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BetIndex disclosure of the redacted personal information


I have already clarified the position with the Information Commissioner's Office and they have informed me to request the information from you - which is what I am doing. I am requesting disclosure of the redacted personal information on the basis that the public interest favours disclosure. I am also requesting all due diligence carried out by the Gambling Commission on Bet Index Limited trading as Football Index prior to that concern being granted a gambling licence.  It should be clear to you what constitutes due diligence. It was the Gambling Commission that granted the licence so you must know what constitutes due diligence and the extent of that diligence.

If you wish to refuse to provide the information then please be clear and then I will appeal that decision to the ICO.


You submitted a new request on 22 December 2021 which, for ease of handling, we have split into two requests (REDACTED and REDACTED) which we will acknowledge separately.


Further to your request for disclosure of the redacted personal information included in the BetIndex assessment and accompanying notes that you have been provided with, please find our response below.

The Data Protection Act 2018 requires the processing of personal data to be fair and lawful. It would be disproportionate for us to publicly disclose the identity of these individuals unless there is a strong public interest in doing so. These individuals have a legitimate expectation that their personal details will not be disclosed in the context in which they were held.

On balance, there is no legitimate public interest in disclosing this information and it would not be fair to do so. This information is therefore exempt under section 40(2) of the Freedom of Information Act 2000.

In addition, the ICO’s decision notice dated 12 November 2021 advised the Commission to remove the personal information from these documents.

Kind regards

Review of the decision

If you are unhappy with the service you have received in relation to your Freedom of Information request you are entitled to an internal review of our decision. You should write to FOI Team, Gambling Commission, 4th floor, Victoria Square House, Victoria Square, Birmingham, B2 4BP or by reply to this email.

Please note, internal review requests should be made within 40 working days of the initial response. Requests made outside this timeframe will not be processed.

If you are not content with the outcome of our review, you may then apply directly to the Information Commissioner (ICO) for a decision. Generally, the ICO cannot make a decision unless you have already exhausted the review procedure provided by the Gambling Commission.

The ICO can be contacted at: The Information Commissioner’s Office (opens in a new tab), Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.

Information Management Team
Gambling Commission
Victoria Square House
Victoria Square
Birmingham B2 4BP

Internal Review Request

Thank you for responding to my FOI request. Unfortunately, the response is not satisfactory so I am requesting that an internal review is carried out.

I believe there is a legitimate public interest in disclosure given the circumstances surrounding the trading and subsequent collapse of Bet Index Ltd - described as the biggest failure in UK gambling history. Unfortunately, during the complaints process for the related FOI request,the ICO did not ask me if I wanted this information released and so they do not formally consider reasons for/against disclosure.

Internal review response


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