BetIndex Limited/Football Index meeting - information request
Request
In the transcript of the detailed financial assessment held with Betindex Limited/Football Index on 26th February 2020, Person F confirms that a conversation had taken place on 25th February 2020 with the Market Maker. Please provide a transcript of the full conversation or minutes for the meeting, plus any supporting slides or information that was supplied by the Market Maker or BetIndex Limited/Football Index to support the conversation.
Response
Thank you for your request which has been processed under the Freedom of Information Act 2000 (FOIA). Please do accept my apologies for the delay in responding to you.
In your email dated 4 August 2023 you requested the following information:
“In the transcript of the detailed financial assessment held with BetIndex Limited/Football Index on 26th February 2020, Person F confirms that a conversation had taken place on 25th February 2020 with the Market Maker. Please provide a transcript of the full conversation or minutes for the meeting, plus any supporting slides or information that was supplied by the Market Maker or Betindex Limited/Football Index to support the conversation.”
Transcript – Section 40(2) of the Freedom of Information Act
We have reviewed the transcript of the meeting that was held on 25th February 2020, and it is our view that the transcript is exempt from disclosure in its entirety and S40(2) Personal Information is engaged.
The Data Protection Act 2018 requires the processing of personal data to be fair and lawful. The Commission considers that any disclosure of the transcript would disclose the personal data of a third party. It would therefore be disproportionate for us to publicly disclose this information unless there is a strong public interest in doing so. The individual or individuals in the position of Market Maker have a legitimate expectation that their personal information will not be disclosed in the context in which it is 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.
Minutes of the meeting, supporting slides or information supplied by the Market Maker or BetIndex to support conversation
I can confirm that there were no slides presented during the assessment. During the assessment, the representatives of BetIndex shared their screen with participants where they demonstrated the system. Additionally, there are no minutes held from this meeting.
I have attached the following documents that were provided in support of the conversation relating to the Market Maker:
- Profit and Loss Analysis for Market Trader Test Accounts
- Production Testing Policy
- BetIndex Limited Market Maker Policy – Draft
- Other extracted information
Personal information relating to identifiable individuals has been redacted from the above documents.
The Data Protection Act 2018 requires the processing of personal data to be fair and lawful. The Commission considers that it would be disproportionate for us to publicly disclose the personal data contained within these documents as there is no strong public interest in doing so. There is no legitimate expectation that the personal information of these individuals will be disclosed in the context in which it is 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.
Review of the decision
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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
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