With the results of the review to be revealed soon, Proctor argues operators like Flutter Entertainment aren't looking to fight to retain the status quo.
However, what the executive says he does want is for the "right change" and the most "impactful approach to player protection."
Proctor wrote: "Getting to the right answer on affordability is complex and not without some knotty ethical issues. It requires finding a critical balance which allows us to protect the most vulnerable from potential harm without disproportionately impinging on the personal freedom of the vast majority of the 30 million people who enjoy a gamble in the UK every year. In essence, it is about looking at financial vulnerability in combination with a range of factors, to prevent harm.
"Inevitably this complexity makes it harder for us to come up with a neat, one size fits all answer and I recognise that the nuances and tailoring in our response will lead some to cry foul and believe that we are fighting to retain the status quo. We are not, we are looking to drive the right kind of change which works even if it isn’t easy."
In the Flutter UK & Ireland chairman's view, this means considering affordability not in isolation but in the context of other factors, such as frequency of bets, personal circumstances and changes in betting patterns.
This perhaps links to recent Oxford research that considered none of these factors, only focusing on how much a player deposited.
"So what does this mean in practice? We believe the way forward is taking a risk-based approach founded on evidence," Proctor added.
"This means not considering affordability in isolation, but in the context of many other data points including frequency of bets and deposits, personal circumstances, time, products used and, crucially, changes in usual patterns of behaviour for each customer. When all these inputs are considered together, we can take an impactful approach to player protection."
