A.O.P.J.N.R. gets involved in establishing more unitary position of its members and the whole slot-machine in connection with the development of standards related to monitoring systems.
Continued from last issue (ICE special edition)
Example of storing data in the event of data reset of the game board:
At the beginning of the day, the accumulated value of the entry CREDIT IN is 1240 lei. By 1 pm, 100 lei are inserted into the device so that the total value gained is 1,340 lei. Then at 1 pm the game board memory resets (RAM Clear). The system will continue to report after this reset a total value of 1.340 lei entered credit, as it was before the reset, independent from the reset procedure that took place.
Subsequently, by the end of the day, another 200 lei are entered in the credit of the machine, so at the end of the day, the heading CREDIT IN total will be 1.540 lei, and for that day the system will report inputs of 300 lei, whether this credit was introduced in different phases when compared to the moment of reset memory of the game board.
Consequently, we believe that any monitoring and reporting of the game board resets (RAM Clear) would be irrelevant because they do not affect the accumulated value monitored and reported by the monitoring system.
5. Regarding monitoring parameter “Games”, it indicates the number of spins of each machine and presses of the start button.
We do not think it will be useful for achieving the objectives of ONJN, it does not have any financial relevance, but its implementation may not pose a problem.
6. Regarding the discussion on data processing servers, will send some considerations, for the two types of architecture that they can work under:
a. The architecture of the remote central server, for which information in raw form received from gaming machines is transmitted to a set of servers located in a professional data center, which processes it and then transmitted and stored in a physical server whose only purpose is to store data. This server, which data is stored on, is physically located in Romania and contains all mandatory data, according to GEO. 77 updated. Through this server the access terminal is made available to the O.N.J.N.
The solution of using this type of architecture is preferred by certain suppliers of monitoring systems, because processes and data can unfold on a professional platform with certified data security, in a data center that holds ISO for this type of activity. Also, functioning at the required quality, speed, reliability and stability is guaranteed on a contractual basis by the company that provides the service. These professional data centers have a guaranteed up-time, achieved by connecting multiple lines of internet connection via power generators, systems that ensure continuous operation even in case of a service interruption connection. Also, the location where it works is precisely defined and is secured by permanent security and video surveillance systems, and the access to the server is constantly monitored, with no possibility of absconding or alter data without “leaving a trace”.
There are also professional methods of back-up data storage and processes developed in the event of failures or errors. Equally, a professional data center is protected effectively against cyber-attacks through advanced security solutions.
b. The architecture with the central server at the headquarters of the organizer, in which case the information in raw form from gaming machines is transmitted via the Internet and stored in a server physically situated in a location of the organizer, which processes it and then stores the data. This server can be accessed by the organizer and by O.N.J.N. through its data access provided.
This structure does not differ fundamentally from the previously presented, meaning that the data collected by SMIB interfaces of the monitoring systems installed in the premises of the organizer are sent all over the Internet to a server that processes them and stores them, except that this server it is physically stored at the headquarters of the organizer, not in a professional data center. In this embodiment, the organizer is the one who ensures the smooth functioning of the server, but also its physical security and data stored, any lost data recovery, protection against possible cyber-attacks as well as providing services necessary for its operation. These goals can be accomplished reasonably by various technical solutions, provided that in most of the cases these services can not be provided to the technical and security that a professional data center provides.
In this situation, there is the particularity that although the monitoring system offered by its provider will be audited, the audit thereof may not be able to expand in the case that the supplier is no longer responsible for storing data and for its accuracy.
However, depending on the good faith of the organizer, this type of platform can operate at reasonable and sufficient levels of quality and safety, without generating risks about the reliability of reported data.
In fact, to the extent that there is good faith of the parties involved, there can be no manipulation of data stored and reported to O.N.J.N., regardless of the chosen architecture solution of the servers.
7. Regarding the discussed topic of compulsory blocking the means of game when disconnecting the interface of the monitoring system, we bring to your attention the fact that after having experienced a wide variety of means of play, game programs and types of serial communication protocols, which we acquired in recent years, following the installation of monitoring systems on a large part of gaming equipment operated in Romania, we submit to your attention that this procedure can not be implemented comprehensively on the entire range of exploited game equipment.
The reason derives from very wide variety of equipment and technical modalities of implementation of serial communication protocols, regardless of how old that equipment is. In terms of technical guarantee, there is no such thing, because it is possible that this procedure might not certainly be working on each type of machine, and certain types of equipment clearly lack the capability to react to this type of command.
On the other hand, we believe that this procedure can be overcome without any risks in taking correct operation data because all data is stored on the memory of the mother board and will be sent to the system when reconnecting the interface.
Even in the extreme case of data loss from the memory of the game board for as long as the interface is disconnected, the parameters of play are stored in the unresetted electromechanical counters, which are secured in a sealed housing by the technical controller, and depending on the indexes they reveal, the SVZ daily register is prepared, which is anyway the only relevant document in terms of fiscal importance as it concerns the revenues obtained from the exploitation of that respective means of game.
Conclusions:
There is a real difficulty to equalize an area so diverse in terms of existing equipment operated.
Even in the case of the games with a history of less than 10 years there have been problems or atypical situations in the implementation of data transmission, for each of these situations having the need to customize the data capture of that equipment through BIMS interface of the monitoring system in order to standardize the information provided to the organizer as well as to O.N.J.N. A generalization of the phenomenon for one type of game platform or a specific communication protocol, as proposed by some participants in the discussion which we refer to, would be flawed as there are types of games currently licensed in Romania, even of the new generation, with serial communication protocols (including SAS) implemented atypical. Yet this should not lead us to conclude that through these types of games fraud will be achieved .
We strongly believe in a progressive change of legislation, so as not to impose right from the start measures that make it difficult or impossible to use certain gaming equipment, to the extent that they can meet the goal of transmission, collection and data reporting accurately, only because of the desire to generalize principles in order to preventively secure the functioning of the gaming equipment.
Final proposals:
Given the relatively short period remaining until the deadline provided for in the legislation on prohibiting takeover of data from the means of game other than in a serial way, and the difficulty of standardizing the entire spectrum of technical parameters used for gaming equipment used in Romania, we propose a set of measures conducive to the implementation of laws, as well as an effective control of its observance, without radical measures, which would be likely to restrict the use of the machinery in the market but can be properly monitored:
1. Adding a parameter to be reported to O.N.J.N. by the supplier of the monitoring system, ie. if the data are taken from the means of the game in serial format or not, whose implementation parameter to be made no later than the entry into force of the obligatory takeover data exclusively in serial format.
2. The establishment of the obligation of the supplier of the monitoring system that during its operation to collect constantly and cumulatively the data from the monitored parameters, regardless of the storage, accidental or voluntary reset or lost of data from the memory of the game board. Also, all parameters required for monitoring and reporting to O.N.J.N. must be memorized in the SMIB interface of the monitoring system for a term of operation of the means of playing of at least 48 hours after the last communication with the server.
As we described above, to the extent that the monitoring system meets necessarily those goals, a possible monitoring and reporting of memory reset of the game board is irrelevant, and its monitoring would produce only a build of additional data without incidence on the correct reporting of monitored parameters.
3. Maintaining the compulsoriness imposed to the organizer in order to have the means of game taken out of operation in case the reports are not transmitted to the monitoring system and by default to O.N.J.N. within 48 hours from the previous data transmission.
4. To the extent considered necessary, we are taking into consideration supplementing the number of monitored parameters and reported to ON.J.N. by monitoring systems, by adding parameters BET and WIN. But we do not consider useful and relevant the monitoring of the Games (Played games, Spins, etc).
It has no relevance in monitoring and interpreting accountant parameters in the class A slot-machine equipment. For the game means with limited risk, there is already compulsory monitoring for every additional stake / spin.
5. In the event of auditing of monitoring systems, serial communication types will be provided which their suppliers are entitled to collect.
6. In the content of the technical checking rules of the means of playing, mandatory verification of serial protocol transmission of all parameters that will be required to be monitored and transmitted to O.N.J.N., for all means of play that will be subject to technical verification and by default, to authorization.
From the formal point of view, certified by any procedure or document issued under previous or current legislation, can not technically discern between means of play which have natively implemented a serial communication port and those that do not have this communication port or from those which had it added subsequently by the manufacturer or by third parties.
Under these conditions, checking the compliance with individual serial transmission format of all parameters specified by legislation is the only “common denominator” of the operating activity of gambling in Romania.
Thus, it can get the certainty that every means of game correctly transmits the necessary parameters, regardless of the type of serial protocol used, the manner of its operation, installation or implementation.
Most importantly, regardless of all these features is that the means of game correctly transmit the necessary data and the monitoring system collects them properly and report them to O.N.J.N. without disturbance.
Starting with the date of implementation of these specifications in technical verification rules of the means of playing and putting them into practice within the technical check, machines which are not checked to see if they respect this obligation will no longer be allowed for approval.
Note regarding the applicability of this method of technical verification.
The verification of good serial communication of parameters to be checked at the technical verification is a simple process that does not involve complex or costly procedures for B.R.M.L. or other authorized verifiers. The equipment that they currently hold are sufficient to carry out an accurate test of the serial communication protocol of the parameters to be tested.
In a transitional basis, until the moment that this procedure will become effective, the compliance of data transmission exclusively in serial format which can be actually verified by O.N.J.N. through the report which the supplier of the monitoring system will provide, on the serial protocol data acquisition and reporting the operating mode in these conditions.
7. We must have in mind that the deadline which organizers must opt for a technical solution or another in terms of authorized machines which do not transmit data natively in serial mode is quite short, even if we assume that the shortest time starting now would be officially confirmed as how to address this situation.
However, the deadline for implementation of a solution by the deadline would not be sufficient to the extent that so far neither the organizers nor the producers could not opt for any particular technical solution in the absence of a legal framework certificate based on which to take those decisions. In these circumstances, I would suggest placing a transitional period of maximum 6 months from the deadline previously provided, during which machines that do not respect the obligation of transmitting data in serial format (as certified this by supplier monitoring service) can no longer be authorized, but the machines still in operation could continue to operate.
Noting that anyway these machines will be reported as such to O.N.J.N. by the supplier of the monitoring system, so their regime will be strictly controlled.
