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Automating the Licensing Application and Renewal Process in Gaming

Barth F. Aaron, Esq.

This is the third in a series of papers which translates a concept of mine from about 15 years ago into modern digital times. I have already presented that electronically stored data is at least as safe as paper writings and that the cloud is no mystery but a safe, secure and efficient mode of data storage with limited access. Its protections include an audit trail that is better than that of paper meaning more security than other data storage means. Now I will attempt to unify my previous presentations into a single concept – that of the electronic preparation, storage, transmission and filing of gaming license applications.

Paper-based license applications are inefficient. Even if one uses an elementary electronic publishing feature, where personal information is stored in a database and then merged into a template comprised of the gaming license application, there is still the printing of a paper “hard copy” of the application, manually verifying the information was properly mapped to the form and complete, manually signing the form and mailing it to the regulator. Now we face the first security issue.

You place your paper application in the mail or with an overnight delivery service. What guarantee do any of them provide that the package will be delivered untampered? In reality there is none. Anyone can steal the package – perhaps risking committing a federal crime, but there has been mail theft before. What about the unscrupulous employee, who simply opens the package, views or copies the information, reseals the package and delivers it? The point is that your personal information in paper form is there for anyone to see.

Electronic data can be encrypted, so that during transmission or storage, only authorized persons with the proper key can access it. Any unauthorized person who gains access has obtained gibberish with unreadable letters, numbers and symbols having no meaning to anyone.

Information stored in the cloud has an added advantage: access can be limited so that you can control who can see the information and who can write, modify and delete the information. Thus, when the regulator accesses your cloud-based data, they can view it. It is not downloaded to their device; they simply view the file from the server. Their access can be time-limited so that after a fixed period of time with no activity, their access is closed and they need to log in again for access. Thus, even if their tablet or laptop is lost or stolen, there is no personal information to be taken.

As I previously wrote, the data centers and server farms which comprise the physical component of the “cloud” are as secure as Fort Knox physically, with the advantage of 24/7 digital security. When one rents space at a secure data center, such as Switch NAP, there is constant digital monitoring so that not only are safeguards in place to protect against intrusion, human monitors verify the validity of access and can shut down unauthorized access immediately. Unlike paper, which can be viewed by any unknown person when you leave the file open on your desk, digital security includes a trail of access so that IP addresses and other signatures are left anytime someone accesses your file.

The system I propose is one where your personal information is entered into an account secured by your unique password and access. License application templates comprise a second database with mapping instructions so that personal information is filled onto the form appropriately. When you are ready to file an application, the system allows the merging of your appropriate personal information with the appropriate template or templates. You have access to review and approve the application and submit it electronically to the appropriate regulator or regulators. Note that you enter your personal information once but can create more than one license application at a time. An encrypted file is electronically transmitted to the regulator. The regulator can be assured that the application is complete, thus saving them an initial step in their process, since the system will not allow an application without all fields completed. Once the regulator receives the form, a series of processes can take place. Some are automated while others continue to be done manually, but all are monitored and tracked by the system, saving regulatory time and effort, creating efficiencies. These efficiencies not only allow the regulator to focus on its primary purpose of investigation and enforcement, but help control costs both for the regulator and the regulated industry.

Others, both public and private, are already electronically processing applications, from employment to other forms of licenses. There is no reason why gaming license applications cannot and should not be processed the same way. This brief outline should show the benefits of efficiency, security and safety in a cloud-based gaming license application process.

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