GDPR Data processing modelPrevention of Conflicts of Interest in the Gambling Sector

Organisation: PrivateSector: Gambling

Processing of employee and customer identification data to detect and prevent conflicts of interest in gambling activities, such as casino employees participating as players.

Purposes (1)

A purpose is the objective pursued by the setting up of your file. It indicates what the processing of personal data will be used for, its purpose. This purpose must be clear and understandable

Prevention of customer/employee conflicts of interest

Legal obligation

- Art. 6(1)(c) UK GDPR - legal obligation: non-remote casino licensees must have and put into effect policies and procedures to manage relationships between staff and customers (Gambling Commission Licence Conditions and Codes of Practice (LCCP), condition 7.1.1 - Gambling staff - casinos). - Where no licence condition applies (e.g. betting operators following ordinary code provision 7.1.3 on gambling staff and irregular betting), Art. 6(1)(f) UK GDPR - legitimate interests (ensuring that gambling is conducted in a fair and open way and protecting the integrity of the services).

Data categories (1)

Personal data is any information relating to an identified or identifiable natural person. A natural person can be identified either directly (eg surname and first name) or indirectly (eg phone number, social security number, email or postal address, but also voice or image)

Identification of employees and customers

Data details

Date and place of birthrequired

first and last namerequired

Data conservation rules

Active base:

Retained for 1 month to perform matching checks.

No statutory period. The controller should set the period based on the frequency of the matching checks (1 month suggested, each run replacing the previous file), in line with the storage limitation principle (Art. 5(1)(e) UK GDPR).

Intermediate archiving:

not required beyond monthly refresh.

Destruction

Data subject (3)

A data subject is any person whose data is collected, retained or processed by the data processing. e.g. In a recruitement process, any candidate for a position proposed in recruitement management process

Former customers
Customers
Employees

Created at:07/08/2023

Updated on:10/05/2026

Nb using:11