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BetIndex Limited/Football Index meeting – report request

Request

The detailed financial assessment conducted with BetIndex Limited/Football Index on xx confirms that Football Index operated “test accounts” and this was discussed with Person B (Gambling Commission) and Person 7 (BetIndex Limited) confirmed that a report could be run splitting out the market maker and these test accounts. Please provide a copy of the report for the market maker and test accounts. Where applicable please confirm the name that these accounts operated under (as they wouldn’t be real people) and what additional due diligence was conducted into these accounts and if there was any suspicious activity.

Response

Thank you for your request which has been processed under the Freedom of Information Act 2000 (FOIA). Please accept my apologies for the delay in responding to you.

In your email dated 4 August 2023 you requested the following information: 

The detailed financial assessment conducted with BetIndex Limited/Football Index on xx confirms that Football Index operated “test accounts” and this was discussed with Person B (Gambling Commission) and Person 7 (BetIndex Limited) confirmed that a report could be run splitting out the market maker and these test accounts. Please provide a copy of the report for the market maker and test accounts. Where applicable please confirm the name that these accounts operated under (as they wouldn’t be real people) and what additional due diligence was conducted into these accounts and if there was any suspicious activity.

We have reviewed the information that is held by the Commission and we have attached the information that we hold that falls within the scope of your request as follows:

  1. Profit and Loss Analysis for Market Trader Test Accounts 
  2. Production Testing Policy 
  3. Football Index Betting Integrity Policy
  4. 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

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

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