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BetIndex – Supporting documents

Request date
6 May 2022

Outcome
Information withheld

Document actions
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Request

I am seeking copies of all documents containing the following information in relation to Bet Index (trading as Football index):

  1. The accounting policy they adopted for revenue recognition (including bets and payouts to customers).
  2. The methodology for valuing football players when they were launched on the Football Index stockmarket.

You have previously provided me with "financial assessments" in relation to Bet Index. It is likely that the persons who carried out these assessments would be aware whether the information I am seeking is held.

Response

Thank you for your request which has been processed under the Freedom of Information Act 2000 (FOIA).

Your request was for the following information:

Copies of all documents containing the following information in relation to Bet Index (trading as Football index):

  1. The accounting policy they adopted for revenue recognition (including bets and payouts to customers).
  2. The methodology for valuing football players when they were launched on the Football Index stockmarket.

I can confirm that the Commission does hold information relating to the accountancy policy for revenue recognition, however, this is included within the BetIndex 2018 Unaudited accounts.

Disclosure of this information has previously been refused by the Gambling Commission citing section 31(1)(g) by virtue of subsection 31(2)(c) of FOIA.

The Information Commissioner’s Office decision notice (PDF) (opens in new tab) explained that the exemption is engaged but that the public interest lies in disclosure. However, the Commission are appealing this decision notice to the First-Tier Tribunal (Information Rights).

As such, at this stage pending the outcome of the tribunal, the Commission is of the view that the information requested is exempt from disclosure under section 31(1)(g) FOIA and therefore will not be released.

With regards to question 2, after a review of the information that we hold, I have been unable to identify information which falls within the scope of this request, therefore, we do not hold this information.

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. However, the response isn't satisfactory so I am requesting an internal review.

  1. I do not accept the application of any FOIA exemption in this case
  2. The public interest test hasn't been carried out (it needs to be carried out based on circumstances today)
  3. The public interest favours disclosure.
  4. I believe more information is held than has been mentioned in the response so I am requesting that information is disclosed.

The collapse of Bet Index, a Gambling Commission regulated business, is one of the largest collapses in UK Gambling history with the loss of over £124m of customer funds. Your decision to withhold this information is vexatious.

Review Response

Further to your Freedom of Information request dated 06/05/22 which we responded to on 23/05/22, and your subsequent request for an internal review received on 23/05/22, 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.

In your original request you requested copies of all documents containing the following information in relation to Bet Index (trading as Football index):

  1. The accounting policy they adopted for revenue recognition (including bets and payouts to customers).
  2. The methodology for valuing football players when they were launched on the Football Index stockmarket.

In our original response, we advised that the Commission does hold information relating to the accountancy policy for revenue recognition, however, this is included within the BetIndex 2018 Unaudited accounts.

Disclosure of this information has previously been refused by the Gambling Commission citing section 31(1)(g) by virtue of subsection 31(2)(c) of FOIA.

The Information Commissioner’s Office decision notice explained that the exemption is engaged but that the public interest lies in disclosure. However, the Commission are appealing this decision notice to the First-Tier Tribunal (Information Rights).

As such, at this stage pending the outcome of the tribunal, the Commission is of the view that the information requested is exempt from disclosure under section 31(1)(g) FOIA and therefore will not be released.

We also stated that, with regards to question 2, we were unable to identify information which falls within the scope of this part of your request, therefore, we do not hold this information.

I have considered our current position with regard to the release of the BetIndex 2018 Unaudited accounts, and at this time agree with the application of the section 31(1)(g) exemption.

With regard to question 2, I have reviewed further the information we hold, and can confirm that we do not hold information that falls within the scope of this part of your request.

In conclusion, I uphold our original decision, therefore, we are unable to fulfil your request.

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.

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