Slot Machine And Biometrics

Some big looming issues for the gaming industry got an examination last week when the UNLV Boyd School of Law put together a program, “Artificial Intelligence, Biometrics and Big Data: An Analysis of Privacy Protections and Public Policy and Its Impact on Regulations.”

Ticket-in, ticket-out (TITO) is a solution for inserting, printing and redeeming tickets from machine to machine that used in more modern slot machines.Originally developed by International Game Technology (IGT) and Casino Data Systems (CDS) under the name EZ Pay, a TITO slot machine prints out a barcoded slip of paper, which can then either be redeemed for cash, or inserted for play into.

The one-day conference drilled down into those subjects as they related to marketing, privacy, responsible gaming, customer experience, regulations and more.

After a basic explanation of artificial intelligence and biometrics, the audience hear the challenges that the new science would present to the industry. With more technology, there’s more opportunity for cheating. Anonymity will disappear as cameras capture everyone with facial recognition technology. The access to the massive amounts of data and what is done with that data is problematic. And how accurate is that biometric data?

Konami Gaming’s Chief Systems Product Office Tom Soukup demonstrated how his company’s Synkros system can deploy a camera at every slot machine and table to capture the identity of everyone playing—whether they want to be identified or not. It eliminates the plastic players club cards and creates a frictionless experience for customers.

The advantages to the casino, says Soukup, is a massive improvement of player tracking and convenience for known and anonymous players. By matching a player with a face, it eliminates the use of duplicate accounts, ensures that barred and self-excluded players will be identified immediately, and players who sign up for a players club will get credit for previous play.

The use of facial recognition at kiosks will combat fraud, money laundering and suspicious activities reports, streamline the issuance of comps and tickets, and for casinos that need to identify players, no paperwork needs to be exchanged.

But nothing comes without a cost. And biometric data, including facial recognition, has its own cost.

In Illinois, where in 2008 a bill was passed that required businesses to get written approval for the use of biometric data, four casinos are being sued by people who claim they didn’t give their approval. And a recent court decision said that they plaintiffs didn’t actually have to have suffered any harm to have standing in such a suit.

Niya McCray, an attorney specializing in privacy issues, says the pushback on biometric data began with Facebook, Google, Microsoft and other but now casinos are being targeted

“Casinos have recently begun to make changes to their privacy policies that include a signoff on biometric data,” she says.

Caesars Entertainment and MGM Resorts both have recently added clauses in their terms and conditions that allow them to gather biometric data from their customers.

Up until recently, biometric data, particularly facial recognition, has been used by the casinos’ security and surveillance departments to help identify threats to their customers.

“Safety trumps privacy every time,” security expert Douglas Florence told the conference.

Katie Lever, corporate counsel for Drew Las Vegas, agreed. “Safety is the most important thing that we can provide our customers.” She recalled at a casino where she worked previously, a big entry way fish tank also included some “fish” that were actually cameras scanning the people who entered.

Alan Feldman, the chairman of the National Center for Responsible Gaming, admitted that4 there’s much the industry doesn’t know or understand about artificial intelligence and biometrics and ran down a variety of questions that still need to be answered.

“This technology into player behavior is still a work in progress” he said. “Does it predict player behavior? Can it predict who might be a problem gambler? Could it determine a diagnosis? Does it violate data protection laws and is it even an invasion of privacy?”

He said there could be unintended consequences.

“Having time limits on gambling could be just as bad as last call in a bar,” he says. “Invariably the drunk asks for two more drinks. Could the same thing happen to the problem gambler?

The promises of biometric and big data, however, hold other possibilities for casinos.

“We might be able to t know every player, every bet every time,” he says. “But will technology reduce or even increase problem gambling? What do customers and employees want? And at what cost? We need to find a balance.”

An impressive use of big data to combat problem gambling was demonstrated by Kim Mouridsen, a professor and head of neuroinformatics research at Aathus University in Denmark, and the founder of Mindway AI, which uses artificial intelligence to uncover brain anomalies caused by additions such as problem gambling. Used in combination with experts in the field, it has the potential to be able to determine whether a person is more susceptible to gambling problems.

Slot Machine And Biometrics

While concern was voiced during the conference for privacy issues, problem gambling and data security, the potential benefits of AI and biometrics was pointed out by Dan Cherry, the corporate vice president of gaming for Penn National. He says the current way they track players is woefully inadequate.

“What the players think we know about them is far beyond what we really know,” he says.

He pointed to how casinos evaluate table game players.

“There is no business area as bad as table games when it comes to knowing the profitability of our players,” he says. “We don’t evaluate on actual win/loss but depend on theo. We don’t understand when they arrive or when hey leave, how much they bet.”

Cherry compared a casino to a Target in the way it lays out its slot floor.

“Can you imagine if Target had aisles for 5¢ items, 10¢ items and 25¢ items? That’s how the casino floor is laid out with slot machines. If we knew the preferences of our customers, we could better serve them. Taking this aggregate data would allow us to merchandize our floors more effectively.”

Martin Lycka, the general counsel for online operator GVC, says compiling all the data from iGaming players doesn’t make it any easier.

“We collect an unholy amount of data for many purposes—safety and security, and improving customer experience,” he says. “But we still have a lot of work to be accomplished even with all the data we have.”

Katie Lever said security is important, but the data “Should be aimed at making a fantastic customer experience.”

“Some people like to be greeted by their first name and handed their favorite drink,” she says. “Others believe that’s a bit to intrusive.”

For GVC, Lycka says, “We try to personalize and customize the approach to each customer. We’ll know if a player might like to be greeted by his first name and his favorite drink.”

For regulators, artificial intelligence and biometrics is a legal and ethical issue.

Sandra Morgan, the chairwoman of the Nevada Gaming Control Board, said it presented challenges and opportunities based on the board’s mission to make sure gaming is transparent but also to make sure it’s prosperous.

“We have a need to embrace new technologies to fulfill that public policy but also protect customers and state residents,” she says.

Morgan said there has been an ongoing federal effort—including a bill introduced by Nevada Senator Catherine Cortez-Masto—to set standards for privacy issues when it comes to AI and biometrics that would superseded the patchwork of state laws that are currently in effect or being considered.

Marcus Fruchter, the administrator with the Illinois Gaming Board, said his state’s rigid privacy laws have been a problem for the gaming industry and some middle ground needs to be reached.

“In our state, a player must be informed in writing about purpose and use of their biometric data and they must give a written release,” he says. “Is that reasonable?”

He says banning AI and biometrics isn’t the answer.

“It’s just not reasonable,” he says. “It inhibits innovation and only hurts our state. We should have informed consent, click thrus, clarity and options for our customers.”

1(1) 2The Legislature finds that individuals and entities that are licensed under this section require heightened state scrutiny, including the submission by the individual licensees or persons associated with the entities described in this chapter of fingerprints for a criminal history record check.
44(2)(a) 45The following slot machine occupational licenses shall be issued to persons or entities that, by virtue of the positions they hold, might be granted access to slot machine gaming areas or to any other person or entity in one of the following categories:
881. 89General occupational licenses for general employees, including food service, maintenance, and other similar service and support employees having access to the slot machine gaming area.
1142. 115Professional occupational licenses for any person, proprietorship, partnership, corporation, or other entity that is authorized by a slot machine licensee to manage, oversee, or otherwise control daily operations as a slot machine manager, a floor supervisor, security personnel, or any other similar position of oversight of gaming operations, or any person who is not an employee of the slot machine licensee and who provides maintenance, repair, or upgrades or otherwise services a slot machine or other slot machine equipment.
Biometrics machine for small offices
1943. 195Business occupational licenses for any slot machine management company or company associated with slot machine gaming, any person who manufactures, distributes, or sells slot machines, slot machine paraphernalia, or other associated equipment to slot machine licensees, or any company that sells or provides goods or services associated with slot machine gaming to slot machine licensees.
250(b) 251The division may issue one license to combine licenses under this section with pari-mutuel occupational licenses and cardroom licenses pursuant to s. 273550.105(2)(b)274. The division shall adopt rules pertaining to occupational licenses under this subsection. Such rules may specify, but need not be limited to, requirements and restrictions for licensed occupations and categories, procedures to apply for any license or combination of licenses, disqualifying criminal offenses for a licensed occupation or categories of occupations, and which types of occupational licenses may be combined into a single license under this section. The fingerprinting requirements of subsection (7) apply to any combination license that includes slot machine license privileges under this section. The division may not adopt a rule allowing the issuance of an occupational license to any person who does not meet the minimum background qualifications under this section.
390(c) 391Slot machine occupational licenses are not transferable.
398(3) 399A slot machine licensee may not employ or otherwise allow a person to work at a licensed facility unless such person holds the appropriate valid occupational license. A slot machine licensee may not contract or otherwise do business with a business required to hold a slot machine occupational license unless the business holds such a license. A slot machine licensee may not employ or otherwise allow a person to work in a supervisory or management professional level at a licensed facility unless such person holds a valid slot machine occupational license. All slot machine occupational licensees, while present in slot machine gaming areas, shall display on their persons their occupational license identification cards.
512(4)(a) 513A person seeking a slot machine occupational license or renewal thereof shall make application on forms prescribed by the division and include payment of the appropriate application fee. Initial and renewal applications for slot machine occupational licenses must contain all information that the division, by rule, determines is required to ensure eligibility.
565(b) 566A slot machine license or combination license is valid for the same term as a pari-mutuel occupational license issued pursuant to s. 588550.105(1)589.
590(c) 591Pursuant to rules adopted by the division, any person may apply for and, if qualified, be issued a slot machine occupational license valid for a period of 3 years upon payment of the full occupational license fee for each of the 3 years for which the license is issued. The slot machine occupational license is valid during its specified term at any licensed facility where slot machine gaming is authorized to be conducted.
664(d) 665The slot machine occupational license fee for initial application and annual renewal shall be determined by rule of the division but may not exceed $50 for a general or professional occupational license for an employee of the slot machine licensee or $1,000 for a business occupational license for nonemployees of the licensee providing goods or services to the slot machine licensee. License fees for general occupational licensees shall be paid by the slot machine licensee. Failure to pay the required fee constitutes grounds for disciplinary action by the division against the slot machine licensee, but it is not a violation of this chapter or rules of the division by the general occupational licensee and does not prohibit the initial issuance or the renewal of the general occupational license.
794(5) 795The division may:

Slot Machine And Biometrics Equipment

798(a) 799Deny an application for, or revoke, suspend, or place conditions or restrictions on, a license of a person or entity that has been refused a license by any other state gaming commission, governmental department, agency, or other authority exercising regulatory jurisdiction over the gaming of another state or jurisdiction; or
849(b) 850Deny an application for, or suspend or place conditions on, a license of any person or entity that is under suspension or has unpaid fines in another state or jurisdiction.
880(6)(a) 881The division may deny, suspend, revoke, or refuse to renew any slot machine occupational license if the applicant for such license or the licensee has violated the provisions of this chapter or the rules of the division governing the conduct of persons connected with slot machine gaming. In addition, the division may deny, suspend, revoke, or refuse to renew any slot machine occupational license if the applicant for such license or the licensee has been convicted in this state, in any other state, or under the laws of the United States of a capital felony, a felony, or an offense in any other state that would be a felony under the laws of this state involving arson; trafficking in, conspiracy to traffic in, smuggling, importing, conspiracy to smuggle or import, or delivery, sale, or distribution of a controlled substance; racketeering; or a crime involving a lack of good moral character, or has had a gaming license revoked by this state or any other jurisdiction for any gaming-related offense.
1049(b) 1050The division may deny, revoke, or refuse to renew any slot machine occupational license if the applicant for such license or the licensee has been convicted of a felony or misdemeanor in this state, in any other state, or under the laws of the United States if such felony or misdemeanor is related to gambling or bookmaking as described in s. 1111849.251112.
1113(c) 1114For purposes of this subsection, the term “convicted” means having been found guilty, with or without adjudication of guilt, as a result of a jury verdict, nonjury trial, or entry of a plea of guilty or nolo contendere.
1152(7) 1153Fingerprints for all slot machine occupational license applications shall be taken in a manner approved by the division and shall be submitted electronically to the Department of Law Enforcement for state processing and the Federal Bureau of Investigation for national processing for a criminal history record check. All persons as specified in s. 1206550.1815(1)(a)1207employed by or working within a licensed premises shall submit fingerprints for a criminal history record check and may not have been convicted of any disqualifying criminal offenses specified in subsection (6). Division employees and law enforcement officers assigned by their employing agencies to work within the premises as part of their official duties are excluded from the criminal history record check requirements under this subsection. For purposes of this subsection, the term “convicted” means having been found guilty, with or without adjudication of guilt, as a result of a jury verdict, nonjury trial, or entry of a plea of guilty or nolo contendere.
1311(a) 1312Fingerprints shall be taken in a manner approved by the division upon initial application, or as required thereafter by rule of the division, and shall be submitted electronically to the Department of Law Enforcement for state processing. The Department of Law Enforcement shall forward the fingerprints to the Federal Bureau of Investigation for national processing. The results of the criminal history record check shall be returned to the division for purposes of screening. Licensees shall provide necessary equipment approved by the Department of Law Enforcement to facilitate such electronic submission. The division requirements under this subsection shall be instituted in consultation with the Department of Law Enforcement.
1419(b) 1420The cost of processing fingerprints and conducting a criminal history record check for a general occupational license shall be borne by the slot machine licensee. The cost of processing fingerprints and conducting a criminal history record check for a business or professional occupational license shall be borne by the person being checked. The Department of Law Enforcement may invoice the division for the fingerprints submitted each month.
1487(c) 1488All fingerprints submitted to the Department of Law Enforcement and required by this section shall be retained by the Department of Law Enforcement and entered into the statewide automated biometric identification system as authorized by s. 1524943.05(2)(b)1525and shall be available for all purposes and uses authorized for arrest fingerprints entered into the statewide automated biometric identification system pursuant to s. 1549943.0511550.
1551(d) 1552The Department of Law Enforcement shall search all arrest fingerprints received pursuant to s. 1566943.0511567against the fingerprints retained in the statewide automated biometric identification system under paragraph (c). Any arrest record that is identified with the retained fingerprints of a person subject to the criminal history screening requirements of this section shall be reported to the division. Each licensed facility shall pay a fee to the division for the cost of retention of the fingerprints and the ongoing searches under this paragraph. The division shall forward the payment to the Department of Law Enforcement. The amount of the fee to be imposed for performing these searches and the procedures for the retention of licensee fingerprints shall be as established by rule of the Department of Law Enforcement. The division shall inform the Department of Law Enforcement of any change in the license status of licensees whose fingerprints are retained under paragraph (c).
1705(e) 1706The division shall request the Department of Law Enforcement to forward the fingerprints to the Federal Bureau of Investigation for a national criminal history records check every 3 years following issuance of a license. If the fingerprints of a person who is licensed have not been retained by the Department of Law Enforcement, the person must file a complete set of fingerprints as provided for in paragraph (a). The division shall collect the fees for the cost of the national criminal history record check under this paragraph and shall forward the payment to the Department of Law Enforcement. The cost of processing fingerprints and conducting a criminal history record check under this paragraph for a general occupational license shall be borne by the slot machine licensee. The cost of processing fingerprints and conducting a criminal history record check under this paragraph for a business or professional occupational license shall be borne by the person being checked. The Department of Law Enforcement may invoice the division for the fingerprints submitted each month. Under penalty of perjury, each person who is licensed or who is fingerprinted as required by this section must agree to inform the division within 48 hours if he or she is convicted of or has entered a plea of guilty or nolo contendere to any disqualifying offense, regardless of adjudication.
1928(8) 1929All moneys collected pursuant to this section shall be deposited into the Pari-mutuel Wagering Trust Fund.

Biometric Machine Images

1945(9) 1946The division may deny, revoke, or suspend any occupational license if the applicant or holder of the license accumulates unpaid obligations, defaults in obligations, or issues drafts or checks that are dishonored or for which payment is refused without reasonable cause.

Slot Machine And Biometrics Machine

1987(10) 1988The division may fine or suspend, revoke, or place conditions upon the license of any licensee who provides false information under oath regarding an application for a license or an investigation by the division.

Slot Machine And Biometrics Fingerprinting

2022(11) 2023The division may impose a civil fine of up to $5,000 for each violation of this chapter or the rules of the division in addition to or in lieu of any other penalty provided for in this section. The division may adopt a penalty schedule for violations of this chapter or any rule adopted pursuant to this chapter for which it would impose a fine in lieu of a suspension and adopt rules allowing for the issuance of citations, including procedures to address such citations, to persons who violate such rules. In addition to any other penalty provided by law, the division may exclude from all licensed slot machine facilities in this state, for a period not to exceed the period of suspension, revocation, or ineligibility, any person whose occupational license application has been declared ineligible to hold an occupational license or whose occupational license has been suspended or revoked by the division.