BetIndex - Records (audio or video) of financial assessment
Request
I am making a freedom of information request:
I have previously made a request for the following (this request is still ongoing):
"In the blog post made by the Chief Executive of the Gambling Commission (link below), he asserted "At the detailed financial assessment in early 2020, BetIndex was able to cover the liabilities in bet dividends for at least 12 months (in cash holdings) and potentially for three years if it made significant reductions to its overheads."
I am requesting a copy of this financial assessment of Bet Index and all supporting documents."
My new request: Please provide any and all audio or video records of this assessment.
Response
Thank you for your request which has been processed under the Freedom of Information Act 2000 (FOIA).
Following your request for the financial assessment of BetIndex and all supporting documents, you are now requesting any and all audio or video records of this assessment.
I can confirm that the Commission does hold information falling within the scope of your request, however, this recording contains information relating to identifiable individuals that would constitute personal data. The personal information contained within the recording includes reference to the participants by name and pictures of some of the staff which are displayed automatically when using Microsoft Teams as a meeting platform.
The Data Protection Act 2018 requires personal data to be processed lawfully, fairly and in a transparent manner in relation to the data subject. It is the view of the Commission that disclosing the personal information within this recording would constitute the disclosure of personal data and would contravene this principle.
This information is therefore exempt under section 40(2) of the Freedom of Information Act 2000.
In addition, the information contained within the recording relates to our specific regulatory techniques. As such, we are not able to release this information into the public domain and the information you have requested is exempt under section 31 of the FOIA.
The Commission seeks to ensure, through its compliance assessment work, that a licensee remains suitable to hold a licence and that they conduct themselves in a way which is consistent with the licensing objectives, the requirements of the Act, and the conditions of their licences and related codes of practice.
The Commission does not disclose further details of this assessment process, for individual operators. Doing so would reveal the methods and techniques the Commission uses as part of the assessment process. It could seriously impact the Commission’s assessment process, if information relating to how it gathers information and evidence as part of that process became known; this is strongly not in the public interest.
Section 31(1) provides that Information which is not exempt information by virtue of section 30 is exempt information if its disclosure under this Act would, or would be likely to, prejudice –
(g) the exercise by any public authority of its functions for any of the purposes specified in subsection (2)
The relevant purposes referred to subsection (2) are –
a. the purpose of ascertaining whether any person has failed to comply with the law, c. the purpose of ascertaining whether circumstances which would justify regulatory action in pursuance of any enactment exist or may arise
There is a legitimate public interest in promoting accountability and transparency of public authorities and disclosure of the requested information, as it relates to BetIndex, could demonstrate to stakeholders and relevant parties that the Commission was active in its regulatory functions. Furthermore, increasing confidence in the Commission as a regulator and its ability to uphold the law.
However, discussing within the public domain specific information relating to regulatory practices may deter key stakeholders from sharing important material with us, as such prejudicing our regulatory functions. Disclosure of the requested information may prejudice the outcome of any future work by the Commission, or another body by exposing techniques and practices to the detriment of the public interest.
The amount of information released relating to our specific regulatory techniques is limited as this could lead to non-compliant operators altering their behaviour specifically to meet the Commission standards purely for assessment purposes.
Having considered the arguments for and against disclosure of the requested information, the Commission’s view is that the public interest is best served through maintaining this exemption.
Information we hold as part of our regulatory activity to assess licence holders is considered to be exempt under S31(2)(a) and (c). Providing this information could seriously impact on the Commission’s ability to fulfil its statutory functions.
The Commission feels that the disclosure of this information ‘would prejudice’ the regulatory functions of the commission.
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
Review Request
Thank you for responding to my FOI request. The response is not satisfactory so I am requesting that an internal review is carried out.
I do not accept the explanations given for withholding the information. I do not accept the application of the section 31 exemption or any other exemption. I do not accept that the communications comprise personal data. The public interest test has not been properly carried out. The public interest favours disclosure. There is a clear, substantial and overwhelming public interest in disclosure due to the loss of £124m of customer funds.
Review Response update
Following our acknowledgement email sent on 18/05/2022 regarding your request for an internal review of our response to your following request:
"In the blog post made by the Chief Executive of the Gambling Commission (link below), he asserted "At the detailed financial assessment in early 2020, BetIndex was able to cover the liabilities in bet dividends for at least 12 months (in cash holdings) and potentially for three years if it made significant reductions to its overheads."
I am requesting a copy of this financial assessment of Bet Index and all supporting documents."
My new request: Please provide any and all audio or video records of this assessment.
Please be advised that we will require further time to process your review request.
We will endeavour to provide you with a response as soon as possible, however, we do require additional time to process the review; we will aim to provide you with a response by 30/06/2022. If we are unable to respond by this date, we will advise you accordingly.
Please accept our apologies for this delay.
Review Response (2)
Further to your Freedom of Information request dated 30/04/22 which we responded to on 18/05/22, and your subsequent request for an internal review received on 18/05/22, we have now concluded our review and our findings are detailed below. This internal review was conducted by someone who was not involved in the processing of your original request.
Following your request for the financial assessment of BetIndex and all supporting documents, you subsequently requested any and all audio or video records of this assessment.
In our response we advised that the Commission does hold information that falls within the scope of your request.
We advised that the information contained within the recording relates to our specific regulatory techniques and the S31 exemption applied.
Section 31(1) provides that Information which is not exempt information by virtue of section 30 is exempt information if its disclosure under this Act would, or would be likely to, prejudice –
(g) the exercise by any public authority of its functions for any of the purposes specified in subsection (2)
The relevant purposes referred to in subsection (2) are –
a. the purpose of ascertaining whether any person has failed to comply with the law c. the purpose of ascertaining whether circumstances which would justify regulatory action in pursuance of any enactment exist or may arise
As this is a qualified exemption, we considered the following public interest arguments for and against disclosure.
Arguments for disclosure
There is a legitimate public interest in promoting accountability and transparency of public authorities and disclosure of the requested information, as it relates to BetIndex, could demonstrate to stakeholders and relevant parties that the Commission was active in its regulatory functions. Furthermore, increasing confidence in the Commission as a regulator and its ability to uphold the law.
Arguments against disclosure
Discussing within the public domain specific information relating to regulatory practices may deter key stakeholders from sharing important material with us, as such prejudicing our regulatory functions. Disclosure of the requested information may prejudice the outcome of any future work by the Commission, or another body, by exposing techniques and practices to the detriment of the public interest.
The amount of information released relating to our specific regulatory techniques is limited as this could lead to non-compliant operators altering their behaviour specifically to meet the Commission standards purely for assessment purposes.
Releasing the information would disclose further details of this assessment process, for individual operators. Doing so would reveal the methods and techniques the Commission uses as part of the assessment process. It could seriously impact the Commission’s assessment process, if information relating to how it gathers information and evidence as part of that process became known; this is strongly not in the public interest.
The Commission seeks to ensure, through its compliance assessment work, that a licensee remains suitable to hold a licence and that they conduct themselves in a way which is consistent with the licensing objectives, the requirements of the Act, and the conditions of their licences and related codes of practice.
The Commission considered that on balance, the disclosure of this information ‘would prejudice’ its regulatory functions and, therefore, considered the information to be exempt under S31(2)(a) and (c).
We concluded that, having considered the arguments for and against disclosure of the requested information, the Commission’s view is that the public interest is best served through maintaining this exemption.
In reviewing the information we hold, we have reconsidered the arguments detailed above and agree with the application of S31(2)(a) and (c). Providing this information could seriously impact on the Commission’s ability to fulfil its statutory functions.
In addition, we also advised that the recording contains information relating to identifiable individuals that would constitute personal data. We advised that the personal information contained within the recording includes reference to the participants by name and pictures of some of the staff which are displayed automatically when using Skype as a meeting platform. The Data Protection Act 2018 requires personal data to be processed lawfully, fairly and in a transparent manner in relation to the data subject, therefore it was the view of the Commission that disclosing the personal information within this recording would constitute the disclosure of personal data and would contravene this principle. The individuals involved with this recording do not have an expectation that their information will be shared with the public. Therefore, we considered this information exempt under section 40(2) of the Freedom of Information Act 2000. Section 40(2) is an absolute exemption which means that we do not have to carry out a public interest test when engaging this exemption, however, we do have to consider whether there is a lawful basis for disclosing this personal information. It is our view that it is not necessary to disclose this personal information and there is not a legitimate reason for doing so.
In conclusion, I uphold our original decisions to apply the exemptions Section 31(2) and Section 40(2) of the Freedom of Information Act to the audio recording of the financial assessment. To be as helpful and transparent as possible, we have made available to you the recording of the financial assessment, however, we have removed the audio recording for the reasons outlined above. We have also redacted any personal information that is visible within the recording.
The recording also includes information that relates to the unaudited financial statements for the two years ended 31 December 2018 and the management accounts for 2019, which has been removed as this information has previously been refused by the Gambling Commission. The decision notice relating to this information published by the ICO on 16 December 2021 (IC-109314-Z5X1) has been replaced by a consent order from the First Tier Tribunal dated 27 June 2022, which found that the public interest in maintaining the exemption in section 31(1)(g) FOIA outweighs the public interest in disclosure. Therefore, this information will not be released.
Due to the size of the video file we cannot send this to you via email. We will be setting up a file sharing link which will enable you to access and download the video. We will email you with a link to access the video file separately once the video file has successfully uploaded. We are aiming to have this video file available for you to download by close of business on 01/07/2022. This information will be available to access for a period of one month from the date of the email after which time it will be automatically deleted. You will need to create an account on ShareFile using the same email address that you have used to correspond with us.
If you are not content with the outcome of your review, you may apply directly to the Information Commissioner (ICO) for a decision. Generally, the ICO cannot make a decision unless you have exhausted the complaints procedure provided by the Gambling Commission. The ICO can be contacted at: The Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.
Further Review Response (3)
Further to our email dated 30/06/2022, I can confirm that the video file has now been uploaded to Share File and you will shortly be receiving an email with a link to enable you to access the video file.
You will be able to either view or download the video file and this will be available until 01/08/2022 after which time it will be automatically deleted.
You will need to create an account on ShareFile using the same email address that you have used to correspond with us.
Further Review Request
Further to your provision to me of a heavily edited and redacted video of a Bet Index Ltd Compliance Assessment video from February 2020, this is a request for full disclosure of the contents of the video in the public interest. I do not accept the application of any exemptions.
Further Review Response (4)
Thank you for your email below.
You originally submitted a request for the recording of the Bet Index financial assessment on 30/04/2022. We responded to this request on 18/05/2022. On 18/05/2022 you submitted a request for an internal review of our response.
The video that we provided to you on 01/07/2022, was provided in response to your request for an internal review which was received on 18/05/2022.
This information was provided as part of the internal review process. The internal review process provided by the Gambling Commission, as set out in the Freedom of Information Act, has now been exhausted .
If you are not content with the outcome of your review, you may apply directly to the Information Commissioner (ICO) for a decision. Generally, the ICO cannot make a decision unless you have exhausted the complaints procedure provided by the Gambling Commission. The ICO can be contacted at: The Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.
Further Review Request
Thank you for your email. The response you have provided to my previous request (Your ref: [REDACTED]) was ambiguous so I am protecting my position.
I am therefore seeking a formal response to this request under the Freedom of Information Act.
(I have already referred case reference [REDACTED] to the Information Commissioner's Office).
Further Review Response (5)
Thank you for your email.
To clarify, we have responded to your original request (ref [REDACTED]) and your review request (ref [REDACTED]) as detailed in our email below. The internal review process has been exhausted for this request.
We will await further communication from the Information Commissioner’s Office in respect of this request.
In your email received on 03/07/2022 you have requested the following: ‘Further to your provision to me of a heavily edited and redacted video of a Bet Index Ltd Compliance Assessment video from February 2020, this is a request for full disclosure of the contents of the video in the public interest. I do not accept the application of any exemptions’
Please could you confirm if you would like this processed as a new request.
ICO Decision Notice
Tribunal Review Request
Please note that I do not accept this decision and there is a very strong possibility that I will appeal this decision to the Information Rights tribunal.
The decision notice is poorly drafted and does not set out full consideration of the circumstances.
Response (6)
Please find attached* (not attached, see text that follows) our response with regards to Tribunal Case reference [REDACTED].
We have enclosed a partial transcript of the meeting held on 26 February 2020, which formed part of the compliance assessment conducted by the Commission, in so far as it relates to the financial assessment of BetIndex Limited and specifically the ability to meet the liabilities for bet dividends.
In light of this disclosure, you may wish to consider if you still wish to pursue your appeal which would now only relate to the names/photographs/voice recordings of the persons attending the meeting.
Response with regards to Tribunal (*referenced previously in - Response (6)).
I write in respect of your request submitted on 30 April 2022 (“the Request”) pursuant to the Freedom of Information Act 2000 (“FOIA”) for any and all audio or video records of the financial assessment into BetIndex Limited (“the Requested Information”). As we have previously confirmed, the Commission holds an audio/visual recording of a Skype meeting held on 26 February 2020 which formed part of a compliance assessment conducted by the Commission. Parts of the meeting on 26 February 2020 considered the financial position of BetIndex Limited at the relevant time, specifically the issue referred to in your Request namely the extent to which BetIndex Limited was able to meet its liabilities for bet dividends.
As you are aware, the Information Commissioner issued a Decision Notice dated 10 November 2022 in which he concluded that the exemption in section 40(2) (Personal Information) of FOIA was engaged in respect of the Requested Information. That Decision Notice is currently the subject of an appeal by you before the First-Tier Tribunal, in respect of which the Gambling Commission (“the Commission”) has been added as a Second Respondent.
The Commission maintains its position that it is entitled to withhold the Requested Information in accordance with section 40(2) of FOIA, in particular, because the Requested Information contains data relating to identifiable individuals that would constitute personal data (specifically the names, photographs and voice recordings of individuals on the call) and those individuals would have a legitimate expectation of privacy with regards to the Requested Information. Further, the Commission maintains its position that no relevant legitimate interest has been identified in disclosure of the Requested Information (in particular in light of the information already disclosed by the Commission or in the public domain at the time the Commission considered the Request), and that the balancing exercise between the legitimate interest in disclosure (if any) and the privacy rights of the individuals lies firmly in favour of protecting the privacy rights of the individuals who attended the meeting. The Commission therefore firmly considers none of the conditions set out in Article 6 of the General Data Protection Regulation are present and, accordingly there is no legal basis for disclosure of the audio/visual recording of the meeting.
However, the Commission has recently given further consideration to the possibility of disclosing information which relates to the financial assessment of BetIndex Limited. Whilst the Commission notes that your Request was specifically for the audio or visual recording of the financial assessment of BetIndex Limited, in the interests of transparency, the Commission has now prepared and decided to voluntarily disclose to you a transcript created of the Skype call in so far as it relates to the financial assessment of BetIndex Limited and specifically the ability to meet the liabilities for bet dividends. This transcript was recently produced to aid the Commission in preparing for your appeal and was not available prior to the submission of your appeal. Nevertheless, we consider the disclosure of the transcript will provide you with the substantive information you seek regarding the contents of the Skype call in so far as it relates to the financial assessment of BetIndex Limited and accordingly narrow the issues which will need to be addressed at the hearing of 29 March 2023.
The relevant extracts of the transcript are attached to this letter, subject to anonymisation and redaction in relation to the names of the individuals present during the Skype call. Those individuals allocated numbers (e.g. ‘Person 1’, ‘Person 2’ etc.) represented BetIndex Limited and those referred to as letters (e.g. ‘Person A’, ‘Person B’ etc.) are Commission employees.
For the avoidance of doubt, we reiterate that the Commission’s position remains that it was entitled to withhold the Requested Information. The Commission’s decision to disclose the transcript of part of the Skype meeting on 26 February 2020 should not be taken as a concession in respect of the correctness or otherwise of its position in respect of the Requested Information, or setting any precedent as to the manner in relation to which the Commission will deal with other requests relating to BetIndex Limited or any other entity that is licensed or has previously applied for a licence from the Commission.
Accordingly, in light of this partial disclosure, the Commission considers that the only remaining issue for the hearing on 29 March 2023 is whether the Commissioner was correct to conclude that the identity of the persons who attended the meeting on 26 February 2020 is exempt under section 40(2). The Commission’s position remains that section 40(2) applies to this information and the Information Commissioner was correct to so conclude. In the circumstances, we invite you to consider whether you wish to continue with your appeal given the disclosure which has now been made by the Commission.
Further, as part of the Commission’s response to the Request, on 1st July 2022 you were provided with a video (without sound) of parts of the compliance assessment. The slides in that video were provided to you in redacted form as some of the material fell within the scope of a previous request being appealed to the First-Tier Tribunal under [REDACTED]. Due to the Commission’s subsequent voluntary disclosure of BetIndex Limited’s unaudited accounts on 4 January 2023, the Commission has reviewed the slides and considers it can disclose a copy of those slides unredacted. These are also attached.
We will be shortly writing to the Tribunal and the parties to provide confirmation of the Commission’s decision to disclose the transcript and providing them with a copy of this letter.
Further Tribunal Request
WITHOUT PREJUDICE
Following [REDACTED] order to postpone the Tribunal hearing to allow for further engagement in relation to the documents recently disclosed by the Gambling Commission, I would be grateful if:
(A) The slide pack is re-sent to me allowing an unequivocal and clear view of the contents of the slides. In a number of cases, it is not possible to clearly make out the text (particularly numbers) as they are blurred.
(B) The slide change-over points are included within the transcript and cross-referenced to the slides to allow the reader to know which slide was being presented at which point in time.
(C) In a number of cases "redacted" has been used in the transcript relating to a person present at the meeting. Persons present at the meeting should be referred to as Person A,B,C.... or Person 1,2,3,...etc...
Response (7)
I write further to your email of 27 March 2023 in which you request the following information:
“(A) The slide pack is re-sent to me allowing an unequivocal and clear view of the contents of the slides. In a number of cases, it is not possible to clearly make out the text (particularly numbers) as they are blurred.
(B) The slide change-over points are included within the transcript and cross-referenced to the slides to allow the reader to know which slide was being presented at which point in time.
(C) In a number of cases "redacted" has been used in the transcript relating to a person present at the meeting. Persons present at the meeting should be referred to as Person A,B,C.... or Person 1,2,3,...etc...”
To address these questions, please see attached the following:
- a slide pack with updated screenshots, which should provide a clearer view of the contents of the slides. The slide pack has also been annotated to include slide numbers so these can be cross-referenced to the transcript.
- an amended transcript with references to the slide change-over points displayed within the transcript and redacted names replaced with the anonymised identifiers (e.g. Person 1, Person A etc.).
I should also make you aware that, in the process of reviewing the transcript to include the slide change-over points, the Commission noticed an accidental omission had been made in the transcript originally disclosed to you, at page 4. One comment had accidentally been omitted. This has now been included in the attached transcript, and marked in bold to indicate which section has been added. Please accept my apologies for this omission. I can however confirm the transcript has been checked again to ensure it is now accurate.
I trust the above will be sufficient to address your outstanding questions regarding this matter. In light of confirmation that you are no longer seeking the personal data of those who attended the meeting, I look forward to receiving notification of the withdrawal of your appeal.
Further Request
WITHOUT PREJUDICE
Thank you for the updated documents and I believe matters are moving towards a final resolution. However, my concern is that the updated transcript, updated slides and original redacted video do not align, specifically at the commencement of the meeting. The unresolved matters are:
- If the Gambling Commission believe there are aspects of the meeting that are out of scope, they should be clearly referenced as such within the transcript.
- The commencement of the updated transcript does not appear to align with the commencement of the slides. Please cross reference slide 1 to the transcript.
- From the updated transcript, it appears that slide 2 was presented without any commentary before a change to slide 3. Is this correct (as according to the redacted video originally released by the Gambling Commission, slide 2 was displayed on screen for approximately one minute) ?
- From the updated transcript, it appears that slide 3 was presented with minimal commentary before a change to slide 4. Is this correct (as according to the redacted video originally released by the Gambling Commission, slide 3 was displayed on screen for approximately one minute) ?
Thank you for your assistance.
Response (8)
Further to your email of 30 March 2023, please see our answers to your questions below:
The Commission has provided to you the information which falls within the scope of your request, with personal data redacted. For the avoidance of doubt, your request sought information relating to the financial assessment which was conducted as part of the remote compliance assessment and we have provided this to you. The remainder of the remote compliance assessment dealt with matters other than a financial assessment of BetIndex and therefore this information falls out of scope. However, please see attached the transcript with the relevant redactions, of matters the Commission considers out of scope.
Slide 1 appears on the video at the very beginning of the presentation. ‘Slide 1’ is now referenced within the transcript.
When slide 2 appeared on the screen, the initial conversation discussed the first three lines of this slide. The first two lines of the slide relate to personal data which has been redacted and therefore anonymised in the transcript. The third line regarding accountants and auditors was left in the slide but not included in the transcript as it was not considered relevant to your request. We have noted however the reference to ‘Slide 2’ in the transcript should have been included at the start of the text box, instead of at the end, which we understand has caused some confusion.
We can confirm the slide reference (slide 3) is in the correct part of the transcript. However, as above, the first part of the conversation regarding the slide related to personal data which has been redacted from the slide and the transcript. The third line regarding bankers has been included in the slide but not in the transcript, as it was not considered relevant to your request.
I trust the above will be sufficient to address your outstanding questions regarding this matter and look forward to receiving notification of the withdrawal of your appeal.
Further Request
Without Prejudice
In his blog post, the Chief Executive of the Gambling Commission referred to "the detailed financial assessment". I am seeking disclosure of "the detailed financial assessment" not merely components of it. It is obvious that matters relating to auditors and bankers form part of "the detailed financial assessment" and therefore should be disclosed.
For the avoidance of doubt, the disclosure by the Gambling Commission should include any and all matters of a financial nature, relating to BetIndex, covered by this meeting. I look forward to receiving what should be the final version of this transcript shortly.
Response (9)
Thank you for your email dated 5 April 2023.
The Commission has provided you with all information held relating to the financial assessment of BetIndex, with personal data redacted. Information considered to be outside the scope of your request has also been redacted from the transcript.
The Commission took the view that factual information relating to BetIndex’s appointed bankers and auditors was outside the scope of your request. Further, we note that this information has already been disclosed within the slides naming the bankers and auditors in response to this request. However, to resolve this matter, the redacted information within the transcript relating to bankers and auditors is provided below highlighted in red. The information highlighted in green has already been provided to you in the redacted transcript.
Slide 2 - We have appointed accountants and auditors. We currently use Sam Rogoff and Co. They’ve been with the company since inception, London based. And just to make the point, all surplus cash is actually used and ploughed back into the product. There’ve been no dividends distributed at the moment from any profits. Everything’s basically ploughed back into growth and into people and tech. We paid £6 million-odd in general betting duty in 2019. [REDACTED PERSONAL INFORMATION] Our bankers are Nedbank for BetIndex, and Barclays and NatWest for Index Labs. We have no debt, no leasing, no long-term capital commitments, no long-term marketing commitments. Can you read that slide, ‘Financial model 2019/2020’?
We confirm that all information relating to the financial assessment has been disclosed to you and look forward to receiving notification of the withdrawal of your appeal.
Tribunal Appeal Withdrawn
Dear Tribunal,
Case Reference: [REDACTED] - Response to Order dated 24 March 2023
In March 2021, Football Index collapsed with the loss of over £124 million of customer funds. The collapse and resultant customer losses has changed the lives of many thousands of Football Index customers.
This case relates to a request made for all audio and video recordings held by the Gambling Commission of an alleged financial assessment of BetIndex Limited, which traded as Football Index.
On 22 March 2023, seven days before the proposed Tribunal hearing into this case, the Gambling Commission disclosed to the Tribunal and the parties what they asserted was the transcript of the audio recording along with partially-readable slides.
Following my request, on 24 March 2023, the Tribunal postponed the hearing to allow for more time for the parties to seek an informal resolution of this case.
After further enquiries, it appears that the disclosed transcript was heavily edited by the Gambling Commission (without any notes to the reader that it had been edited). The Gambling Commission have subsequently disclosed a revised transcript along with readable slides.
On the basis of the revised transcript and readable slides, I am content to withdraw my appeal. However, should the revised transcript prove not to be complete or accurate then I reserve my position with regard to any further action or requests. I also remain concerned with the Information Commissioner’s Office’s diligence in this case. It is clear to me that more information could have been disclosed at a much earlier stage of my request.
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