The GCF write to the Gambling Commission and Minister Stuart Andrew MP with an alternative plan to affordability

What are Harms markers and are they working?

The GCF have written to the Gambling Commission and Minister Stuart Andrew MP with an alternative plan to affordability. The proposal is for the creation of an app called ‘bettor help’ which gamblers would be pointed towards when they hit certain sign of addiction markers. The idea developed with the aid of addiction specialists, would centre on helping those showing the clinical signs of addiction whilst enabling the vast majority of punters who gamble without issue to carry on, without facing the friction of proving income and wealth to bookmakers in order to spend their own money. The letter is reproduced below:

‘The Gamblers Consumer Forum are writing to you with an alternative proposal to affordability checks. We have grave concerns, as do our supporters, regarding the current format of these policies. As evidenced by the recent hearing at the Culture, Media, and Sport Select Committee, those who have designed these regulations have no insight as to the definition of the harm they are regulating, the metrics of the success or those regulations, or indeed the impact and practical application of those regulations.

According to estimates by the Gambling Commission, an overzealous application of affordability checks could potentially see one million customers face checks which could ultimately see them forced to hand over sensitive financial documentation, which will affect a significant amount of those who gamble in a perfectly healthy manner. Perhaps more concerning, there is no evidence that affordability checks will work for the addicts they purport to protect, particularly as addiction – in whatever form – is not characterised by losses incurred or money spent, but by cognitive compulsion.

As with all other addictions, there is only one real solution: clinical treatment. Clinical treatment does not try to regulate people, but tries to support, understand, and help people to identify, treat, and manage their addiction. If the Government and the Gambling Commission are to help those struggling with gambling harm, it needs to concentrate its efforts on guiding those who need it towards that treatment, rather than placing blind faith in non-clinical solutions with no proven track record of success. One of the most successful addiction recovery methods employed is that used by Alcoholics Anonymous, that sees individuals acknowledge their addiction and opt to seek clinical help. Recently, Scotland introduced minimum alcohol pricing, which, rather than reduce the number of problem drinkers, saw people displacing their food expenditure to alcohol, and has seen death by alcohol climb to a 14 year high. It is quite clear that non-clinical solutions are poor solutions for clinical problems, and indeed, can make the problem far, far worse.

We do not believe affordability checks, in their current form, will work, either in the pursuit of helping those with a gambling addiction, or simply on the basis of their impracticality. However, being one of the central features of the White Paper on gambling reform, we recognise that the Government and the Gambling Commission are committed to their mission of reducing gambling harm.

With the help and support of addiction specialists, we are therefore writing with an alternative proposal to affordability checks. We believe this proposal, endorsed by the clinicians we are now working with, will be significantly more successful in identifying those who exhibit addictive behaviours, and will not inflict collateral damage on the sporting industries that are funded in part by betting turnover. Currently, the affordability checks will disproportionately apply to significantly more customers than those who are either clinically diagnosed with a disorder or are exhibiting symptoms of being an undiagnosed potential addict. We believe our alternative proposal will alleviate current opposition towards White Paper policy, whilst also providing guidance and support to those suffering as a result of their gambling.

We also know this proposal will go a significant way to mitigating what the Right Honourable Lucy Frazer KC MP spoke about when announcing the White Paper, and that is “unchecked addiction”. Moreover, we believe this an opportunity for both the Government and the Gambling Commission to consider an alternative to affordability checks to demonstrate they are in fact believers in the democratic process of a consultation; Tim Miller’s comments at a recent Regulating the Game conference seemed to suggest the regulator had already confirmed the use of affordability checks weeks before the consultation is even due to close.

Our proposal

We propose that affordability checks are replaced with an app we’ve called Bettor Help, and we are calling on the Government and the Gambling Commission to commission it. Running parallel to this, we propose that affordability checks are replaced with ‘clinical indicator screening’ – a more robust version of the current harm markers, that see many gamblers ensnared to treat an addiction they do not have. This clinical indicator screening will seek to examine addictive behaviours, rather than ‘affordability checks’ that probe someone’s spending habits.

For this to work, bookmakers will be provided with a more robust list of clinical harm markers, universally graded by severity. When a customer triggers this, they will be sent a link to the app, and the app will contain a mechanism so the operator can see it’s been downloaded.

The app will contain the following features:

–          An article written by a gambling addiction centre about how broach the subject of a gambling addiction with friends and family

–          10 clinical screening questions written by Dr Lefever – a world leading specialist and clinician of addiction

–          An article written by a recovering addict to discuss their own path through treatment

–          An area to monitor bets and money spent

–          A template email to send to an operator asking for a break

–          An ability to potentially identify ‘vulnerable’ individuals, in keeping with the Government’s policy concepts around advertising.

–          A postcode finder that will point users to their nearest addiction clinic

–          Facts and warnings about the dangers of the black market 

The clinical screening questions for our proposal have been written by Doctor Robert Lefever, a pioneering addiction specialist, following a meeting with our Head of Communications, Abbie MacGregor, herself a PhD candidate in Neuroscience/Psychology with a Masters of Research in Cognition. Doctor Lefever earned his degree in Medicine from University of Cambridge, and opened the first addiction rehabilitation clinic in the United Kingdom where he has treated over and above five thousand patients. This has earned him a reputation for being one of the most-well respected mental health professionals in this country. It is our view, and the specialists involved in our campaign, that the current methods of diagnoses by the Gambling Commission used are simply exaggerations and examples of normal behaviour, rather than specific addictive characteristics, and therefore it is vital they are also universally ranked by severity. This ensures that harm markers above will go some way to ascertaining whether that individual exhibits signs of having the ‘genetics’ or ‘trauma’ component exuded in their gambling behaviour. The mechanisms are already in place for operators to use harm markers as a basis of intervention, allowing the Government to fulfil their assurances that affordability checks will be frictionless.

Our ten clinical screening questions to be contained in Bettor Help are listed below:

  1. Do I find that the amount that I have won or lost is often irrelevant in deciding when to stop gambling or risk tasking?
  2. Do I steal or embezzle to cover gambling losses or to cover my losses in risky ventures?
  3. Do I find it more painful to give up gambling and risk taking than a close friendship?
  4. Have others expressed repeated serious concern over my gambling or risk taking?
  5. Do I tend to accept opportunities for further gambling or risk taking despite having just completed a session or project?
  6. Do I prefer to gamble or to take risks in one way or another throughout the day rather than at particular times?
  7. Do I tend to use gambling or risk tasking as a form of comfort and strength even when I do not feel that I particularly want to gamble or to take further risks?
  8. Have I gambled or taken risks at the first opportunity to do so in case I did not get a chance later on?
  9. When my favourite form of gambling or risk taking is unavailable, do I gamble on something else I normally dislike?
  10. Do I get irritable and impatient if there is a complete break of ten minutes in a gambling session?

The Gamblers Consumer Forum understand the good intentions behind affordability checks – it wants to prevent the extent of what Doctor Lefever refers to as exposure, particularly in the online environment. Exposure, however, is simply one component of three required in the formation of the addict, and no amount of one component will compensate for the absence of another:

  1. Genetics
  2. Trauma
  3. Exposure

Therefore, simply targeting exposure will not succeed in identifying, treating, and managing gambling addiction. Our proposal aims to target all three – pointing those suffering from pathological and problematic gambling towards treatment that will confront those cognitive impulses, whilst managing their trauma and exposure under clinical care. The concept of an app is not a new advent – indeed, on the back of Drink Aware’s hugely successful campaign that aims to educate, not regulate, it launched a Drink Aware App that has received hundreds of thousands of downloads.

Doctor Lefever’s three components of addiction successfully address the important caveat in the debate: why, given its mass availability, are we are not all addicted? There is no evidence that addiction of any form is a kind of economic delinquency – it is a clinical and cognitive condition that needs specialised treatment from the professionals that are qualified to give it.

Another of the addiction specialists we are working alongside, Robert Mabbett, makes the important point that stigmatising gambling as a form of economic delinquency you might catch at a racecourse, rather than a congenital illness of the brain acquired through no fault of one’s own, actually makes addicts a lot more reluctant to come forward to seek treatment. This is an insufficiently considered point, given studies have shown that up to 63% of gambling addicts were found to have a history of alcohol abuse or dependence. If addicts are choosing not to seek treatment through fear of embarrassment, it is possible they will simply divert towards other addictive agents. Blanket affordability checks that may well stigmatise the recreational pastime of millions of people should not and cannot be treated as substitutes for the real solution, which is specific clinical treatment from trained professionals, and robust harm markers is one way of directing them towards that programme of recovery.

We have also received an overwhelming amount of support from recovering addicts following the launch of BettorHelp on our Twitter account. One commented: “I guess I’m a ‘functioning gambling addict’ who for 15 years plus has been able to control his compulsion. An addict can only give up or control their behaviour when they want to. Enforcing bans or limits as with affordability checks on an addict simply exacerbates the problem and leads them to gamble harder and faster than before as they don’t know when or where their next bet will be. The BettorHelp app would have helped me hugely. It’s not forcing me to stop, it’s giving me the opportunity to review my gambling. I knew I had a problem at 18/19 with gambling but I didn’t want to stop and was too embarrassed to talk and fearful if I did, I would have to stop completely. I would have found it far easier to open up and work on controlling my addiction and have acted sooner had an app like this been available.”

We are in active discussion with a number of other addiction specialists and centres across the country, bringing them our proposal which we believe will allow the Government to succeed in its aims with minimal opposition. We believe giving this proposal serious consideration will act as a reassurance to the gambling public that the Government and the Gambling Commission is willing to listen to clinicians from all sides of the debate. We hope you will consider meeting with the Gamblers Consumer Forum, and those who have endorsed our Bettor Help proposal, to discuss this further. There is no perfect solution or overnight cure when it comes to addiction, but we have to accept the one simple truth: addiction is a clinical condition that requires clinical treatment. To propose anything else is to give addicts and their loved one’s false hope that it is possible to regulate addiction out of existence.’


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