General template
PRIVATE AND CONFIDENTIAL
Your contact details
Their contact details (see ceoemail.com)
Date
Dear…………………………,
FAILURE TO PROTECT A VULNERABLE PERSON
I was a customer of your company during (enter exact dates). After collecting evidence and taking advice I’m now writing to make a formal complaint against (enter name of company) for a failure to protect me as a vulnerable adult.
Please treat this letter as a formal complaint under your complaints procedures.
As CEO of (enter name of company) you will be aware that many gambling companies have been fined recently for breaching licensing conditions and codes of practice. As you will read later it is clear (enter name of company) failed to achieve the standard expected under the circumstances and failed to meet their licensing conditions and codes of practice.
Reasons for Complaint (not exhaustive)
- I was allowed to lose …………………………………… with no relevant intervention by (enter name of company), including enquiries into where the money was coming from.
- Following a subject access request and other enquiries (enter name of company) has confirmed that:
- (enter details of what has been found in your case) Possible examples are; multiple deposit methods, failed deposits, rapid multiple deposits, cancelled withdrawals, chasing losses, betting through the night, betting on multiple events and multiple products, etc.
In summary, I’ve shown many traits of an acute gambling disorder and (enter name of company) did nothing to protect a vulnerable person.
What I require (enter name of company) to do
- A good starting point is to accept a failure of responsibility. I’ve done this; (enter what you have done, e.g. attend Gambler’s Anonymous, being gambling free for ?? months, accessed medical help, etc), but (enter name of company) has not accepted their responsibilities despite overwhelming evidence of your failings.
- I’d also like (enter name of company) to read closely my constructive offer that follows.
I’m aware of a number of similar cases to mine that have been settled out of court, so I do feel it is in my interests to pursue this option if needed. However, I have no wish to drag my case and (enter name of company) through the courts or the Gambling Commission’s investigatory processes, which could lead to a fine or fines amounting to hundreds of thousands of pounds for (enter name of company). However, after seeking advice I now have the strength to pursue every route open to me. I would, therefore hope we can come to some sort of informal settlement that reflects the responsibilities of both parties. I’m more than willing to sign a non-disclosure agreement if a suitable offer is made by (enter date).
I look forward to hearing from you and hopefully constructively moving forward to a mutually acceptable solution without the need for the involvement of the Gambling Commission.
Yours sincerely,
(insert your name) (insert your username)
Anonymous examples
1. Use of the template
Dear *********
FAILURE TO PROTECT A VULNERABLE PERSON
I was a customer of ****** and am writing to make a formal complaint against ****** for a failure to protect me as a vulnerable adult.
Please treat this letter as a formal complaint under your complaints procedures.
Reasons for Complaint (not exhaustive)
- ****** reopened my account in the summer of 2019 after I had apparently finished a five year self exclusion.
- It’s clear from my betting history that in many roulette sessions the stakes go up as I start losing, i.e. I chase losses. When I do manage to win there are several examples of me reversing withdrawals to keep gambling.
- g. One session of roulette starts at ************. I start off by staking just over £50, which is bad enough, but mid-session I am staking nearly £700 a spin and also reverse a withdrawal and deposit more into my account. A total of 8 separate transactions for £2.4k in 20 minutes before ***************.
- This session results in me depositing over 7K as well as losing whatever was in my account at that time, which would have been several thousand, plus the £2.5k reverse withdrawal. The deposits alone involved 20 separate transactions. There are over 1000 lines of data in my betting history file at this moment in time, so over 500 spins of roulette, many of them at nearly £1k a spin.
- I was able to stake hundreds of thousands of pounds during this short period, and that is beyond most people’s means. It doesn’t appear that any checks around the affordability or sustainability of my gambling were undertaken. I had to borrow to facilitate this gambling period. It’s something that is affecting both me and my family financially today.
- From *********, I am on your website for hours every day in several sessions, lasting all day. I’d have been in work at this point, probably hiding and using meeting rooms on my own to gamble rather than do any work, so the damage done on the *** was the sixth straight day of high stakes gambling using an account that had previously been self-excluded. NB: ****** has admitted that my account should never have been reopened as I had another self-excluded account (that I wasn’t aware of), which still had several months to run on the exclusion.
- When I called to re-activate the account, you found my details based on the information I was asked for on the phone, so the claim by your staff that this could be seen as an attempt to avoid detection is nonsense. I do take the point that a gambler does have to take some responsibility, but at the same time, there is overwhelming evidence of a gambling disorder before the session on the **** and that ****** could have identified it, particularly as ****** had put me only your ‘VIP’ programme by then.
- I’ve already made several attempts to resolve this, including emails to yourself and to your escalations team and a subject access request (SAR) to access my data in order to do the aforementioned analysis. It’s fair to say that ****** has been obstructive with the SAR data, forcing me to do hours of manual analysis rather than give me the data in a format I could use, despite my request to. I’ve not been taken seriously, despite everything your business has put me through and I’ve had to fight to beat the addiction I was suffering from.
What I require ****** to do
- I expect that ****** should treat this period as if my account had never been reactivated, and refund all of the deposits made on my account in 2019. I am still thousands of pounds in debt as a result of this period of time.
- I’d also like a full apology for the issues I’ve suffered, plus the subsequent issues around not dealing with my complaint and all of the obstructions around my SAR.
I look forward to hearing from you within 14 days and hopefully constructively moving forward to a mutually acceptable solution.
Yours sincerely,
2. Example timeline
J4P now recommends that people enclose a timeline along with the template email.
- Opened ************ Account: **************.
- I was made a ******** VIP customer: Tuesday 20th **********: Losses at this point were £**,**. No income checks had or were made before the upgrade.
- March ****: 22 card reverse withdrawals for a total of £**,***. No interactions by *******.
- **** January ****: One of many periods asking for free bet tokens and rebate of losses. Notes made by ***** on personal data files. No questions, proof of income or interactions made.
**.01.***********. I asked for tokens as hasn’t had any in a while and wanted a decent bet on football and horseracing tomorrow so I gave him two.
Further asking for free bets to try to win money back. No questions or interactions of well being asked. Tokens given. ****** give me free bets as a one off again to keep me placing rather than look into my financials and check my well being.
**.02.****. I made further complaints seeking lost funds due to no cash out available.
**.03.****. I asked where I was on rebate. Account checked and no concerns raised after winning £**,*** and losing it all within a week.
- Attended VIP event ***********************. Expressed gambling activity concerns to VIP relations manager, no action taken. I was clearly showing signs I had a secret problem and not to let anyone know. No interactions or further questions asked.
- **** 20th ***** ****: I complained over rebate amount. £**,**** loss in * weeks and that rebate amount wasn’t paid correctly when I questioned it. No concerns or interactions made.
- ***day ***** August ****: Asked for the second credit card within a week to be removed from my account after losses. I was trying to prevent myself from spending on them and getting in more debt but I just added credit cards back on at a later date chasing losses and lost more. No interactions or questions asked.
- Etc, etc, etc.
- Self Excluded: Wednesday *th **** ****.
You have made your case with a gambling company CEO, what is likely to happen next? The most common response is that you will receive an email stating, “Your email to our CEO has been passed to us for investigation.”
Do not expect that investigation to be rapid (under 2-4 weeks) or fair (see example response) (https://justiceforpunters.org/gambling-company-investigation-response/).
