Tag: dan-waugh

The harm figures don’t hold, and neither does the man citing them Will Prochaska has written in PoliticsHome (funded rag) that Britain’s gambling market has left “millions of people harmed, communities held back, high streets blighted”. Every part of that sentence is contestable, and the numbers underneath it do not survive scrutiny. Even in the world of Mary a Whitehouse types there ought to be a grain of evidenceThe absurd claim that millions are harmedThe figure derives entirely from the Gambling Survey for Great Britain. Regulus Partners has shown the GSGB overstates participation in some gambling activities by as much as 728 per cent. Its problem gambling estimate of 2.7 per cent is around seven times the 0.4 per cent NHS figure that the Office for Health Improvement and Disparities itself used. Where is the documented rise in actual problem gambling rates to support his fantasies? To accept it, you must also accept that every official gambling statistic produced over seventeen years was substantially wrong, that the NHS has serially misreported the prevalence of health disorders generally, and that audited operator customer data is incorrect.The Commission’s own independent reviewer, Professor Sturgis, found the survey may substantially overstate both gambling and gambling harm errrr. The Commission’s counter-evidence on response bias was debunked by Sturgis and then suppressed, (commission has group 1 form for surpression of inconvenient information) emerging only under Freedom of Information. Its lead advisor, Professor Wardle, had already warned that the dominant effect was over-reporting within the GSGB rather than under-reporting elsewhere. The Commission has conceded the survey’s principal value may lie in trend analysis rather than measuring prevalence.Applied consistently to the same dataset, the methodology makes roughly one million National Lottery customers problem gamblers, at a cost exceeding £6.2 billion.That is the arithmetic on which the harm campaign rests.The claim that high streets are blightedBetting shop numbers have fallen from around 8,995 in 2015 to 5,825 in 2025. The Gambling Commission has confirmed roughly 3,000 closures since 2019 and more than 15,000 jobs lost. Adult Gaming Centres are fewer than they were in 2012 and have not changed materially in a decade.There is no proliferation. There is a contraction, and the regulator has said so publicly.Who is making this argument? Will Prochaska is Director of the Coalition to End Gambling Ads and previously led Gambling with Lives. CEGA states on its own website that it is funded by Las Vegas residing Derek Webb. You know him eh? The same declaration appears in his competing interests statement in the BMJ.Derek Webb made his money inventing casino table games, including three card poker. His campaigning began when he found his game running on fixed odds betting terminals without royalties. He has said publicly that instead of suing he funded a campaign to make his point. He then spent around £3 million making those machines commercially unviable through regulation. He has since given substantial sums to the Labour Party, including £750,000 in 2024 and £300,000 in 2023.So the man calling for the end of gambling advertising is funded by a man who profited from casino gaming and turned to UK regulation after a commercial dispute.That matters for the  Prochaska blurb. He cites the Social Market Foundation as ‘independent corroboration’ of his economic case. The SMF is also funded by Derek Webb! He is not citing external support. He’s one of Webb’s boys. In the clubHis own organisation’s website relies on the OHID estimate of gambling-related deaths in England. That is the same OHID analysis the Office for Statistics Regulation has said cannot be used to support causal claims, and which OHID’s own Director-General has stepped back from. Because it’s almost entirely a work of fiction. None of this is hidden. CEGA declares its funding openly. The problem is not secrecy. It is that a campaign funded by one man keeps citing itself as evidence, and Parliament keeps treating it as an excuse to be worthy.

If the Government does not want consumers to be asked to produce bank statements and tax returns in order to spend their own money, why is this happening?

‘If the Government does not want consumers to be asked to produce bank statements and tax returns in order to spend their own money, why is this happening? ‘

Great Britain: Regulation – Will Commission‘s slight return strike a blue tone with bettors?

“You don’t have to have the solution,

You’ve got to understand the problem,

And don’t go hoping for a miracle,

All this will fade away.”

‘Slight Return’, the Bluetones (1995)

The long-awaited publication of regulatory policy on affordability checks for gambling consumers in Great Britain may have provided clarity of a sort – but last week’s announcement was also notable for what it did not contain. 

The Gambling Commission’s intention to run a six-month pilot of financial risk checks had been well-trailed. It was surprising therefore that its announcement contained so little information about how the tests would be conducted; by whom; and what criteria would be used to determine success. In 2017, the Gambling Commission’s Responsible Gambling Strategy Board published an Evaluation Protocol, based on the principles of ‘robustness and credibility’, ‘proportionality’, ‘independence’ and ‘transparency’. As things stand, it is unclear to what extent – if at all – the Commission intends to comply with its own protocol (or indeed the Government’s Magenta Book).

The Protocol states, for example, that good evaluation “should include a clear articulation of what an intervention is intended to do, the outcomes it is intended to achieve, and how it is envisaged these outcomes will come about”; and also that it “has data collection which is planned before the intervention is implemented – so that, if necessary, baseline data can be collected before the policy starts.”  

The Gambling Commission has stated that the purpose of the new regulation is to create greater consistency for consumers; to regularise the patchwork quilt of trigger points and thresholds for checks that currently exists. At the same time, it has been remarkably incurious as to why this system of checks came into being in the first place and what effects it has had. If the Government does not want consumers to be asked to produce bank statements and tax returns in order to spend their own money, why is this happening? How has the existing system affected consumers, the functioning of the licensed and unlicensed markets and the finances of British horseracing? Without understanding this, how will we know that the Commission’s new system is better? Without robust analysis of the problem the policy is intended to solve, how will the success or otherwise of the pilot and any succeeding regulation be assessed?

The results of the 2021 ‘short survey’ into consumer attitudes towards affordability checks is another significant omission. Last year, the Gambling Commission committed to publish “the results from the survey”, which was completed by 12,125 individuals, thought mainly to be bettors (horserace bettors in particular were encouraged to submit their views). Instead of this, the Commission has published what might best be described as a narrative description of responses to the overall call for evidence – which is not at all the same thing. The market regulator’s reluctance to publish the actual results will prompt speculation that it perceives the views of consumers to be inconvenient or of marginal relevance to its mission. The Commission may find that a failure to do what it said it would, hinders rather than helps its goals of increasing transparency and building trust.

Last year, the Gambling Commission denied a request, made under the Freedom of Information Act, to release the survey results. It claimed that the “necessary preparation and administration involved in publishing the information” outweighed the “legitimate public interest in promoting the accountability and transparency of public authorities”. What had seemed a doubtful excuse at the time now seems highly implausible. It is difficult to believe that the composition of a single webpage on responses to the 2020/2021 call for evidence involved very much “preparation and administration”. Having been forced to wait for more than three years for publication, this single page may strike the thousands of people and hundreds of organizations who took the trouble to respond as a rather slight return. Those who believe that the Commission has no interest in the views of recreational consumers are likely to feel vindicated. In a paper published in 1999, Bill Eadington, the father of modern gambling studies, described the way that gamblers are often treated as “customers whose demands are not fully respected in the public policy formulation process.” He had a point.

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Dan Waugh

E:  dan.waugh@reguluspartners.com

W:  www.reguluspartners.com