Independent Monitoring
INDEPENDENT MONITORING SYSTEM
1. Purpose: An Independent Monitoring System (hereafter, "IMS"), as available and approved by the Colorado Racing Commission (hereafter, the "Commission"), shall be utilized to monitor the totalisator system independently in order to ensure the security and integrity of the wagering process.
2. Monitoring System Capabilities: At a minimum, the IMS shall verify all transactions performed by the totalisator that relate to the wagering process. The IMS shall detect anomalies in the wagering process that do not comply with the Regulations or that could compromise the integrity of the wagering process, and shall provide immediate notification of the detection of such anomalies to the system operator.
A. The IMS shall produce alerts corresponding to potential wagering rule violations or other situations that could compromise the integrity of the wagering process. Additionally, the IMS shall be able to produce reports related to that monitoring activity.
B. The IMS must be designed to operate at or near real time in a high data volume environment, and shall detect and remain operational even in the case of disruption of the totalisator system.
C. Because the IMS must collect and store data that is sensitive both from a security and a commercial perspective, the IMS must ensure the security of the data collected. The data collected may only be used for the purposes set out herein. The IMS must demonstrate significant controls to prevent unauthorized access or use of the data. The IMS must adhere to the Facility Standards as they apply to the Operating Environment and Computer Room Security.3. Operation of the Monitoring System: The IMS must be operated by an IMS Provider that is an Independent Third Party organization approved by the Commission. The IMS Provider shall be responsible to operate and maintain the IMS, respond to alerts raised by the IMS (in a prompt manner), and coordinate the response procedures to the alert (as set out in section 6). The IMS Provider shall be a trusted organization or company, having no commercial or ownership interests in the Pari-Mutuel industry other than in providing Independent Monitoring Services. The IMS Provider and its employees may, at the discretion of the Commission, be subject to the licensing provisions of the Commission.
4. Supplier of the Monitoring System: The IMS Software must have been developed and supplied by an Independent Third Party, having no commercial or ownership interests in the Pari-Mutuel industry other than in providing software for monitoring, risk management and related areas of security. The IMS Software Supplier and its employees may, at the discretion of the Commission, be subject to the licensing provisions of the Commission.
5. Responsibility of the Race Meet Operator: The Race Meet Operator, either independently or through the contracted totalisator company (hereafter collectively known as the "Operator"), will be responsible, as an approved system(s) becomes available, for engaging an approved IMS Provider to provide the monitoring capabilities. The Operator of the Race Meet and the Totalisator Company must ensure that the totalisator system that is processing wagers is capable of interfacing with the IMS. The Totalisator Company must ensure that any changes to the totalisator system do not disrupt the operation of the IMS. The IMS Provider must ensure that the Commission has approved the Response Procedures defined for any alerts raised by the IMS. The Operator's engagement with the IMS Provider must provide the Commission access to the IMS Provider and the IMS through a terminal located at the discretion of the State of Colorado Division of Racing Events (hereafter, the "Division").
6. Response Procedures: The Operator, working with the IMS Provider, shall define response procedures for responding to alerts raised by the IMS. Such procedures shall define for each type of alert, what procedures shall be followed to respond to that situation. Such response procedures shall be submitted to and subject to the approval of the Division. The Division shall have the right to define its own level of notification and involvement in the response to any alert raised. The Operator shall be responsible for ensuring that the agreed response procedures are in place for in each case for which an alert is raised, and that a procedure for the maintenance of a log of alerts and responses is also in place. The IMS Provider will be responsible for ensuring these procedures are followed. The Operator and/or IMS Provider shall report to the Division on each alert that has been raised and the response that has been undertaken according to reporting obligations defined by the Commission.
7. Rights of the Commission: The Commission, through the Division, shall have the right at any time, with or without notice, to view the IMS, its reports and its data. The Commission, through the Division, shall have the right to review alerts raised and responses taken to ensure compliance with the requirements of the Race Meet Operator.