Tag: gambling-addiction

it’s ok to lie- in a good cause!

Last year, the Gambling Commission wrote to the Betting and Gaming Council (‘BGC’) to ask it to stop referring to Health Survey statistics. It now transpires that it did so on behalf of the activist organisation, Gambling with Lives (‘GwL’)

Great Britain: Politics – is something rotten in the state of the West Midlands?
A novel solution to addressing ‘problem gambling’ was briefly glimpsed in parliamentary debate last week – the imposition of strict gambling controls on people in the West Midlands; leaving those living elsewhere in England to flutter as they see fit. 

During Wednesday’s Westminster Hall Debate on Gambling Harms, Sarah Coombes MP (Lab, West Bromwich) claimed that there were “168,000 people in the west midlands who say that problem gambling is devastatingly affecting their lives” and the lives of family members. Seconds earlier, Ms Coombes’s colleague, Jim Dickson MP (Lab, Dartmouth) had told the chamber, with the authority of the now defunct Public Health England (‘PHE’), that an identical number of people in the whole of England were experiencing ‘problem gambling’. Taken together, these statements appear to indicate that gambling may only be a problem for people living in the environs of Wolverhampton, West Bromwich, Walsall, Coventry and Birmingham (home of Britain’s Gambling Commission).

No sooner did this regional lockdown ‘public health approach to problem gambling’ hove into view, than it started to dissolve under the weight of wider MP interventions. Dawn Butler MP (Lab, Brent) argued that there are around 20,000 ‘problem gamblers’ in her constituency alone; and Cameron Thomas MP (LibDem, Tewkesbury) claimed (incorrectly) that PHE had put the national figure at 246,000. Other MPs insisted that there were in fact 1.3 million or more ‘problem gamblers’ in Great Britain – claims that rely on the misuse of official statistics, as defined by the Gambling Commission. 

In general, the debate was a poor advertisement for parliamentary discourse. One Liberal Democrat MP suggested that supporters of Liverpool FC would find themselves “unable to talk to their friends and family about the losses and their addiction” as a direct result of Ladbrokes becoming the club’s official betting partner; while Butler of Brent claimed, without providing a shred of evidence, that gambling was “more addictive than heroin”. According to National Health Survey (‘NHS’) estimates, the rate of DSM-IV gambling disorder lies between 0.1% and 0.2% of the adult population, compared with 3.1% of people showing signs of drug dependency and a similar proportion with mild or severe alcohol dependency). As flies to wanton boys are statistics to MPs; they use them for their sport.

Only one participant – Labour’s Jake Richards, Member for Rother Valley – appeared to notice what was going on, observing that, “we have heard a lot of statistics in this debate, but they vary because we just do not know what we are dealing with”. Mr Richards was half-correct in his diagnosis. The real reason for the confusion is that prevalence rates are based on responses to self-report surveys – and estimates vary significantly depending on how these are conducted. NHS Health Surveys have historically been conducted in-person, an approach considered to be the “gold standard” in terms of yielding accurate results (Sturgis & Kuha, 2022). The Gambling Commission’s Gambling Survey for Great Britain (‘GSGB’) is conducted online and is less likely to be reliable due to low response rates and topic salience bias (ibid.). GambleAware’s Annual Treatment Survey uses self-selected online panels (surveys of people who actively choose to spend their time filling out questionnaires) and, while these panels may have their uses, providing reliable population-level figures is not one of them.

The chief executive of the Gambling Commission, Andrew Rhodes recently lamented that arguments over which survey is more accurate distract from what really matters. He is correct – but this is a situation of the Commission’s own making. Repeated attempts by the regulator to undermine public confidence in Health Surveys in order to shore up the defences of the GSGB reflect poorly on those involved and have prompted activists to describe the use of NHS statistics as “a con”. If it is a con, then it appears that both HM Government and HM Opposition are in on it. In last week’s debate the shadow gambling minister, Louie French (Cons, Old Bexley and Sidcup), and the DCMS minister, Stephanie Peacock (Lab, Barnsley South) chose statistics from NHS Health Surveys rather than the GSGB. 

Last year, the Gambling Commission wrote to the Betting and Gaming Council (‘BGC’) to ask it to stop referring to Health Survey statistics. It now transpires that it did so on behalf of the activist organisation, Gambling with Lives (‘GwL’). On 2 October 2024, GwL wrote to the Commission to ask whether it would take action against the BGC for continuing to use NHS figures (which have the status of Accredited Official Statistics) in preference to those from the GSGB (which don’t). Eight days later, the Commission did precisely that – copying and pasting the GwL objections into an email to the trade body. It did so despite the fact that the BGC’s actions do not constitute misuse; while turning a blind eye to cases of actual misuse. The regulator will presumably now also take the DCMS and shadow minister to task for the ‘non-crime statistics incident’ of believing the NHS.

The publication of the NHS Adult Psychiatric Morbidity Survey and the GSGB 2024 this summer will put another couple of ‘problem gambling’ figures into the mix; and these will be supplemented next year by the Health Survey for England – unless the Commission intervenes (it has told the Department of Health and Social Care that it wishes to ‘manage’ statistics that compete with its own). The chances of clarity or coherence breaking out any time soon seem slim. 

Regulus Partners – February 2025

Abusing NHS statistics

UK: ‘We don’t need no thought control’ – why the Gambling Commission should leave NHS stats alone

In recent years, the Gambling Commission has been on the receiving end of criticism from all sides of the so-called gambling debate. Last year, the MP, Sir Philip Davies declared that the regulator was “out of control”, while the Social Market Foundation has described it as “not fit for purpose”. The Commission has not publicly endorsed either of these views – or advertised them on its website – presumably because it considers them to be untrue as well as unflattering. Last month, however, the Betting and Gaming Council (‘BGC’) was asked by the Commission to make claims about the prevalence of gambling harms which are probably false – and to publish them on its website.



In an email recently released under the Freedom of Information Act, the Commission wrote:
 
“We’ve been keeping an eye on use of GSGB [Gambling Survey for Great Britain] data and use of figures as the official statistic. We’ve noticed that BGC still refers to previous stats, it’s not a misuse of stat issue but we’d be keen for you to start using the official figure moving forwards.”
 

This invitation was politely declined by the BGC on the grounds that it has greater confidence in NHS statistics (which are accredited by the UK Statistics Authority) than in the Commission’s (which are not). The BGC is similarly unlikely to profess that its members are (to borrow from Blackadder) ‘head over heels in love with Satan and all his little wizards’; but the Commission can always try.  

 
The regulator’s entreaties should be considered in the light of the following circumstances:
i) the balance of evidence indicates that the GSGB substantially overstates levels of gambling and gambling harm in Britain
ii) the Gambling Commission knows this
iii) in asking the BGC to go along with the charade, the Commission is acting, at best, inconsistently
iv) the GSGB is already being used (and misused) by activists, seeking to reopen the Government’s Gambling Act Review.



We examine each of these points in turn.  

 
1. The balance of evidence
The GSGB may be the new source of official statistics, but this does not mean it provides a reliable picture of gambling prevalence in Britain. To believe that it does, it is necessary to subscribe to the following:
        i.            Every single official statistic on gambling and harmful gambling produced over the last 17 years – by the National Health Service (‘NHS’), the Department for Culture, Media and Sport and the Gambling Commission itself – has been substantially wrong
      ii.            The NHS has serially misreported the prevalence of health disorders in general – and continues to do so
    iii.            Audited data on actual customer numbers using licensed operators is incorrect (or there is a massive black market that failed to show up in previous studies and of which the Commission was previously unaware)
     iv.            The opinion of the independent review (conducted by Professor Sturgis of the London School of Economics) that the GSGB may substantially overstate true levels of gambling and gambling harm is misguided
 

To believe that all these things are true (and to cajole others into professing the same) requires more than blind faith and a sheriff’s badge. Tellingly, the Gambling Commission does not have very much confidence in the GSGB itself; and has issued guidance that key results should be used “with some caution” or not at all.


2. Withholding evidence (again)
The Gambling Commission’s defence of the GSGB has largely consisted of attacks on NHS statistics, claiming that they have under-reported rates of ‘problem gambling’. While scrutiny is important, undermining accredited official statistics on health is a step not to be taken lightly. Some sort of evidence is required. For this, the Commission has relied upon a 2022 study which claimed social desirability response bias (ie, the fact that people sometimes answer survey questions in what they consider to be an acceptable rather than accurate fashion) caused under-reporting of ‘problem gambling’ in NHS surveys. This ‘evidence’ was thoroughly debunked by Professor Sturgis as part of his independent review – but for reasons known only to the Commission, the analysis was suppressed. It required a Freedom of Information Act request to secure the release of the information. This is not the first time that the Commission has prevented publication of critical evidence – having previously withheld survey data on customer opposition to affordability checks. Disclosures also reveal the Commission was warned by its lead adviser, Professor Heather Wardle, that social desirability response bias was likely to be a “marginal factor” in explaining differences between the GSGB and Health Surveys (and that the dominant factor of topic salience bias resulted in over-reporting in the GSGB). 
 
3. Two-tier thought policing?
In recent years, various parties have taken highly selective approaches to the use of ‘problem gambling’ statistics – often ignoring official estimates in favour of more convenient alternatives. Last year, the National Institute for Economic and Social Research did so in a report funded by a Gambling Commission settlement – using a rate two or three times higher than the official statistic. There is no suggestion that the Commission objected to this. In public consultations, the Commission itself relied on ‘problem gambling’ prevalence rates from the 2018 Health Survey for England rather than lower figures from the 2021 edition (ie, the official statistics at that time). In a speech in Rome last month, the chief executive of the Commission, Andrew Rhodes criticised those who wished to “turn the clock back” to previous official statistics, and in the very same speech cited participation estimates from ‘previous official statistics’.

 
4. The weaponisation of research
The importance of all of this has been amply demonstrated in recent weeks. Both the Institute for Public Policy Research and the Social Market Foundation cited the GSGB’s inflated rates of ‘problem gambling’ in support of demands for ruinous and self-defeating tax rates (as high as 66% of revenue); while GambleAware has used the survey findings to call for tobacco-style health warnings to be slapped on all betting and gaming adverts (including those for the National Lottery). The Commission appears, therefore, to be encouraging the use of inaccurate statistics on gambling harms in the knowledge that they will be used in support of an anti-gambling agenda.

Perhaps Sir Philip had a point after all…

REGULUS PARTNERS NOVEMBER 2024

ABSURDENOMICS

Absurdonomics: Bad money or poor education?


This week, Baroness Twycross participated in her first public discussion on gambling regulation, since being handed the policy brief in the summer. It was a salutary experience for the new minister, who may now be starting to grasp just how murky, partisan and at times downright dishonest the so-called gambling debate has become.
The minister will have been disconcerted to hear from fellow panellist, Professor Adrian Pabst of the National Institute of Economic and Social Research (‘NIESR’), that the costs to the state of ‘problem gambling’ could now be in the region of £5bn a year. It is likely however, that her counterparts at the Department of Education would have been even more alarmed if they understood how the professor had managed to arrive at this figure.


Last year, NIESR published its report on the ‘fiscal costs and benefits of problem gambling’. It asserted that harmful gambling cost the British taxpayer at least £1.4bn a year – a figure that hinged on its estimate that 0.7% of adults in Britain were ‘problem gamblers’. Since then, the Gambling Commission has published a controversial new Gambling Survey for Great Britain (‘GSGB’), which indicates a prevalence rate of 2.5% instead.

Professor Pabst appears therefore to have upweighted his previous estimate in line with this new figure. There are, however, two obvious problems with this. First, the GSGB is an unreliable survey – irretrievably damaged by selection bias – and the Gambling Commission itself has said that it cannot be used to provide population level estimates of harmful gambling (which is precisely what the NIESR revision relies upon). Second, the original NIESR cost estimate of £1.4bn is largely made-up!!

Roughly 60% of NIESR’s 2023 cost estimate refers to excess use of Universal Credit by ‘problem gamblers’; and was calculated using data from the ONS ‘Wealth and Assets Survey’. The ONS survey however, contains no information whatsoever that might be used to identify ‘problem gambling’; and so NIESR invented its own. It decided for example, that anyone who had won £500 or more in the previous two years and was not working due to ill health must be an ‘at risk gambler’.


Its criteria for identifying ‘problem gamblers’ meanwhile, was so speculative that it encompassed people who did not gamble at all. In this way, NIESR conjured a ‘problem gambling’ cost estimate of £800m a year out of thin air (and this presumably rises to £2.9bn using the Pabst rate of inflation).The next biggest area of alleged cost involves excess use of hospital inpatient services and was based on results from the 2007 NHS Adult Psychiatric Morbidity Survey. This dataset does at least contain estimates of ‘problem gambling’; but NIESR’s figure of £447m a year in costs (32% of the total) was based on a ridiculously small sample of just nine survey respondents; and the calculation was neither provided nor explained. The remaining 11% of costs were derived using similarly weak methods. The report is riven with flaws (including basic errors of addition, multiplication and division) and inconsistencies (it provided no fewer than four different cost estimates for excess use of GP surgeries by ‘problem gamblers’).

The project was overseen by an expert advisory group, chaired by Dr James Noyes of the SMF, a long-standing collaborator with Professor Pabst. Dr Noyes also chaired this week’s SMF event in Liverpool. Other members of the expert advisory group included Professor Heather Wardle from the University of Glasgow and Dr Henrietta Bowden-Jones of the NHS. At the time of its publication, Professor Wardle described NIESR’s work as “an important new report”, which showed that “the fiscal burden of gambling harms in the UK…have been underestimated”; somehow overlooking the myriad problems with how it was put together.

NIESR’s report was funded by a £140,050 regulatory settlement approved by the Gambling Commission – but the market regulator has expressed a lack of interest in the quality of output or the fact that some of those involved have used the report for the purposes of anti-gambling activism – not just in Britain but in New Jersey too. Regulatory settlement rules stipulate that funds must not be used for campaigning or lobbying – but as the Commission does not actually check what is done with settlement funds and provides no sanction or recourse for misuse – this rule is of only academic importance.

Professor Pabst’s comments this week may constitute a breach of settlement fund rules as well as the Gambling Commission’s guidance on the use of the GSGB – although the latter is so ambiguous that it would be hard to apportion too much blame.

The NIESR report forms part of a wider canon of studies claiming substantial social and economic costs from gambling. Earlier this month, Nera Consulting published a report alleging that online gambling was economically harmful because it diverted consumer spending away from more labour-intensive industries. Nera’s claim revolves around the idea that people should spend their money, not on things that they enjoy but on goods and services that require large numbers of people to produce them. Similarly, a report from the SMF in 2022 suggested that online gambling was economically harmful because it did not involve extended supply chains – a bizarre claim in an era of environmentalism.

Public Health England, the Office for Health Improvement and Disparities and the Institute for Public Policy Research have also produced a variety of speculative and, in some cases, misleading cost estimates.

Large sums of money have been expended on these projects – both by the state and by one private individual in particular – but it’s unclear what has been learned as a result (aside from the fact that basic numeracy appears not to be a requirement to work for an economic think tank). Even if researchers were able to provide meaningful estimates of costs, it is questionable what policy purpose they might serve without a similarly rigorous estimate of consumer and societal benefits. While Baroness Twycross heard much about the ‘bad money’ of betting, we must hope that her eyes have been opened to the absurd economics of the gambling debate.

Note: In 2023, we shared our critique with NIESR and asked (on several occasions) whether the authors considered any aspects of our analysis to be incorrect. We received no response to our enquiries.
REGULUS PARTNERS

The moral collapse of the gambling commission

Great Britain: Regulation – the moral collapse of the Gambling Commission

For those with an inclination to learn, this week’s events offer the Gambling Commission a valuable lesson in authority. The market regulator exercises a coercive authority, mandated by Parliament, over anyone who holds a licence to provide betting or gaming services in Great Britain. Where others are concerned, it must rely on moral authority – but this commodity has been all but exhausted by its own actions.

In an open letter to the Prime Minister published on Monday, a succession of activists, politicians and researchers (categories that have become increasingly indistinct), openly flouted the Commission’s authority while the ink was still dry on its guidance for how results from the Gambling Survey for Great Britain can and cannot be used. In what can only be considered a triumph of hope over experience, the Commission had promised that the issuing of its guidance document would curb the tendency of campaigners to misuse Official Statistics; but the Peers for Gambling Reform (‘PGR’) letter to Sir Keir Starmer (or ‘Sir Kier’ as these Peers appear to have dubbed him) showed this trust to be misplaced. The GSGB is not due out until this morning – but the signatories to the open letter jumped the gun by referring to “a higher picture of gambling harm than existed previously” (a claim that contravenes the guidance regardless of its attribution to the former minister, Stuart Andrew MP). 

The role of gambling market regulator is a difficult one – but the Gambling Commission has made its task needlessly troublesome by playing politics. As articles in the Racing Post and elsewhere have revealed, the Commission has in recent years suppressed evidence, manipulated surveys and facilitated the funding of anti-gambling activism through the disbursement of regulatory settlements. As the journalist Christopher Snowdon has observed, the Commission’s decision to publish misleading prevalence statistics while at the same time telling people to ignore them for the purposes of estimating prevalence is irresponsible: “They’re your statistics. Take some responsibility”, he wrote last week.

It is rumoured that at least one media outlet has refused a Gambling Commission request to amend its reporting of the GSGB. In any case, belated corrections on an obscure clarifications webpage provide scant redress for the impact of misleading headlines.

The PGR letter was revealing in other ways. In demanding the imposition of a safer gambling levy, the signatories claimed that “it is widely understood that the statutory levy would give oversight of treatment funding to the NHS, research funding to UKRI and prevention funding to OHID.” The DCMS has stated its intention to allocate commissioning responsibilities to the NHS and the UKRI but has made no such announcement with regard to the OHID, so it is unclear where the PGR is getting its information from. The appointment of OHID to the role would probably spell the beginning of the end for the licensed betting and gaming market in Great Britain. Officials at the department have indicated a desire to impose tobacco-style controls on operators and consumers; and have proposed annual increases in duties (effective prohibition), total bans on advertising and even – as bizarre as it may seem – ‘plain packaging for all gambling products (“no colours, logos or images”). They have shown a willingness to manufacture statistics and mislead policy-makers in support of this ambition.

It has been suggested on social media that the Good Law Project complaint about GambleAware (whose moral distaste for gambling pales by comparison with the OHID’s illiberalism) was designed to knock the charity out of the running to be the prevention commissioner. The Charity Commission’s rejection of the complaint (announced this week) should prompt an investigation into potential wrong-doing by those who involved (including whether the OHID had anything to do with it). Scrutiny of charities is important but requires care. Spurious accusations designed to disrupt the activities of the Third Sector is unacceptable. The Gambling Commission may not be the only ones to discover how quickly moral authority can erode.

Text book misconduct in public office

Primed Numbers: exercises in policy-based evidence-making?

Last month, the Racing Post revealed that the Gambling Commission had withheld for more than three years, evidence of widespread consumer opposition to affordability checks. The story raised a number of questions – from legal experts and others – about how evidence is used to inform regulation. In particular, it prompted speculation about why the market regulator was able to claim a consumer mandate for the imposition of checks when the weight of evidence tilted so clearly in a different direction. In this article, we examine the Gambling Commission’s use of consumer research on affordability checks, how survey responses can be stimulated to achieve the desired effects and why we should be wary of policy-based evidence-making.

The evidence trail starts in 2019 when the Gambling Commission asked the research firm 2CV to investigate consumer attitudes towards the prevention of ‘binge gambling’ episodes. The results of this survey indicated considerable antipathy towards hard interventions with more than 70% of respondents rejecting operator-imposed controls (with one-quarter selecting no action whatsoever).

The Gambling Commission omitted these findings when it published the results of the 2CV study and they were also excluded from the 2020 call for evidence on affordability checks, despite clear relevance. The results of the Gambling Commission’s ‘mini-survey’ in 2021 were even more stark. While three-quarters of respondents (most of whom were online bettors) agreed that operators should be required to take action to support vulnerable customers, 78% rejected proposals for affordability checks, citing consumer privacy, consumer freedom and their likely ineffectiveness in preventing harm. Just 14% of respondents stated that they would comply with checks while two-thirds said that they would feel uncomfortable being subjected to assessments by Credit Reference Agencies (‘CRAs’).

As the Racing Post has reported, these results were kept under wraps for almost three-and-a-half years and were deliberately excluded from the 2023 consultation on Financial Risk Assessments (‘FRAs’). In October last year, the Commission refused a request under the Freedom of Information Act (‘FOIA’) for the survey findings to be released, claiming that it would be too time-consuming to do so and that it saw “no outstanding public interest” in making them while the consultation was open. In February this year, the chief executive of the Commission, Andrew Rhodes, gave a personal pledge that the results would be published. The Commission however, failed to publish the survey results when plans for FRAs were announced in May; and it took a further FOIA request to finally force its hand.

By this point however, the Gambling Commission had released the results from a third survey (a self-selected online panel managed by the polling firm, Yonder); and this time the results were rather different. A large majority (78%) of respondents agreed that checks were “necessary to protect people from gambling harm” and just 6% disagreed. It is true that the 2023 survey related to a modified form of the affordability checks proposed in 2021 – but this seems an unlikely explanation for such a change in views on checks and the use of CRAs in particular (see chart). Is it plausible that consumer attitudes should have altered so dramatically in just two years?

SurveySample size
Gambling Commission 202112,124
Yonder 20231,000

There are two strong contenders for explaining why the Yonder panel yielded such different views from the 2019 2CV survey and the Commission’s own ‘mini survey’ in 2021. The first relates to sample composition. The 2021 survey was responded to by people interested in the issue of affordability checks – people who had sufficient skin in the game to take the trouble to respond. The Yonder panel by contrast, consisted of people who get their kicks (as well as some small financial compensation) from taking part in surveys – but who otherwise might have little interest in the policy (only 14% had personal experience of affordability checks). It is easy to be supportive of controls imposed on others.

The bigger issue however, is likely to be one of response priming. Prior to completing the 2023 survey questionnaire, panellists were exposed to ‘stimulus packs’, including ‘video stimuli’ to “maximise engagement and efficiency”. They were informed that the checks being consulted on were already Government policy and that they would “protect the most vulnerable while allowing everyone else to enjoy gambling without harm”. They were then shown a selection of newspaper headlines, with the explicit intention that these should affect (or stimulate) responses. Some of these headlines reflected concerns about checks while others warned about delays to implementation; but the overall impression was far from balanced.

One of the headlines told respondents that “Gambling addicts will die because of delay to reforms, government warned”; another that “‘There will be more people dying’: mother whose daughter took own life criticises gambling white paper”. In other words, survey participants were encouraged to believe that people would take their own lives if the checks were opposed. They were also exposed to headlines expressing opposition to checks (e.g. “MP urges racing to make its case against ‘crippling’ Gambling Commission proposals”) but such concerns will pale when juxtaposed against self-harm. Viewed in this light, the Yonder panel’s strong support for FRAs appears distinctly unsurprising. The second of the two ‘suicide headlines’ in the stimulus pack did not even relate to affordability checks but instead to advertising; and in fact rejected the idea that “even stricter versions” of checks would prevent loss of life (suggesting that survey respondents were not simply led – but actively misled). A third headline related to a comment piece in The Times written by a director at the activist group, Gambling With Lives; while the author of the fourth is understood to have connections with the same organisation.

Reviewing the stimuli to which the Yonder panellists were subjected, it is difficult not to be cynical about the Gambling Commission’s intent. Having failed on two occasions to obtain the desired response, the Commission left nothing to chance with the Yonder survey. Even if we ignore these issues and take the 2023 Yonder survey at face value, it does not explain why the Commission repeatedly refused to publish the results of the 2021 ‘mini survey’ (or the 2019 2CV study). The Commission’s selective use of evidence is difficult to justify – and so far it has made absolutely no attempt to do so. Its silence in the face of serious concerns about consultative process appears evasive rather than dignified. If it has reservations about the 2019 and 2021 surveys, it should explain what these are and allow people to make up their own minds about their value. Suppressing inconvenient evidence serves only to undermine confidence in the regulatory process.  

In around six weeks from now, a pilot scheme to assess the viability of Financial Risk Assessments will commence; yet the Gambling Commission has still not published details of how this will be evaluated. The criteria for success have not been released and it is unclear how the integrity of the tests will be assured. Having spent the last three-and-a-half years agitating for checks, the Commission cannot be considered a neutral actor; and its reputation for impartiality has taken a battering of late. In the absence of a proper explanation for the withholding of evidence and a commitment to transparent evaluation of the pilot, the market regulator faces the threat of fresh controversy – and possibly legal challenge. It is unlikely that the incoming Culture Secretary, Lisa Nandy, will thank the Gambling Commission for such an avoidable headache.

Unreliable Suicide Claims in Gambling: ABSG’s Questionable Stance

The Great Suicide Deception. Part III – Conspiracy of Silence

Dan Waugh, Regulus Partners. May 2024

The Great Suicide Deception. Part III – Conspiracy of Silence

This is the third in a series of articles examining claims made by state bodies in England about rates of suicide associated with ‘problem gambling’. In the first we demonstrated that estimates of suicide mortality produced, first by Public Health England (‘PHE’, 2021) and then by the Office for Health Improvement and Disparities (‘OHID’, 2023) were irretrievably flawed. In the second, we looked at the behaviour of PHE and OHID, finding indications of a priori bias or inexplicable negligence and unsound governance. In this third article, we examine the conduct of others in positions of authority and ask why so many people who knew that PHE and OHID’s claims were unreliable decided to look the other way. We also recognise those who were prepared to apply critical analysis. Once again, we observe that, while gambling disorder has been recognised as a risk factor for self-harm for more than 40 years, efforts to tackle this are unlikely to be advanced by the use of junk science.

1. Why did the Gambling Commission not ‘do the right thing’?

By April 2022, Britain’s Gambling Commission knew that estimates of suicide mortality published by PHE were “unreliable” and based on “inaccurate” assumptions. This may have been a somewhat uncomfortable finding, given that the regulator had previously described the review as “important and independent”. It had arrived at this opinion despite not having received anything more than an executive summary (which it had not read when it agreed to provide “a supportive quote”). It also knew that PHE was far from “independent”, having been made aware of its intention to apply tobacco-style controls to participation in betting and gaming.

At a meeting in March 2022, Gambling Commission officials admitted that they did not understand how PHE had arrived at some of its estimates (no-one could have been expected to – given the fact that the calculations were mathematically incorrect). In April, these officials circulated a highly critical review of the PHE report, in which they noted that the suicide claims were not based on “reliable data”. The Commission however, elected not to take the matter up with the OHID (which had subsumed PHE upon the latter’s disbandment) or to inform the Secretary of State. The market regulator – which counts “doing the right thing” among its corporate values – elected to suppress its critique. In one rather sinister coda to the Commission’s critique, one official speculated that PHE’s claim of more than 400 suicides might be rescued, if only future prevalence surveys showed a higher rate of ‘problem gambling’ in the population. At this point, the Commission had started work on a new Gambling Survey for Great Britain in the expectation that – as a result of methodological issues – would produce a higher rate of ‘problem gambling’ than reported by tNHS Health Surveys.

 

When asked by journalists whether it considered the PHE claims to be reliable, the Gambling Commission responded that it was not its role to review the work of other state agencies; but failed to mention that this is precisely what it had done. As late as 2023, its chief executive, Andrew Rhodes continued to defend the PHE-OHID estimates, despite being aware of the problems with them; and it seems likely that the market regulator has been involved in disseminating the misinformation via approval of regulatory settlement funds.

2. the ABSG and the irrelevance of accuracy

In the summer of 2022, the OHID wrote to the Gambling Commission’s Advisory Board for Safer Gambling (‘ABSG’) to ask for its opinion on criticism of PHE’s suicide analysis. In her response, the ABSG’s chair, Dr Anna van der Gaag appeared to agree that there were indeed a number of issues. She wrote: “I see their point about basing calculations on the Swedish hospital study leading to an over estimation of the numbers”. She then proceeded to suggest that accuracy in such matters was unimportant and that attempts to apply scrutiny was “a distraction from what matters to people and families harmed by gambling”. This represented a change in attitude from three months earlier when the ABSG had described PHE’s highly exact estimate of 409 suicides associated with problem gambling as a “catalyst towards action”. The Gambling Commission allowed the ABSG to publish this opinion in the full knowledge that it was based on unreliable data. 

The following year, Dr van der Gaag was one of two co-adjudicators responsible for allocating around £1m in Gambling Commission (regulatory settlement) funding for the purposes of research into suicide and gambling. Applicants were specifically directed towards the OHID analysis (i.e. estimates that the ABSG knew were flawed) as well as claims by the activist group, Gambling With Lives (despite the fact that even the OHID had indirectly criticised one of GwL’s claims). One of the successful bids (a £582,599 award to a consortium led by the University of Lincoln) included Gambling With Lives as an active member of the research team. 

3. the Silence of the ‘Independents’

Among those who have supported the claims of PHE-OHID are a number of self-styled ‘independent’ researchers. These include academics from the universities of Cambridge, Hong Kong, Lincoln, Manchester, Nottingham and Southampton, as well as King’s College, London, who have cited the estimates uncritically in their work. Perhaps they considered (naively, if so) that research produced by the Government is unimpeachable; yet the errors made by PHE-OHID are so glaring that no researcher of any calibre could have failed to notice them. The failure to subject such serious claims to critical analysis before repeating them indicates – at the very least – an absence of intellectual curiosity. Much is made of the need for research independence (typically defined solely by an absence of industry funding, regardless of ideology or other affiliations); but independence has little value if it is not accompanied by intelligence and integrity. 

4. Breaking ground

A small number of groups and individuals have been prepared to apply scrutiny and challenge, despite the circumstances. The Racing Post and the think tank Cieo have published a number of our own articles on the problems with PHE-OHID (as well as other issues with research-activism); and a handful of journalists, including Chris Snowdon, Steve Hoare and Scott Longley have been prepared to challenge the PHE-OHID claims. Figures from trade groups, bacta and the Gambling Business Group have spoken out publicly on issues with PHE-OHID.

Officials at the Department for Culture, Media and Sport have displayed a capacity for critical analysis, notable by its absence elsewhere in Whitehall. Their White Paper on reform of the betting and gaming market acknowledged valid concerns about self-harm but conspicuously omitted the OHID figures. Lord Foster of Bath, a stern critic of the gambling industry, has acknowledged that the PHE-OHID claims are not reliable and – in a show of honesty and humility rare in the gambling debate – apologised for using the figures himself. He continues to make the case for self-harm to be treated seriously in a gambling context; but without recourse to spurious statistics. Philip Davies, the Conservative Member of Parliament for Shipley, has challenged unsound statistics in parliamentary debates; and Dame Caroline Dinenage’s select committee for Culture, Media and Sport noted concerns of reliability in its report on gambling regulation. 

One member of the Gambling Commission’s senior management team – Tim Miller – has been prepared to discuss and acknowledge problems with PHE-OHID; an attitude that contrasts sharply with that of his colleagues.

5. ‘Noble lies’ and consequences?

Underlying the PHE-OHID saga is a sense that some people in positions of authority consider it acceptable to publish inaccurate or misleading statistics if the cause is – in their opinion – just. Some have even suggested that scrutiny of misinformation is unethical, rather than its manufacture. In July this year, the Gambling Commission intends to publish statistics on the prevalence of suicidality amongst gamblers. Given its role in PHE-OHID (in addition to major issues with its new survey), it is questionable why anyone should consider these results credible. It has also – via Gambling Research Exchange Ontario – sponsored a programme of research into wagering and self-harm. Given that these studies have been explicitly grounded in the PHE-OHID deception – and the complicity of many of those involved – suspicions of bias will accompany publication. It is the publication of unreliable research – rather than scrutiny of those statistics – that undermines public trust in authority. Attempts to address health harms in any domain will be ineffective if they are based on inaccurate evidence.

An independent and open review should be carried out into the PHE-OHID deception; but it is difficult to see how this will happen. The Department of Health and Social Care and the Gambling Commission are unlikely to embrace scrutiny; and the DCMS will not wish to embarrass either its regulator or another government department. There are too many people in Parliament and the media who have played a part; and too few prepared to break ranks. The gambling industry meanwhile (with a number of notable exceptions) has shown little inclination to challenge. There is one hope – that the Office for Statistics Regulation will be prepared to take an interest in the integrity of public health estimates. Such an intervention would go somewhere at least towards restoring trust in public bodies.

Sample Bias – the new normal

 
Great Britain: Regulation – Is the Great British Gambling Debate heading for a Terminal solution?


Last week’s House of Lords debate on gambling advertising was in many respects the same tired old combination of mistruths and moral indignation; but it was notable for providing a glimpse into the next phase of gambling policy discourse in Britain. Lord Foster of Bath, who instigated the short debate told the House that:
 
“I suspect public concern is about to rise because, in July, the Gambling Commission will release new figures about gambling harm. The Gambling Minister in the other place has already indicated that they are likely to show that 1.3 million people will classify as ‘problem gamblers’ and that a further 6 million are at risk. If confirmed, these figures are far higher than those used to inform the Government’s work on their White Paper. This is a real cause for concern, further strengthening the call for action.”


 
The intent could not be clearer. If the publication of the Gambling Survey for Great Britain (‘GSGB’) in July reveals a markedly higher rate of ‘problem gambling’ than the estimates relied upon by the Government in its White Paper, then the wisdom of the policies contained therein will be open to question. Lord Foster’s point is a fair one. In its White Paper, the Government relied on the 2018 Health Survey for England, which reported a ‘problem gambling’ prevalence rate of 0.38%; and the current Official Statistic (from the HSE 2021) is 0.25%. The Final Experimental Stage of the GSGB reported a figure of 2.5% – between six and ten times higher than the HSE. If the Government and regulator are confident that results obtained from the GSGB are reliable, concern groups will justifiably ask for a re-run of certain policy decisions (and possibly even Judicial Review, given the litigious bent of some activists).
 
The problem is, of course, that the Gambling Commission does not appear to be at all confident that results obtained from the GSGB will be reliable. Each of the new survey’s iterations – from the Pilot Survey in 2022 to the Experimental Stages in 2023 to Wave 1 of the official survey in 2024 – has revealed signs of sample bias. In an independent review (‘independently’ funded by the Gambling Commission), Professor Patick Sturgis of the London School of Economics, commented on the “non-negligible risk” that the GSGB would “substantially over-state the true level of gambling and gambling harm in the population”. He also urged caution, warning that “until there is a better understanding of the errors affecting the new survey’s estimates of the prevalence of gambling and gambling harm, policy-makers must treat them with due caution.” Such advice appears lost on the Commission (which prefers to gloss over inconvenient opinions). In addition to rates of ‘problem’ and ‘at risk’ gambling’, it plans to release survey findings in respect of suicidality, violence and abuse, mental ill-health and use of food banks – in the knowledge that the figures may very well be incorrect and misleading. Just when the Department for Culture, Media and Sport might have thought it was nearing the end of a long and tortuous journey on gambling reform, the Commission is throwing down new track.


 
The threat to the licensed betting and gaming market in Great Britain is severe. The public health establishment (including senior figures within the Department for Health and Social Care) has signalled its intention to “tackle gambling” (all gambling and not just harmful gambling) in the same way that it has dealt with tobacco smoking. Demands for total bans on advertising (including at racecourses), the sale of beer and wine in bingo clubs and casinos and the imposition of ‘plain packaging’ for all gambling products (no colours, logos or images – farewell Queen of Hearts), will intensify. In Scotland, it is reported that the SNP plans to raise the legal age of gambling if it achieves independence (presumably with a carve out for anti-gambling vitriol in its Hate Speech legislation) but this is only a stop along the route rather than a final destination. It is far from obvious however, that the industry realises the perilous nature of its current position. Tone-deaf advertising on bus stops and at railway stations only strengthens the ground for those seeking a terminal solution.