Correspondence with DCMS regarding Financial Risk Assessments Pilot
Request
Please can you supply copies of all correspondence between the Gambling Commission and the Department for Culture, Media and Sport regarding the evaluation of the Gambling Commission pilot of Financial Risk Assessments? This information is requested for the period 1st January 2025 to the present.
Response
Thank you for your request which has been processed under the Freedom of Information Act 2000 (FOIA).
In your email you have requested copies of all correspondence between the Gambling Commission and the Department for Culture, Media and Sport regarding the evaluation of the Gambling Commission pilot of Financial Risk Assessments. This information is requested for the period 1st January 2025 to the present.
Financial risk assessments are a proposed way of identifying high-spending remote gambling customers who may be in financial difficulties, in order to help support them.
The Gambling Commission are testing whether - and how - financial risk assessments could be introduced in a way that supports high-spending customers in financial difficulties but also supports a frictionless customer journey for the vast majority of customers. NatCen is working as our evaluation partner to support this work advising on methodology and clarity and transparency of use of data. Further information regarding what we are seeking to achieve and how we have approached setting potential thresholds for assessments is in our interim consultation response on financial risk assessments and in a series of blog updates. For example, the Commission has previously released information about the pilot of financial risk assessments and insights from implementation of financial vulnerability checks through a series of blogs which you may find useful, such as:
Blog - Financial risk assessments pilot update
Blog - Financial risk assessments pilot – update on progress
Blog - Financial risk assessments pilot – update on Stage two
Blog - Financial risk assessments pilot – update on post-pilot analysis
Blog - Financial vulnerability checks: Insights from implementation
The Commission plan to continue to provide details of our approach, decisions, and NatCen’s role through consultation response documents and through publishing data, other reports and updates. As such, we are of the view that this information is exempt under section 22A(1) (“Research Information”) of the FOIA.
Section 22A(1) (“Research Information”) provides that Information obtained in the course of, or derived from, a programme of research is exempt information if:
(a) the programme is continuing with a view to the publication, by a public authority or any other person, of a report of the research (whether or not including a statement of that information), and
(b) disclosure of the information under this Act before the date of publication would, or would be likely to, prejudice the programme,
i. the interests of any individual participating in the programme,
ii. the interests of the authority which holds the information, or
iii. the interests of the authority mentioned in paragraph (a) (if it is a different authority from that which holds the information).
Public interest test
This is a qualified exemption; therefore, the Commission must consider whether the public interest in maintaining the exemption is greater than the public interest in disclosing the requested information. These arguments are as follows:
Arguments in favour of disclosure:
- there is a legitimate public interest in promoting the accountability and transparency of public authorities.
- there is a public interest in Government Departments providing information they hold, that falls within the scope of an FOI request, as quickly as possible.
- disclosure of the raw data and the conversations about it allows for a wider evaluation of the conclusions that have been published.
Arguments in favour of maintaining the exemption:
- this needs to be balanced with the public interest in the Commission ensuring the maximum time/cost effectiveness.
- this research is ongoing and there is an intention to publish data, alongside any supporting analysis.
- as such, authorities should be able to complete research before it is subjected to external scrutiny.
- premature publication of this data could lead to an incomplete and confusing picture emerging and would be likely to cause prejudice to the programme of research and statistics.
Weighing the balance
Whilst we recognise that there is a public interest in promoting the transparency and accountability of public authorities in a timely manner, there is no outstanding public interest in releasing this information whilst the programme is still ongoing. Having considered the above factors, the Commission is of the view that the balance of the public interest lies in maintaining the exemption.
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.
It should be noted that if you wish to raise a complaint with the ICO about the Commission’s handling of your request for information, then you are required to do so within six weeks of receiving your final response or last substantive contact with us.
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