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  • Willy Allison

I'm Not Your Big Brother

Updated: Jan 11, 2021

Facial recognition technology finally works. But before you rush out and buy, there are some things to think about.


The Minority Report

On June 25 of this year, Bloomberg published an article titled “China's Big Brother Casinos Can Spot Who's Most Likely to Lose Big.” An intriguing headline designed to get people’s attention; it certainly got mine. The article went on to say:

Some of the world’s biggest casino operators in Macau, the Chinese territory that’s the epicenter of global gaming, are starting to deploy hidden cameras, facial recognition technology, digitally enabled poker chips and baccarat tables to track which of their millions of customers are likely to lose the most money.”

A lot to digest there. It was kind of like reading the plot of a sci-fi movie complete with robot invasions and a zombie apocalypse. A futuristic city where innocent citizens are surrounded by a laser beam force field and monitored by ruthless cyborgs armed with evil technology who track down inferior beings known as losers and terminates them. 

Back on planet Googletron, where those who type louder get more likes, the article prompted a meteor shower of internet bloggers and writers jumping on the casino big brother band wagon. They piled on with stories that were part fiction, part fantasy and part cautionary tale.

The sad thing is none of the writers got the casinos side of the story. I mean really…writers please. You give the casino industry far too much credit. We’re just not that smart. Take your virtual reality goggles off for a minute. Here’s the real story: some innovative Macau casinos are going digital.

In recent years manufacturers have been working with casinos to develop technologies that will automate table games. This will allow casinos to account for all transactions. Right now the process is manual and lacks accountability and transparency. The goal is to introduce technology that will bring us into the 21st century and allow us to account for every bet. This will help us accurately calculate players value, improve game protection and enhance compliance with anti-money laundering laws by improving the ability to KYC (know your customer) better. 

But words matter. Not long after the June 25 article, amidst the subsequent media frenzy, gaming regulators in Macau shut down the development of artificial intelligence technologies in casinos. Millions of dollars of development and countless days of trials halted, just like that. One article. Game over? The Macau regulators have since changed course and have stated that new technologies involving artificial intelligence will have to be approved by them and can only be used by casinos for security purposes.  

So What’s it All About 

It’s about privacy. It’s about people’s fear of the future in a world of artificial intelligence. In recent times there have been numerous accounts of people’s data being stolen and used by governments, politicians and corporations. Alarming stories of how we are all being manipulated by artificial intelligence. It’s no secret (anymore) that our personal information is being collected and used by many organizations for profit and gain. A lot of big data companies like Facebook, Goggle, Amazon and Cambridge Analytica have come under scrutiny. It’s now the casino industry’s turn. 

Civil liberty and privacy groups are concerned facial recognition technology is invasive. “Face-prints” are like finger prints. The thought of being face-printed without consent every time you walk into a casino is making some people anxious. They have some valid concerns. Few rules govern the use of facial recognition and image databases right now. How are images obtained? How are they stored? Are their images going to be shared or sold to third parties without their consent? Who has access to their images outside the casino? 

Although I find a lot of the big brother blogs and articles ridiculous in the way they paint a distorted reality behind a gotcha headline, there is one common message that I pretty much agree with. A plea to authorities and corporations that use facial recognition technology to be considerate of citizen’s privacy and transparent to the public by educating them on the uses of the technology. I think it is important moving forward that casinos have clearly written policies, procedures and accountability measures in place when adopting these new technologies. 

Up until recently the issue of facial recognition technology has flown under the radar. No one had really taken concerns of misusing the technology seriously. Facial recognition technology has been around for years but contrary to the imaginations of bloggers, facial recognition is currently not used in many casinos. Quite frankly, it just hasn’t been that good until now. 

The National Institute of Standards and Technology’s (NIST) conducts regular vendor tests to assess and rate the accuracy of facial recognition algorithms. The NIST claims between 2014-2018 facial recognition software got 20 times better. So after all these years, it finally works…and we want it. 

Why We Need Facial Recognition in Casinos 

To understand why casino surveillance people are excited about this stuff, you must understand the need for it. Over the last 20 years the increased responsibilities laden upon casino surveillance departments has lessened their ability to effectively watch everything. 

Responsibilities like investigating disputes, reporting procedural errors, slip and fall claims, human resource investigations, violence and CYA management practices has been added to traditional responsibilities like catching criminals, cheaters, advantage players, crooked employees and undesirables. Add compliance obligations like identifying voluntary excluded problem gamblers, anti-money laundering activity and underage patrons and it’s easy to understand how things can slip between the gaps.

Despite the extra workload, staffing levels have not changed in most surveillance departments in the last 20 years. It’s a cost casino executives chose not to bear. Artificial intelligence, in particular facial recognition technology, is viewed as a practical solution to the ever-increasing responsibilities and the shrinking pool of expertise.

Full disclosure, I am a big fan of the potential of artificial intelligence and facial recognition. We still have a way to go but we’re getting there. I think the benefits are numerous but before we dive in face first we need to collectively take a step back and think about how we intend to use  (and not use) facial recognition technology in the future. 

What would be good applications for facial recognition in casinos? For me good uses would include enhancing our ability to keep casinos clean from undesirable activity, maintaining compliance with increasing obligations under state and federal laws and staying profitable for stake holders in a highly competitive market. 

Unlike Macau regulators, I see good uses for facial recognition technology in security and marketing. From an operational perspective the introduction of facial recognition is “righting a wrong” in surveillance. For years the task given to surveillance operators to remember thousands of faces of people they’ve never met before has been a bogus premise. Those casino executives who say their existing systems are adequate are telling porky pies.The introduction of 21st century automated technology to replace a few people “looking” (or not looking) will provide a more scientific means of delivering on the promise of keeping bad people out of the casino 24/7 regardless of manning levels and workload in the monitor room. 

From a business perspective I believe the real ROI will be in collecting data to provide a broader analysis for marketing purposes and real-time alerts so operational departments can provide better service.

Before we start thinking about how facial recognition technology can be used specifically, let's drop the terminology “facial recognition.” It freaks some people out. Let’s call it “matching.” Actually, facial recognition systems don’t identify anyone. Camera images are collected and matched against a group of images in a pre-existing database. Search results are not considered positive identifiers. They are advisory and are used as an investigative lead only. The system calculates the probability that the two images maybe a match.

Sometimes an individual image can have multiple matches. Identifying anyone is still going to take a human to make a decision on the match and confirm by asking the person for valid identification. 

Here are some potential uses for automated matching technology in casinos: 

Get Outta Here! These are people who represent a threat to our reputation, our customers, our employees, our legal and moral obligations, the protection of the games and the bottom line. These people may include problem gamblers, cheats, thieves, advantage players, known and suspected criminals, disgruntled ex-employees, abusive customers, harassing customers, smelly pirate hookers and general trouble makers.

Welcome Back Mr Big. These are people that we want to roll out the red carpet for. When VIPs arrive at the casino the technology could send real-time alerts to operational departments and hosts. “Good evening Mr X, it’s nice to see you and your lovely daughter Ms X again. We have taken the liberty to book Ms X into our beautiful spa while you’re playing in the private salon this afternoon and have reserved your favorite table in our fine dining restaurant.”

Know Your Customers: Collecting demographic information from a broader analysis of your customers images to tailor personal and public promotional messages and enhance their overall experience.  

I believe the potential of matching technology in casinos won’t be realized until after it is installed in the casino environment and we have time to allow the machine learning aspect of the technology to kick in. I recently spoke to someone in the casino industry who has deployed matching technology primarily so the casino could identify voluntary and involuntary excluded people, particularly problem gamblers. The introduction of the technology has been such a success that they are now looking to expand its capabilities to collect data for marketing. 

Facing it Head On

There’s a lot of gray out there right now when it comes to people’s privacy and the law. I think regulators and government officials don’t know how to deal with the rapid pace and advancement of digital technology. Play back the video of Facebook’s Mark Zuckerberg’s testimony to the Senate explaining what the internet is. The look on the faces of those out of touch old men was priceless. Once they do work it out, I fear regulations introduced are bound to be overactive and unnecessarily restrictive. 

Let’s not wait. As an industry I think casinos should get out in front of this issue. We should be driving the narrative in consultation with all of our stakeholders, especially vendors and regulators. I believe we need to develop a code of ethics and strict internal controls in the use of camera technology and artificial intelligence. 

I suspect a lot of surveillance directors and casino executives may think this is an issue that we should put under the cone of silence. Most casinos don’t have facial recognition yet so they probably don’t care right now. Besides, when we do get the technology it’s none of their damn business how we use it.

I think it is better to be transparent to avoid public perception that we might be up to no good. That is…if we’re not up to no good. I don’t exactly have faith that all casinos will use the technology appropriately. Any weak links in our industry could cause a public backlash that leads regulators to pump the brakes on our technological progress. Self-regulation is better.

A quick story on privacy issues before I give you my bitcoins worth on what we need to do. Last century in a galaxy far far away I was a surveillance director at a major casino that had just won a monopoly to operate in the state. The state had never seen a casino before. We came to town and overnight became the largest surveillance monitored public establishment in the state. Knowing the state privacy commissioner had some typical big brother concerns about the surveillance of individuals, I called him up and invited him to visit our operation. I gave him a tour of the room so he could see for himself that we ran a professional operation with tight controls on CCTV monitoring. I think he was impressed. I also explained how we were highly regulated by the state. We sat down and he spoke openly about his concerns. I told him not to worry as we don’t do any of those things and I assured him I would address every concern he had by establishing a CCTV Code of Ethics.  I drafted a document and had everyone in the department read and sign that they understood it. The Code of Ethics addressed a number of concerns including who had access to the video, what and how long did we retain recordings, ethical monitoring (no T & A shots) and controls to ensure video recordings are not shared or sent to third parties. I held my management team responsible for enforcing the code. I sent  the Privacy Commissioner a copy of our Code of Ethics. He thanked me. I never had a problem.

The first step is to know and understand the privacy and data collection laws in your jurisdiction. Get with your legal counsel, internal controller, compliance and human resource managers and develop internal policies and controls for facial recognition technology. There are a number of resources out there that provide templates for best practices. Once you have all the relevant information, update your current CCTV policies, code of ethics and internal controls. Moving forward, your policies on facial recognition should be able to be articulated confidently by public relations people in response to any questions regarding the use of the technology. 

I believe customers want to know that casinos are safe places to come. They don’t want to be cheated, robbed, taken advantage of or hurt. Not from other people. Not from the casino. Customers want to know that their rights are not going to be violated while they are in the casino. I believe they understand the nature of casinos and accept that they are under surveillance but it comes with a trust that the technology (to borrow a line from the greatest television spy of all time Agent Maxwell Smart,“86”) is used for good and not evil.



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