Q&A: Duncan Garvie, ThePOGG

Earlier this year ThePOGG passed a big milestone after the amount returned to players via its complaints system passed the $1m mark. Manager Duncan Garvie talks to Joanne Christie about setting up the site with the goal of going into bat for players, and also gives his view on the challenges facing the UK affiliate market

iGaming Business: How did you get involved in the affiliate space?
Duncan Garvie: I started off as a player, primarily offline, but after making a reasonable amount of money doing that I wanted an activity that didn’t require so much travelling — but I still wanted to be involved in gambling.

At that point, I decided to set up a site to help gamblers find quality sites to play with, ones that were more likely to treat them fairly and less likely to have complaints against them.

Is this why you decided on the slightly unusual model of offering a mediation service?
Personally, I wouldn’t be comfortable working within the market if we were sending players to operators that weren’t trustworthy, so it has always been our core focus to send players only to operators we feel are the very best in the market. I felt we needed a third party to stand up for players.

The way we decided to make sure that our operators were the best and were treating players fairly was to run the complaints service, so if a player came to us and said, “I’ve been treated unfairly”, we had a voice with the operator.

Not every operator responded positively to that, a lot of them don’t want to engage with third parties or do so reluctantly at best, but that’s what weeds the bad operators out and what you are left with is operators which are very player-focused and willing to listen when complaints come in.

It has been very successful — only a few months ago we passed over $1m returned to players and since that point we’ve returned almost a quarter of a million more. And we have a far closer relationship with those partners we work with than I think most affiliates do with the partners they work with.

But how do you monetise this complaints provision?
I’m reluctant to focus too heavily on monetising something of this nature. We do have a banner on our complaints page advertising some of our operators. That is in the process of a redesign and whether that remains or not I don’t know now.

I feel that the complaints monetise themselves as what you end up with is a core group of engaged gamers who regularly return to the site. Quite often these are people we’ve helped and they are active gamers — that’s the type of traffic every affiliate wants on their site.

What are the bulk of complaints you receive about?
Mostly, they are bonus terms. You’ve also got a lot that are payment related, especially in markets outside the UK. The unlicensed US market is really bad for slow payments.

Another rapidly rising area of complaints is responsible gaming. Players are becoming better educated as to what their rights are and what operators should be doing to protect vulnerable gamblers and vulnerable players.

How do you balance your advocacy approach with maintaining good relationships with operators?
Our rating system has always built into it compliance with complaints. The operators at the top of our rankings all have a long history of being transparent and willing to discuss complaints, and in most situations nobody walks away with hard feelings after a complaint.

Even when the operator ends up paying the player, most of the time a discussion convinces the operator that the right thing to do in this situation is to pay. It is just a case of having reviewed terms and conditions and making sure everything is compliant with those terms and conditions.

Most of the operators at the top of our tables are very eager to be seen as player friendly.

How long was it before you could do affiliation full time?
There was a transition period where I was still playing but as ThePOGG grew, which was relatively quickly, it soon got to the point where I didn’t have time to play anymore.

At the present time I would estimate I work about 70 hours a week – it does vary a little week to week but it would be unusual for it to be less than 60 just to keep on top of things. The player complaints do keep us very busy.

How is the business structured?
We’ve just got the one portal just now. The business structure is a complex system that is going to change shortly. We are physically based in Scotland but the business is currently based in Malta. That is likely to move back to the UK within the next few months.

We’ve had the same challenges as many affiliates in the UK, having found it difficult to get a business bank account from a banking sector that is resistant to working with the igaming community. So, unfortunately, for a time that forced us to move offshore.

How many employees do you have and what are their specialisms?
There are currently about seven people working on ThePOGG in various roles. I deal with most of the content management but we do have another full-time content writer and another part-time one.

We have a couple of programmers working on a paid-per-job basis but they are pretty much engaged all the time for us. We have somebody doing design and SEO pretty much full-time and we’ve got a systems admin who’s part-time.

Do you use third-party agencies for any of your digital marketing/acquisition activity and, if so, which types?
Not at the present time. Right now we’re looking to build these things in-house. The person heading up our SEO is developing those skills with a mind to bringing all of that in-house.

Are you worried about the possibility of operators closing down their affiliate programmes in light of Sky Bet’s closure and the recent clampdown by operators on affiliates?
I think the changes in the UK market are far more significant than many affiliates realise. You’re seeing programme after programme coming out with rather restrictive changes with regard to what affiliates can and can’t do.

I think this has been coming for a long time and I think broadly speaking it was needed. There have been a number of affiliates doing things that they absolutely never should have been doing, and operators that have been engaging with these affiliates that should have been paying more attention to what they were doing.

But I can see a kneejerk reaction is already happening among operators and I can see a lot of affiliates getting shut out of the UK market. The cost and implications for meeting compliance requirements over the next two years are only going to escalate.

It’s going to be an interesting couple of years in the market.

So do you think operators are overreacting?
The operators are responding to what they are getting told by the regulator and the Advertising Standards Authority. And, having spoken to a lot of operators about this, I do understand their frustration and we sympathise with them, especially in relation to advertising standards.

At the present time, I am not all that convinced that the rules are as clear as they need to be. I think a lot of operators are getting caught in the middle of goalposts that are moving constantly and as such they are now becoming far more wary of working with affiliates.

Specifically, they are looking to take far more control of what their affiliates are doing but whether this can work I don’t know. It will certainly be interesting to see how it develops as it is going to involve big workload challenges for affiliates, especially in relation to making sure that any bonuses they advertise have got the right terms and are up to date when those terms change.

It’s no longer going to be possible for affiliates to ignore emails from affiliate programmes about changes to terms and conditions. These are going to have to be acknowledged, recognised and acted on quickly.

Do you think that, if this is going to have a huge impact on affiliates’ workload, it could drive even further consolidation in the affiliate space?
Absolutely. In the last three years certain affiliate networks have just dominated the market and I think it is highly likely that smaller affiliates are going to struggle in the UK market. Whether the bigger affiliates are going to do any better, that remains to be seen.

If you have hundreds of sites and you are advertising an operator on all of them, that’s hundreds of sites you have to change every time a bonus term changes, so the workload implications are for them a lot higher. But these affiliates networks generally have far larger resource pools.

Does this worry you as an affiliate of your size?
Yes. It absolutely does, without question. Our primary concern is in the management of complaints and that keeps us far more accurate on bonus terms than most affiliates, but far more accurate at the present time in my opinion isn’t going to be enough.

Entirely accurate is what you will have to get to, and so we are having to take steps to improve the systems we have in place to cope with this.

How do you think the General Data Protection Regulation (GDPR) will affect the industry?
The GDPR significantly increases the restrictions that all businesses will face when dealing with personal data. Online gambling operators are going to have to be a lot more careful regarding providing players with explicit definition of who they are sharing information with and why, especially if they are relying on consent to do so.

It will no longer be sufficient to say that they are sharing data with “3rd party marketing companies”: the specific companies and the reason for sharing the data will have to be clearly laid out.

Users will also have to be provided with a clear opt-out, which is as easy to use as the opt-in, allowing them to revoke permission to share their data.

This will become even more of an issue where company structuring involves different companies under the same ownership performing different roles with the information gathered by the gambling operator.

Even though there is shared ownership, explicit detail will still have to be provided to share information.

There’s a lot that will only really become clear after the GDPR comes into effect on 25 May, 2018 but with fines for breach of such a significant nature (up to 4% of annual turnover or €20 million, whichever’s higher) any operator not acting now on this to ensure compliance is taking a significant risk.

We’ve already compiled and submitted a lengthy document to the ICO asking for clarification of various aspects of the GDPR guidance they’ve put out and made significant changes to our own privacy policies to try to get ahead of this one.

Have you been affected by the shutdown of the casino and poker markets in Australia?
We certainly had some traffic in Australia and we still have some traffic in Australia. It is one of our top 10 sources, although I can’t say we really noticed any significant difference when Australia shut up shop.

We have been growing rather rapidly at the present time so that could simply be a case of our growth having outpaced the loss.

I have no doubt it has had a significant impact on a number of affiliates — it was a valuable market and I think that fundamentally as a policy the closure of the market is a mistake.

The prohibition model has already been tried in the United States and it didn’t work there. All it ended up doing was channelling players through to more questionable operators which were prepared to flout the law.

That is my view on what is going to happen in Australia — we are already seeing it. We’re seeing an escalation in the number of complaints we see from Australian traffic and they are all about the same group of operators that up to now had been mostly accepting unlicensed US traffic.

What proportion of your traffic is now coming from mobile rather than desktop, and what challenges is this presenting?
We’re seeing close to 50% of traffic coming through from mobile now. Mobile has definitely been an issue in the last three years. We’ve had to make specific and wide-ranging changes to the design and structure of our site.

It has proved challenging, especially with the level of detail that we tend to put in our content. To make this content accessible for mobile users we’ve had to go through a lot of testing and a lot of trial and error to figure out what works and what doesn’t for mobile users.

The differences can be quite dramatic in terms of your bounce rate, your time on page and the number of pages viewed. It’s just a case of trying something, watching the figures, trying something else then switching back if it has not worked. It is an ongoing process, a constant issue.