Gambling on your privacy iin Alberta

I sent this to the Alberta Information and Privacy Commissioner on September 1, 2010

Dear Commissioner,

Today I came across a news release from the Gaming Standards Association (GSA), of which the Alberta Gaming and Liquor Commission (AGLC) is a member, that greatly worries me. The release states that the AGLC is a member of the GSA.

The GSA's stated values include, "that open standards benefit our industry because they provide speed to market, innovation, value, and extended useful life" http://www.gamingstandards.com/index.php?page=what_is_gsa/vision_mission

The news release includes the following information, which is what concerns me about serious violations of privacy by the AGLC, as well as a definite conflict of interest between the stated goals, values, vision and mission of the GSA and the AGLC.

"The objective is to enable existing systems to link together to provide a completely integrated view of each customer from across the entire operation, including the customer's profile, their future itineraries, and past spending. Systems within the project scope include Property Management, Point-of-Sale, Player Tracking, Spa, Concierge, Show Ticketing, and other activities systems.

The effort will build upon and expand successful past efforts by GSA and HTNG in their respective arenas. HTNG's Single Guest Itinerary specification, which synchronizes customer records and itineraries across various hotel and resort systems, will be expanded to incorporate gaming activities. Elements of both HTNG's and GSA's customer profile are expected to be incorporated in a new, common profile format. The group will add historical spending activity to the structure so that hotel and casino staff can see a complete view of the value of the guest.

Implementation will occur through modest upgrades to existing systems, allowing hotels and casinos to avoid the expense and disruption of totally new systems."

http://www.marketwire.com/press-release/Leading-Technology-Associations-Team-Up-Integrate-Customer-Information-From-Wide-Range-1312345.htm

Further, a Mr. Jeff Wyton, Alberta Gaming & Liquor Commission, sits as the Chair of the Operator Advisory Committee.
http://www.gamingstandards.com/newsletter/spring09/committeeupdate.html

Reading the GSA 2010 Objectives, it appears that the purpose of the GSA is primarily to find and implement means of tracking and sharing gambling profiles and history between gaming locales and convince government/regulatory/operator bodies to approve the sharing of this personal and private information with all players in the private gaming industry in order to increase their profits through the exploitation of this information.

Goal 1 Focus On The Operators Community

1.1 Create and execute an international marketing program focused entirely on convincing operators so they understand the value proposition from requiring GSA standards in the products they buy

1.2 Ask member companies to provide details of their 2010 sales force training events and user conferences and provide GSA materials designed for those audiences or offer speakers as requested

1.3 Ensure that operator community understands that GSA standards are now the product of choice, replacing SAS and that new business functionality is only available through the GSA standards

1.4 Actively recruit international operators as GSA members

1.5 Highlight the importance of the OAC process and utilize this to grow operator’s participation in the standards development process whilst growing operator membership

Goal 2 Focus And Support Regulators

2.1 Create an on-line data dictionary to facilitate a common understanding of gaming terminology

• Populate and maintain data-dictionary with terminology as defined in GSA standards

• Populate and maintain data-dictionary with terminology as defined by the various jurisdictional technical regulations and identify as such

2.2 Target key regulatory jurisdictions, as identified by the board or the industry, to accept GSA standards and provide support to early adopters

2.3 Organize a GSA update / follow up meeting in Australia with the local industry

2.4 Educate the regulators as to the value of GSA certification, progress and technology capabilities of the GSA standards through interactive and personal communications (road trips)

2.5 Identify key publications read or events attended by regulators and promote certification value and benefits

2.6 Identify key tradeshow or conference events where regulators are present and secure speaking opportunities

http://www.gamingstandards.com/pdfs/10-GSA-072_2010_Objectives.pdf

These GSA "Goals" seem to not support the stated Core Business of the AGLC as stated in their 2010-2013 Business Plan:

Core Business 2: Gaming

The AGLC licenses and regulates all charitable gaming activities (casino table games, pull-ticket sales, raffles and bingo events) and conducts and manages ticket lotteries and all electronic gaming devices (slot machines, VLTs, and electronic bingo).

These activities are conducted in Alberta under the authority of the Criminal Code (Canada), Gaming and Liquor Act and Regulation, other federal and provincial legislation, and Board policy.

The AGLC is committed to ensuring that all gaming activities are conducted with integrity, delivered in a manner that encourages responsible gaming, meet the needs of consumers and communities, and meet the expectations of Albertans.

http://aglc.ca/pdf/aglc/business_plan_2010_2013.pdf

I hope to hear from you soon regarding my concerns about privacy regarding the AGLC. As it appears from what I have seen, this violation of privacy legislation by sharing details of gambler profiles is being actively promoted by Jeff Wyton of the AGLC who is also acting as a Chair of Operators of the GSA and not as a Regulator representative.

I look forward to hearing from you.