The Gamblers Consumer Forum write to the Gambling Commission to raise concerns regarding their relationship with Gambling With Lives

What are Harms markers and are they working?

The Gamblers Consumer Forum have written to the Gambling Commission to raise concerns regarding their relationship with Gambling With Lives following disclosures made under an FOIA. The letter to the Commission is reproduced below:

We are writing further to disclosures made under FOIA with reference to exchanges between the Gambling Commission (‘GC’)and Gambling with Lives (‘GWL’). The release of this correspondence raises a number of concerns and questions that we have set out below (and to which we would welcome clarity).

1. GWL’s misuse of statistics

In your letter of 8th January 2024 you state that GWL has been making “incorrect uses of data” – an assessment with which the GCF agrees. We note that GWL has enjoyed exclusive and un-minuted meetings with the Secretary of State for Culture, Media and Sport and the Gambling Minister (the most recent recorded meeting was held on 16th October 2023). I therefore ask that the GC brings to attention its concerns with the misuse of statistics by GWL. GWL is or has been involved with the development of the NICE guidelines on the treatment of harmful gambling, the Department of Education’s review of harm prevention education programmes and its involvement with the Office for Health Improvement and Disparities. I ask therefore that the Department of Education and the Department of Health and Social care are also informed of your concerns with regard to the reliability of GWL’s claims. We would be grateful if you could confirm whether you will be doing this.

2. GC action to prevent the misuse of statistics

At the time of writing, the GWL website still claims that “Every day someone takes their life in the UK because of gambling”; and that both 105,000 and 80,000 UK children are “addicted to gambling or at risk”. These claims are clearly misleading (as the GC has acknowledged). I therefore remind you of your pledge to tackle the misuse of statistics as set out in your open letter last year:

“Where Official Statistics have been used inaccurately, the Commission will generally assume the misuse was accidental and ask the party to correct the record. If the party fails to do so, or declines, then we will consider referring the matter to the Office for Statistics Regulation (OSR). Something we have done recently. The Commission also reserves the right to publicly challenge the misuse of statistics by any party, if they fail to correct their misstatement.”

Please can you explain why the GC has taken no such corrective action against GWL (or even issued any warnings) despite its repeated recalcitrance on the misuse of statistics? Taking or threatening such action against certain parties and not others may expose the GC to accusations of bias.

3. GWL education programme

I note too that GWL has also misused statistics in its brochure on its harm prevention education programme. Given that this education programme was funded by a regulatory settlement payment approved by the Gambling Commission, I ask that you review the GWL education materials as a matter of urgency and that you publish an opinion on the accuracy of GWL’s use of statistics within them. I also ask that you supply the GCF with a copy of the materials so that we may carry out our own independent review.

Please can you advise whether the GC has reviewed the quality and accuracy of the GWL education materials at any point – an in particular before it approved a further regulatory settlement payment in July 2023?

4. Levy commissioning

Additional FOIA disclosures indicate that the Gambling Commission has been providing GWL with information on the commissioning of the statutory levy. Please can you state whether this information was shared exclusively with GWL and whether other interested parties such as Gamble Aware received the same information at the same time?

5. Regulatory settlement funds

One further point we wish to raise is regarding regulatory settlement funds. The documents suggest a third tranche of regulatory settlement funding was approved for GWL last year and that the organisation intended to submit a fourth. We understand that the rules around these funds state they must not be used for campaigning or lobbying. We would like to ask what mechanisms are in place to audit the use of these settlements in order to ensure that funds are used for the purposes stated and that they are not diverted to other activities (e.g. lobbying). Please can you advise what penalties are in place should these rules be transgressed and whether the misuse of statistics by organisations would have any impact on the award their future bids for further regulatory settlements.

I look forward to your response to these important points and questions.


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