Key Event Notification
Request
Under the Freedom of Information Act 2000, I am requesting institutional data regarding recorded information held by the Gambling Commission on the following four points:
Did the Gambling Commission receive a "Key Event" notification under Licence Condition 15.2.1 or a technical incident report under RTS 3 from either "Recro Limited" (Operating Licence: 056448-R-332766) or "BeyondPlay" on 5th April 2025 (05/04/2025)?
If a technical incident or jackpot system freeze/switch was registered on that date, what is the exact date and timestamp (hour and minute) when the Gambling Commission's systems first logged this event notification?
What specific administrative, compliance, or regulatory actions did the Gambling Commission initiate between 5th April 2025 and 30th April 2025 in response to this event (e.g., requesting technical reports or opening a compliance review)?
Between 5th April 2025 and 30th April 2025, did the Gambling Commission exchange any official correspondence with the approved test house eCOGRA regarding a technical malfunction, code verification, or audit trails for this jackpot software?
This request seeks purely administrative and statistical data regarding the Commission's duties and does not request any personal data of individual players. If specific details are deemed exempt under Section 43 (Commercial Interests) or Section 31 (Law Enforcement), please provide a redacted disclosure confirming only whether a technical incident was formally recorded in your systems during April 2025.
Response
The Commission is a regulatory body with licensing, compliance, and enforcement functions; through our regulatory activity, the Commission aims to protect consumers and the wider public, and to raise standards in the gambling industry. We take care to publish as much information as possible. However, we must also be careful not to reveal any information that could hinder our ability to conduct investigations or enable those we may investigate to avoid detection. The Gambling Commission do not provide comment on any specific operators unless it is in the public interest to do so. As such, we are unable to confirm or deny whether we hold any information within the scope of your request. Section 31(3) of the FOIA (Law Enforcement) exemption applies.
Having acknowledged that the Commission is not able to confirm or deny whether we hold any information within the scope of your request, section 31 of the FOIA requires that we consider a public interest test to identify whether there is a wider public interest in fulfilling this request as opposed to maintaining the exemption.
Arguments in favour of disclosure
The Commission is a public body which is required to regulate the gambling industry in the public interest. There is therefore a public interest in members of the public having confidence the Commission is being open and honest with the information it holds so that it can be held to account.
It is important that the public are assured that the Commission is carrying out its functions in ensuring that it is fulfilling its statutory obligations as set out in section 22 of the Gambling Act 2005. The statutory duties laid out in section 1 are:
a. preventing gambling from being a source of crime or disorder, being associated with crime or disorder or being used to support crime,
b. ensuring that gambling is conducted in a fair and open way, and
c. protecting children and other vulnerable persons from being harmed or exploited by gambling.
Finally, fulfilling this request may encourage stakeholders to work with us and contribute to our programme of work, increasing confidence in the Commission as a regulator and its ability to uphold the law.
Arguments in favour of maintaining the exemption
The Commission has robust and effective processes and procedures in place which are utilised when carrying out activities which contribute to our regulatory functions. These procedures and processes have been put in place to increase the integrity of our work, demonstrating to the public at large that they can have confidence in the Commission’s ability to uphold its statutory obligations.
Confirming or denying information which makes specific operators or events identifiable could alert individuals involved to the fact that the Commission was/is or alternatively wasn’t/isn’t engaging in specific conversations; providing an opportunity for individuals to alter their behaviours or evade detection. This would result in making it more difficult for the Commission to achieve its aims.
Further to this, simply confirming or denying this request for information would impact on the openness of stakeholders when sharing important information with us or other law enforcement agencies. The amount of information released is carefully considered in order to protect the integrity of the Commission's work and individuals from being unfairly associated with unsubstantiated allegations.
Weighing the balance
Given the points considered, disclosure of the information would be damaging to the Commission as a regulatory body which serves to protect the wider public interest.
Ultimately, the Gambling Commission regulates gambling in the interests of consumers and the wider public. As such, the Commission believes that the interests of the public are better served through maintaining the exemption, therefore, we are not in a position to confirm or deny whether we hold any information in relation to 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.
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