printed ticket/voucher/hand pay receipt must display the following information: a) operator s name and address; b) gaming device number; c) date and time (24-hour format) of issue; d) alpha-numeric currency amount; e) sequence number; f) validation number; g) unique identifier (e.g. bar code); h) transaction type (e.g. cash out ticket, hand pay receipt); and i) duplicate ticket indicator (e.g. duplicate number 3). This data must also be stored on the server. 3.8 Ticket validation Payment by ticket printer as a method of credit redemption is only permissible when there is an independent means to validate the printed ticket/voucher/hand pay receipt prior to any credit or other type of redemption. The validation system must be able to identify duplicate tickets to prevent fraud by reprinting and redeeming a ticket that was previously issued. To meet this requirement, an audit trail of at least three (3) months relating to all ticket transactions must be maintained for dispute and/or complaint resolution purposes. To aid anti-money laundering investigations, the validation system, but not the ticket itself, must provide the casino operator at the time of validating the ticket, with the following information: a) the number of games played since the last zero credit on the terminal; and b) the total cash input since the last zero credit on the terminal. This data must also be stored on the server. Consultation questions Q10. Do you believe that a full audit trail should be maintained for a minimum of three months? Q11. Do you have any other comments on this section? 12
Specific error conditions and alert requirements 1.16 This section concerns the errors, or significant events, that devices should be able to identify and communicate. The aim of these requirements is to ensure that the equipment is secure and that gambling is fair and open. For example, if a note is jammed it is important that the terminal alerts the operator to this so that the participant can have their funds returned promptly, rather than a complaint arising. 1.17 The Commission recognises that not all terminals have all of these features, for example some terminals may not accept coins, and that not all of the error conditions listed will be relevant to all devices. 4.0 SPECIFIC ERROR CONDITIONS AND ALERT REQUIREMENTS Devices must detect, display and alert the operator to the error conditions and significant events listed below (where relevant). Alerts must be cleared either by an attendant or upon initiation of a new play sequence and must be communicated to an on-line monitoring and control system, where one is in place: a) coin in/out jam; b) hopper empty or timed out; c) hopper runaway or extra coin paid out; d) RAM error (including an indication of battery failure or low battery power source); e) note acceptor-in jam; f) program error or authentication mismatch; g) door open (including note acceptor); h) reverse coin-in (coin travelling the wrong way through acceptor); and i) power reset. Printers must allow software to interpret and act upon the following conditions: j) out of paper/paper low; k) presentation error; l) printer jam/failure; and m) printer disconnected - which may only be detected when the software tries to print. Each gaming device and/or note acceptor must detect and display (for note acceptors, it is acceptable to disable or flash a light or lights) the following error conditions: n) stacker full (where installed) a note acceptor must disable itself and accept no further notes. The device does not have to generate an error message when the stacker is full; o) note jams it is acceptable for the note acceptor to indicate there is a note jam by disabling itself and accepting no further notes or by some other method; p) note acceptor door open where a note acceptor door is the device door, a door open signal is sufficient; and q) stacker door open (where installed) or stacker removed. Any note acceptor device must perform a self-test at each power up. In the event of a self-test failure, the note acceptor must automatically disable itself (i.e. enter note reject state) until the error condition has been cleared. Consultation questions Q12. Do you consider it appropriate that the requirements specify which error conditions the devices need to identify and communicate? 13
Q13. Are all the error conditions listed appropriate and are there others that should be included? Q14. Do you have any other comments on this section? Wireless network systems 1.18 The requirements proposed for wireless network systems used for casino equipment are intended to ensure that the network coverage area is clear and that the network is secure, can respond appropriately to failure and can maintain an appropriate audit trail. Most network systems in casinos covered by these requirements are currently wired rather than wireless, for example automated roulette wheels tend to be wired to their terminals. However, this may well change in the future. 1.19 The Commission does not intend to set any rules relating to voided games as a result of communication loss or other device malfunctions, as it is expected that the operator will do so in their terms and conditions which will be available to the player. 1.20 The Commission does not intend to set out exact requirements for time stamping of significant events as it is considered more appropriate that the manufacturer do so on the basis of the overall system design. 5.0 WIRELESS NETWORK SYSTEMS 5.1 Network coverage If a gaming device is designed to allow players to participate using a wireless network the following must be complied with: a) unless denoted by clear signage, there must be no areas where players may participate in any gambling using such a device where the communication signal is: i) not available; ii) of poor quality such that interruptions in play would be likely; b) there must be adequate wireless coverage so that the failure of a single transmitter does not significantly reduce the players ability to participate in the game. 5.2 Network failure Where a network failure occurs: a) all devices must alert the player within 10 seconds of the failure. It is permissible for a device to continue with any game if the network connection is restored provided that the player is not disadvantaged in any way; and b) a manual alternative method of play (e.g. keying in game outcome or other element as opposed to an automatic download via wireless network) is permissible where there is no disadvantage to the player and where there is adequate time to do so. Catch up facilities (e.g. button pressed to bring device up to current position within game) are permitted, but may only be used where the game that was in play when the network failure occurred has not been completed. 5.3 Communication requirements All protocols must use communication techniques that have proper error detection and/or recovery mechanisms which are designed to prevent unauthorised access or tampering, employing Data Encryption Standards (DES) or equivalent encryption with secure seeds or algorithms. 14
5.4 Power level display requirements Portable devices must give warnings when the battery life of the device reaches a low level. 5.5 Audit requirements An audit log of the following (as a minimum) must be retained for a minimum of three (3) months: a) a sufficient time stamping of game, financial and error events so as to be able to resolve any player disputes and/or complaints arising as a result of timing issues. For example: i) time stamp of final stake being placed within the game; ii) time stamp as to when winning determinant(s) was received by player terminal; iii) time stamp of point within the game at which no more stakes can be placed; and iv) time stamp of any warnings given that no more stakes would be accepted; b) game determinant(s) as displayed to the player (if presented differently to that received from external source); and c) total stake including any combinations placed with sufficient information to be able to determine win/loss from winning determinant(s). Consultation questions Q15. Are the requirements relating to network coverage appropriate? Q16. Are the requirements relating to network failure appropriate? Q17. Do you have any other comments on this section? Existing equipment 1.21 As mentioned in the Commission s broad approach section, the final requirements following this consultation are generally intended to apply from 1 September 2007. The Commission is conscious that, although most existing equipment is likely to be able to meet these requirements immediately, some older equipment will not. We welcome views during this consultation about the timetable for implementing the changes. Consultation questions Q18. Should existing equipment that does not meet the standards be allowed to continue to operate beyond September (and why)? Q19. If yes, for how long should casino equipment that doesn t meet the requirements be allowed to continue? Supervision of automated and semi-automated casino games 1.22 The Commission is considering whether there should be specific requirements relating to the supervision of automated and semi-automated casino games. Such a requirement could potentially be included in these technical equipment requirements, although it may more logically be included as a separate licence condition or code of practice provision, if one was considered to be necessary. However, this consultation does present an opportunity for the Commission to seek views on the issue in the context of the other requirements that will apply to these pieces of equipment. 15
1.23 LCCP Issue 1 sets out a general requirement that licensees must implement policies and procedures for customer interaction where they have concerns that a customer s behaviour may indicate problem gambling. For table games in a casino, the croupier and pit boss may contribute to the casino s approach to customer interaction. 1.24 However, it could also be argued that the croupier and pit boss are primarily concerned with handling funds and ensuring the gambling is fair, with the casino s social responsibility procedures being implemented primarily by other staff. The casino must consider how their customer interaction policy will be implemented in relation to table games, gaming machines and the automated and semi-automated terminals. As such it may not necessarily follow that additional supervision should be required specifically for the automatic and semi-automatic terminals. 1.25 The Commission currently believes that the existing conditions in LCCP issue 1 should suffice for supervision of all forms of gambling on the premises. It is for each licensee to consider how best to meet those conditions. However, we would welcome views on this issue. Consultation question Q20. Do you think there should be a specific supervision requirement in respect of automatic and semi-automatic terminals? Other comments 1.26 This chapter of the consultation sets out the requirements for casino technical equipment that the Commission considers necessary to meet its licensing objectives. However, we are keen to ensure that we have covered all relevant aspects of the equipment. Consultation question Q21. Are there any other issues that the Commission should consider in respect of casino equipment? 16
Chapter 2: Bingo technical equipment Introduction 2.1 This chapter of the consultation covers all bingo equipment used in the provision of facilities for gambling on bingo premises. Examples of such equipment include paper bingo tickets, random number generators (RNGs) and electronic bingo terminals (EBTs). 2.2 Operators who intend to provide facilities which will allow customers to gamble through the use of electronic communication, such as EBTs, electronic card marking devices and equipment used to deliver linked bingo will require a non-remote bingo operating licence and an ancillary remote bingo operating licence. 2.3 Section 235 of the Gambling Act sets out the definition of a gaming machine and accordingly gaming machines are bound by the relevant requirements and technical standards. Certain electronic bingo equipment, such as an EBT, is not defined as a gaming machine provided it is used in accordance with a condition attached to a licence under section 85(2)(b) of the Act. Such a condition will be attached to ancillary remote bingo operating licences and states that licensees must comply with the Commission s specifications for bingo equipment. 2.4 The same condition is attached to the non-remote bingo operating licences and in that licence covers equipment such as RNGs and paper bingo tickets. In addition gambling software licences include the condition that Licensees must comply with the Commission s technical standards and with requirements set by the Commission relating to the timing and procedures for testing. 2.5 The text in the boxes under each section sets out the Commission s proposed specifications for bingo equipment. The section below sets out the legal basis for the requirements. GAMBLING COMMISSION SPECIFICATION FOR BINGO EQUIPMENT Introduction This document sets out the Commission s specification for bingo equipment referred to in the licence condition attached to bingo operating licences by virtue of section 85(2)(b) of the Gambling Act 2005 (the Act). In the case of any machine designed or adapted for the playing of bingo, compliance with the specification is necessary in order to avoid the machine being categorised as a gaming machine. In so far as the specification deals with the operation of gambling software (computer software used in connection with remote gambling by means of equipment to which the specification relates under the auspices of an ancillary remote bingo licence) it comprises the Commission s technical standards with which, by virtue of a condition on their licences, gambling software operators are required to comply. 17
Game requirements 2.6 This section covers information displayed to bingo customers. The information required to be displayed on the main stage prize information board or available in real time through other means is reassuring for players and helps ensure that the game is open and fair. The display of this information is current practice. The total prize fund can be displayed as its component parts, gross value of tickets sold and total net stake money and it is still permissible to show it in that format. Previously the total prize fund has also included the total added prize money. This was funds added, by the operator, to the stakes for which players played in order to augment the available prize. There was a statutory maximum. However, under the new legislation, there will be no obligation on operators to return all stakes to players in prizes and so the term added prize money will cease to have any significance. 2.7 The proposed display of information on players gaming devices requirements will help make sure that the games are fair and open as customers will have access to all the relevant information available to them on their game device (or via another method, where appropriate). The Commission proposes that customers should be able to access, on the gaming device, the operator s policy on the charging of participation fees and the proportion of stakes, if any, paid out by way of prizes. 1.0 GAME REQUIREMENTS 1.1 Definitions Main stage bingo game: This is the primary game (or games) played in any bingo session, involving physical (paper) and/or virtual (electronic) tickets which are typically purchased before the bingo session starts. Interval bingo game: This is any game played outside of sessions of main stage bingo, entry into interval games may be purchased prior to each game starting (an example of an interval game would be mechanised cash bingo ). 1.2 Main stage prize information board The main stage prize information board must display the information listed below at all times during the game session, and it must not be permissible for a player to participate in the game without a clear and unobstructed view of the board, unless the player can clearly view the same information, in real time, by other means. Information to be displayed: a) opening and closing numbers of tickets. Physical (paper) and virtual (electronic) tickets must be displayed separately. There must be provision to display both sets of numbers from any split series permutations; b) total number of tickets sold; c) total number of tickets spoiled; d) total prize fund (this may be subdivided into its constituent parts if required); and e) details of allocation of prizes. Any determination of winners must be displayed either on the main stage prize information board or by any other means so that the information is available to all players simultaneously. 1.3 Display of information on players game devices Players must be able to access on the game device, and display screens must be capable of clearly displaying, the following: a) the information listed in Section 1.2 a to e, although this is optional if the player can clearly see the main stage prize information board (or the same information in real time) during play; 18
b) the operator s policy on the charging of participation fees and the proportion of stakes to be paid out by way of prizes; c) players credit held on the system; d) game rules and price of play information; e) information on how to gamble responsibly and help for problem gamblers; and f) alarm or fault information when needed. Consultation questions Q22. Is the list of information that must be displayed on the main stage prize information board appropriate? Q23. Should it be permissible for a player to participate in the game without being able to view the specified information? Q24. Do you agree with the proposed information that must be available on the screen of a player s gaming devices? Q25. Should it be permissible for the information to be available on the screen of a player s gaming devices to be displayed elsewhere? Q26. Do you have any other comments on this section? Random number generation 2.8 Bingo is reliant on the generation of random numbers. In order to ensure that games are fair and open it is important that the numbers produced are sufficiently random. The requirements proposed below are intended to ensure that they are. 2.9 Examples of generally accepted statistical tests, Marsaglia s Diehard and the National Institute of Standards and Technology (NIST) tests, are given in the requirements. Other tests could be used provided they are also appropriate and could be considered generally accepted statistical tests. 2.0 RANDOM NUMBER GENERATION Random number generation (and game results) must be acceptably random. Acceptably random here means that the system is able to pass appropriate and generally accepted statistical tests (for example, statistical test batteries such as Marsaglia s Diehard, National Institute for Standards and Technology (NIST)) and analysis designed to give a high degree of confidence in the randomness of the output. Testing must demonstrate that: a) the output from the random number generator (RNG) is uniformly distributed over the entire output range; b) the output is unpredictable, i.e. it is computationally infeasible to predict what the next number will be, given complete knowledge of the algorithm or hardware generating the sequence, and all previously generated numbers; c) random number generation does not reproduce the same output stream (cycle), and that two instances of a random number generator do not produce the same stream as each other (synchronise); 19
d) any forms of seeding and re-seeding used do not introduce predictability; and e) any scaling applied to the random output complies with a) to d) above. 2.1 Mechanically based RNG games Mechanically based RNG games of bingo are games that use the laws of physics to generate the outcome of the game and must conform to the following rules: a) they must meet the requirements of Section 2.0; b) the mechanical pieces must be constructed of materials that prevent decomposition of any component over time (e.g. a ball must not disintegrate); and c) the properties of physical items used to generate the random outcome must not be altered. 2.2 Mechanical ball mixing method. A mechanical device that uses air flow for mixing and randomly withdrawing balls to determine the letters, numbers or symbols to be used in a game of bingo must operate in the following manner: a) it must follow the rules for mechanically based RNG games; b) it must allow participants full view of the mixing action of the balls; and c) it must not be possible to change the random placement of the balls at the exit receptacle of the device, except when the device is shut off. 2.3 Scaling algorithms If a random number with a range shorter than that provided by the RNG is required for some purpose within the gaming device, the method of re-scaling, (i.e. converting the number to the lower range), is to be designed in such a way that all numbers within the lower range are equally probable. Consultation questions Q27. Do you agree that these requirements will ensure genuinely random numbers are generated? Q28. Do you have any other comments on this section? Electronic device and server based system requirements 2.10 More recent server based systems involve a number of terminals being linked to a separate dedicated server. These requirements also apply to systems that don t have a dedicated server, but use one of the linked terminals as a server. The systems need to support fair and open gambling and keep crime out of gambling. The requirements intend to ensure that the systems are secure, prevent fraud, are able to provide an adequate audit trail, can cope with service interruption and help to resolve any disputes. 2.11 The significant events referred to are, for the purposes of these requirements, the error conditions listed in section 4, a) to q), of the requirements (page 24). These are significant events that the machine can automatically record. Other significant events, such as a complaint or dispute, cannot be automatically recorded by the machine, so are not relevant here. The approach to, and recording of, other significant events is dealt with in LCCP issue 1. 20