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External Testing Report from GLI


Document KE 1-229945321 Labsdaq has been previously released under FOI regarding Betindex Limited Licence Number 43061. Line 86 of the Document refers to an External Testing Report from GLI (Fairness) Please release a copy of this report redacted where required. I would like to remind you that a previous testing report has also been released, after appeal, so there is no legitimate reason for refusing this request in full. Please also provide a copy of the confirmation from the Gambling Commission that the new software could be integrated.


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

In your email you have requested the External Testing Report from GLI (Fairness) reference in line 86 of the previously released document KE 1-229945321.

As you will be aware, the Commission is a regulatory body with licensing, compliance and enforcement functions. Through our regulatory enforcement activity, the Commission aims to protect consumers and the wider public, and to raise standards in the gambling industry.

The Licence Conditions and Codes of Practice (LCCP) impose an obligation on gambling operators to submit key events.

We expect Licensees to work with us in an open and cooperative way and to inform us of anything we might need to be aware of in order to regulate effectively. We encourage operators to be as thorough and as detailed as possible with their submissions. They would not do this if they believed that the information they provided would be released, and the quality of the information that we receive from operators would be impacted as a result.

Given the nature of the information contained within this report and consequently the impact to the regulatory work of the Commission in releasing those records, we are of the view that some of the information contained within the report, is exempt under the FOIA.

We have redacted from this report information relating to identifiable individuals that would constitute personal data.

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 the attached document 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.

Further to this, we consider that information identifying this level of detail about individual companies, to be of a commercially sensitive nature. This level of detail is not otherwise in the public domain, therefore, we are of the view that this information is exempt under section 43 of the FOIA.

Section 43(2) Commercial Interests

Section 43(2) of the FOIA provides that information is exempt information if: its disclosure under the FOIA would, or would be likely to, prejudice the commercial interests of any person (including the public authority holding it).

The Public Interest Test

Having acknowledged that some of the information within the scope of your request is exempt from disclosure, section 43 FOIA requires that we consider a public interest test to identify whether there is a wider public interest in fulfilling this request opposed to maintaining the exemption.

Public interest arguments in favour of disclosure

  • there is a legitimate public interest in promoting accountability and transparency of public authorities
  • Increased transparency regarding operators would promote consumer confidence and help them make informed choices.
  • There is considerable public interest in general relating to the collapse of Bet Index.

Public interest arguments in favour of maintaining the exemption

  • Businesses which have interacted with those licenced by the Commission e.g. the licensee’s subcontractors, have a reasonable expectation that their information would not be published on an individual basis, particularly whilst they (the subcontractors) are trading, even where the licensee no longer exists.
  • Details of individual companies not directly associated with the gambling industry does not contribute to supporting consumers with their choice of operator.
  • The amount of information released regarding companies who have engaged with licensees is carefully considered, particularly where an operator has been the subject of action or scrutiny. This is in order to protect the integrity of the individual companies from being unfairly associated with negative inferences.

Weighing the Balance of public interest arguments

Whilst the Commission aims to be open and transparent, there is a need to preserve the confidentiality of information submitted on that basis and to be mindful of the commercial sensitivities of information that is held.

Having weighed these issues, the Commission is of the view that the public interest is best served through maintaining this exemption. There is very little that providing this information would do in terms of the public interest whilst disclosure would be likely to impact on the commercial interests of individual companies .

Please see the attached report, as requested.

Further to this you have requested a copy of the confirmation from the Gambling Commission that the new software could be integrated.

I can confirm that no recorded information is held falling withing the scope of this part of your request.

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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