Detect the harm, intervene on the record, refer only with consent.
The plan must provide for at-risk players and a specialised assistance group. What surveillance owns is the detection layer — the indicators, the interaction log, and the line before diagnosis.
1 ·The duty in law
The responsible gaming plan must provide players with information on gambling dependence and addiction, and it must establish a specialised responsible-gaming group to provide assistance and counselling (Art. 42-B(1)). That group is a standing structure the operator has to staff — not a response improvised when a situation arises.
Where there are grounded indications that a person is affected by gambling addiction disorder, the DICJ may send their personal data to the Social Welfare Bureau (IAS) and request intervention — but only with that person's consent (Art. 16-B). The statute draws the line the property must not cross: identify and refer, do not diagnose or treat.
2 ·Where the risk sits
| Detection without a record | A host or inspector notices distress but nothing is logged. If it is not recorded, it did not happen — and the year’s execution report has a hole where an intervention should be. |
| Data moved before consent | A referral to the IAS is made, or personal data shared, without the person’s consent. Art. 16-B makes consent a condition of the referral, not a formality captured afterwards. |
| Intervention read as advice | Staff stray from an operational duty of care into counselling or diagnosis. The property’s job is to observe, interact and refer — not to treat. |
3 ·The surveillance part
Detection is a surveillance competency before it is a welfare one. The monitoring room already reads behaviour for integrity risk; the same discipline reads it for harm. Observable, defensible indicators — not speculation about a person's state of mind — are the ones worth acting on: sustained escalation of stakes after losses, session length far outside a patron's pattern, repeated ATM or cage visits within a single session, distress or aggression at the table, requests to borrow from other patrons, a return within minutes of self-imposed departure.
Indicators are a trigger to interact, not a diagnosis
None of these confirms harm. Each is a reason to bring the specialised RG group into the loop and to record an interaction. The value of the indicator set is that it makes intervention consistent and evidenced — the two properties an execution report needs and an ad-hoc judgement lacks.
The interaction record is the deliverable. Time, observation, action taken, who was notified, whether a referral was offered and whether consent was given. It is the artefact that proves the harm-prevention element of the plan was actually operating — and it is surveillance-held.
4 ·Cadence & timing
| When | What |
|---|---|
| Continuous | Watch for the indicator set across the floor; it is a monitoring duty, not a campaign. |
| Per incident | Log the interaction at the time; record consent before any personal data moves. |
| Periodic | Refresh the indicator set and re-brief hosts and pit staff on the interact-and-refer line. |
| Into 31 Dec | Interaction and referral records feed the year’s execution report (see Governance). |
5 ·The correct pathway
- Observe against the defined indicator set — behaviour, not supposition.
- Bring in the specialised RG group; keep the contact private and calm.
- Interact within the duty of care; do not counsel, diagnose or promise an outcome.
- Offer the routes available — the property’s own limits or exclusion, and the statutory options.
- If an IAS referral is appropriate, record consent before any personal data moves (Art. 16-B).
- Log the interaction in full; it is both the duty discharged and the evidence of it.
6 ·Sources
- 1.Plan must address dependence and provide a specialised assistance group — Law 16/2001 as amended by Law 7/2022, Art. 42-B(1), BO 25/2022, 22 Jun 2022Player information on addiction · specialised responsible-gaming group for assistance and counselling
- 2.IAS intervention requires the person’s consent — Law 10/2012 Art. 16-B, BO 52/2018, 27 Dec 2018DICJ may send personal data to the IAS and request intervention only with the person’s consent
- 3.Processing and interconnection of exclusion / interdiction data — Law 10/2012 Art. 16-C, applying Law 8/2005, BO 52/2018
Legal provisions are VERIFIED against the Boletim Oficial. The indicator set, the surveillance responsibilities, the cadence and the pathway are Surveillance Intelligence Asia's own analysis, graded separately from the cited record.