Tuesday 1^st August 2023

Dear Mr Rhodes,

cc. Dame Caroline Dinenage MP, Chair of the Culture, Media, and Sport Committee.

We, the Gamblers Consumer Forum, write in response to evidence taken under oath by campaign organisation Gambling with Lives at the recent Culture, Media, and Sport Select Committee on 18th July 2023. Our analysis of Mr Will Prochaska’s contribution to this Committee Hearing, Strategy Director for Gambling with Lives, commits on multiple occasions a misreporting of official statistics and a misinterpretation of data and clinical classifications lifted from various studies. The Code of Practice for Statistics is based on the three pillars on trustworthiness, quality, and value, and Mr Prochaska clearly violates this philosophy when reporting figures throughout his testimony.

The Gamblers Consumer Forum was set up in July 2023 in response to the Government’s White Paper. Part of our mission, as well as being the voice of the ordinary gambler and supporting addicts with empirical, cognitive-based science, is to combat misinformation on gambling harm. It has long been the case that the debate on gambling regulation has been hijacked by groups, compiled of individuals without any clinical experience, that base their activities on the false premise that everyone is one bet away from addiction. This unchallenged anti-gambling rhetoric has led to the development of a false and exaggerated analysis of gambling addiction, inflated by statistics that are either fabricated or that are derived from studies whereby poor methodological choices would have clearly compromised the data gathered to privilege a hypothesis that gambling is an indiscriminately harmful activity.

We believe, however, Mr Prochaska extends upon this intellectual dishonesty by participating in something that completely undermines public confidence in this debate: applying his own personal prejudices and beliefs to official data and statistics, through either misreporting or misinterpretation. As an individual who holds both an undergraduate degree and a Masters of Science, it is not unreasonable to expect Mr Prochaska to have the ability to interpret data and account for potential caveats in that data, or possess the aptitude to review literature accurately on a specific subject. Given the Gambling with Lives’ Governing Document outlines a commitment to “raising awareness…through public education and disseminating research”, it is concerning to us that Mr Prochaska feels it appropriate to, rather than promote transparency in the interpretation of studies and their conclusions, to cast aspersions on the gambling industry without actually classifying key definitions central to the matter in question during his defamation.

Our industry is under attack by those who have a flagrant disregard for considering the impact of their asserted falsehoods on the 99.6% of gambling consumers who bet without issue, those addicts who require specific clinical treatment from those with a specialisation in addiction recovery, and industries such as the horse racing industry, which relies heavily on funding from betting turnover. The Gambling Commission has a legal duty to stand up for each and every group of consumers, and therefore we hope you will take this letter of complaint against Mr Will Prochaska of Gambling with Lives extremely seriously. A lack of integrity in the data compromises how the industry is perceived and regulated against by lawmakers, and so it is essential that these poor practises are addressed in the strongest terms and their use eliminated from future dialogue.

We outline below where we believe Mr Will Prochaska is guilty of misreporting of official statistics.

Response to Q.234

Will Prochaska: “Between 300,000 and 1.4 million people in the UK experience gambling disorders and each of them will impact six to 10 family members.”

Analysis: To the extent that the number of people with gambling disorder (DSM-IV/ICD-10 ‘pathological gambling’) may be estimated from household prevalence surveys, this is clearly misleading. According to the Health Surveys in 2016 and 2018, the estimated rate of ‘pathological gambling’ (in respectively, Great Britain and England) was between 0.22% and 0.26%. It seems plausible that the rate was lower in 2021, when rate for DSM-IV ‘problem gambling’ (indicated by a score of 3 or more) was 30% lower than in 2018. Will Prochaska therefore appears to have:

i)                   Ignored findings from the Health Survey for England 2021 (current ‘official statistics’);

ii)                 Conflated ‘gambling disorder’, a recognised clinical diagnosis, with the sub-clinical classification ‘problem gambling’.

iii)               Used the results of the GambleAware (discredited by the Gambling Commission) to imply an upper range (rather than using the confidence intervals in the Health Survey);

iv)               The claim about six-to-ten family members impacted appears entirely unsupported.

Will Prochaska: “Oxford University research on 6.9 million Lloyds banking customers’ data shows that 25% of all gamblers are significantly harmed.”

Analysis: The study in question (Muggleton et al. 2021) does not show this at all. The study (significantly flawed because it assumed that cash outflows denoted net expenditure and failed to consider winnings or withdrawals back to the bank account) examined correlations between expenditure on gambling and expenditure on other goods, activities and services. Mr Prochaska made no attempt to give a transparent definition of what is defined as “significant harm” in relation to this figure, or how he has calculated the 25% figure cited.

Will Prochaska: “…a lot of debate focuses the on percentage of individuals who are vulnerable to addiction being tiny. Simply, that is not supported by the evidence. The evidence is that a much larger proportion of people who gamble is significantly harmed and that changes the policy response.”

Analysis: The evidence from Health Surveys is that between 0.22% and 0.26% of adults (or between 0.4% and 0.5% of adult gamblers) may be classified as DSM-IV ‘pathological gamblers’ (DSM-5 ‘gambling disorder). That is a small percentage. Disorder or addiction is not the same as harm yet throughout his giving of evidence, Mr Prochaska conflates these two very separate definitions. How large the group of those “significantly harmed” can only be estimated once “significant harm” has been defined (which Mr Prochaska fails to do). Certainly, the proportion of adults experiencing financial difficulties is relatively small (c0.5% of adults; c1% of adult gamblers) – according to results from the NHS Health Surveys.

i)                   Mr Prochaska effectively denies the validity of NHS Health Surveys as providing evidence of the prevalence of DSM-IV ‘pathological gambling’

Will Prochaska: “online slots have a 45% addiction and at-risk rate”

Analysis: An ‘addiction and at-risk rate’ is an entirely fabricated term. Health Survey shows rates of ‘problem gambling’ (not addiction) for customers who participate in different gambling activities among others. In other words, it is impossible to isolate rates of ‘problem gambling’ for specific activities. This is illustrated by the National Lottery draw, where 0.7% of players are classified as PGSI ‘problem gamblers’ (and 6.1% are classified as PGSI ‘at-risk’). Following Mr Prochaska’s interpretation would imply that 135,000 people are addicted to the National Lottery draw (with around 1 million people ‘at-risk’ because of the National Lottery). This is clearly absurd, and unevidenced by any citable literature. Mr Prochaska has therefore:

i)                   Conflated ‘problem gambling’ with addiction;

ii)                 Misinterpreted PGSI results by activity in order to inflate figures.

Will Prochaska: “If you accept the CEO of the Gambling Commission’s suggestion, 90% of the industry’s revenue comes from 5% of its customers, so you have an industry that is effectively dependent on harm.”

Analysis: The statistic used here is from Forrest & McHale (2022) but it is yet another example of Mr Prochaska adopting a personal, cherry-picked interpretation on official data. Forrest & McHale found that the top 5% of online betting accounts generated 86% of GGY (with 23% of accounts net winners over the period of observation) but for online gaming 90% of GGY was generated by the top 20% of customers. Forrest & McHale provide no information with respect to whether the top 5% of online bettors were harmed. Mr Prochaska’s statement is therefore misleading for the following reasons:

i)                   He applies findings from a study of online bettors to all gamblers (including non-remote);

ii)                 He implies that Forrest & McHale’s findings demonstrate ‘dependency on harm’ when in fact they provide no information on harm.

iii)               It seems likely that WP has misrepresented the views of the Gambling Commission.

Response to Q.252

Will Prochaska: “There are 100,000 children in the UK who are either already addicted to gambling or at risk.”

Analysis: This is a misinterpretation of findings from the Young people and Gambling Survey 2019. The Survey  provides an estimate for the number of schoolchildren (aged 11-16 years) likely to be classified as either ‘problem gamblers’ or ‘at risk gamblers’ using the adapted screening instrument, the DSM-IV-MR-J. The DSM-IV-MR-J does not provide diagnosis of ‘ gambling disorder’ (or ‘addiction’). The DSM-IV-MR-J criteria are modelled on those from the DSM-IV – but use softer definitions and lower thresholds. For example, the use of pocket money or school lunch money for gambling is defined as an “illegal act” – even when the gambling itself is legal (private bets or playing cards with friends and family). It is instructive to note that while the DSM-IV-MR-J ‘problem gambling’ rate for 16-year-olds in the last three ‘Young People and Gambling’ surveys has been 4.6%, 2.5% and 3.5%; the DSM-IV ‘problem gambling’ rate for 16-year-olds in the last three Health Surveys has been 0.0%, 0.0% and 0.0%. While rates of DSM-IV-MR-J ‘problem gambling’ may be a cause for concern, it is misleading to conflate them with problem gambling amongst adults (and even more misleading – and potentially harmful – to claim widespread ‘addiction’). The most recent edition  of the Young People and Gambling Survey (2022) report a ‘problem gambling’ rate of 0.9% and an at risk rate of 2.4% (compared with 1.7% and 2.7% in 2019). Mr Prochaska’s statement is misleading for the following reasons:

i)                   He misrepresents the findings of the Young people and Gambling Survey by conflating the DSM-IV-MR-J ‘problem gambling’ classification with ‘gambling disorder’ (or ‘addiction’).

ii)                 He elects to choose results from the 2019 survey in preference to the most recent survey (2022).

Mr Prochaska throughout his testimony uses his privileged position as evidence-giver to the Culture, Media, and Sport Select Committee as a self-indulgent opportunity to espouse his personal views on the harm caused by the gambling industry, continuously misinterpreting findings from research and conflating definitions to suit that agenda. The definition of what qualifies as addiction is the bedrock of this entire debate around gambling reform. Mr Prochaska at no time makes reference to what the definition of addiction is, and indeed makes its definition vastly unclear and ambiguous by trying to conflate it with other sub-clinical terms, of which he does not attempt to define either. Clearly it is in the best interests of the consumer to prevent poor quality evidence being given to those within the sphere of influence again, and we look forward to hearing the Gambling Commission’s response to this blatant attack against all gambling consumers, and the integrity of evidence-based debate as a whole.

Yours sincerely,

Gamblers Consumer Forum