The State Online Monitoring System (SOMS) has many advantages for all participants of the legal gambling market. I have repeatedly mentioned this in my posts, as well as the fact that SOMS should be introduced only with the adoption of draft Law 2713-д in order to enable more effective functioning of the regulatory system in the field of gambling. However, SOMS is a complex mechanism, each element of which needs to be worked out in detail before implementation. Player's personification during his/her identification is one of these elements. It exposes a player to a number of serious risks, and therefore should not be part of the SOMS.
From the point of view of state administration, SOMS is a unique mechanism. This system allows clear monitoring of every player's transaction with every legal gambling organizer. Certainly, it is capable of simplifying the work of the regulator, improving the reporting of market participants and ultimately putting an end to the manipulation of the real amount of taxes paid by gambling companies in Ukraine.
Being at the same level with draft Law 2713-д, SOMS is one of the two main elements that the regulatory system currently lacks to ensure the stable functioning of the legal gambling market. Just in case, I will remind you once again that both of these elements must be implemented simultaneously. And speaking of this, I am not referring to anyone personally from the government authorities, but simply emphasizing what logic of introducing SOMS should be. This logic is based on the experience of more developed Western gambling markets, where similar monitoring systems have been in place for many years. Here you will find detailed answers to questions "How?" and "Why?".
Lack of personification of player data is another very important aspect of the introduction of SOMS. Personification carries a number of risks both for the players themselves and for the relevant state body that will control the SOMS.
Risks related to the protection of players' personal data. We all know very well how often personal data leaks happen due to hacker attacks. We also see examples of leaks of personal data from tens and hundreds of thousands of social media accounts, or selling of data of bank card holders. The player of a legal gambling organizer must be protected from such technical manipulations by attackers. If the system clearly personalizes the player, that is, links the TIN and bank data to a specific full name, then this exposes players to increased risks, in particular, financial ones.
Corruption risks. If the system allows open identification of players, this means that the employees who ensure its operation will be able to access a large amount of personal data. Accordingly, if it is about a player who is an official, a political figure or just is famous person, his/her data will have an increased value, and therefore can become the subject of corruption schemes.
Risks of cyberattacks. Personification of player data significantly increases their value to attackers, and therefore significantly increases the risks of cyberattacks on government bodies that control and have access to them.
Currently, players of legal gambling establishments and legal online platforms face many obstacles, and most players are very wary of legal organizers precisely because of the identification and bureaucracy involved. That is why SOMS should not become an additional obstacle in their interaction with a licensed provider of gambling services. Because if the players are aware that someone unknown can gain access to their personal data and use it for criminal purposes, they will definitely steer clear of the legal organizers.
It is obvious that such an outflow of players to illegal gambling organizers will only worsen the situation on the legal gambling market and may lead to the collapse of all the achievements of the reform. Of course, the state has the full legal right to monitor the transactions of licensees with players. However, at the same time, it has a duty to ensure strong protection of players' data and take into account their interests. It is this balance that SOMS should be built on.
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