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Licensing agreements with BetIndex


I would like to request copies of all licensing agreements that have been made between yourself and the group of companies associated with Index Labs and Football Index. This includes Bet Index and personal gambling licences that have been granted to directors, and the individual (REDACTED).

REDACTED To date I have only seen the licence agreement issued by the Jersey Gambling Commission, which was included in the court bundle post administration. The licensing agreements issued by the UKGC were not included in the court bundle, and I am not aware of them being in the public domain.


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 licensing agreements that have been made between the Gambling Commission and the group of companies associated with Index Labs and Football Index. This includes Bet Index and personal gambling licences that have been granted to directors, and the individual REDACTED.

Copies of the licencing documentation issued to operators is not released into the public domain. We do publish some details of operator licences on our website. Further to this, the Licence conditions and codes of practice (LCCP) set out the requirements all licensees must meet in order to hold a Gambling Commission licence.

The license application form expressly states that information provided will be treated in confidence. Therefore, there is a legitimate expectation that such information will be treated accordingly.

The Commission does not disclose information relating to its correspondence with operators as the Commission relies on their submissions at the application, assessment and review stages of our licensing processes. We encourage operators to make frank submissions to us to allow us to take appropriate steps in a timely manner, reviewing licence holders thoroughly and fairly.

Disclosure of such information would be likely to impact on the voluntary supply of information from the operator in question and potentially other operators also.

Section 31 of the Freedom of Information Act 2000 (FOIA) (Law Enforcement) provides that information held by a public body is exempt if its disclosure would, or would be likely to prejudice the exercise of a public body of its functions for any of the purposes specified in subsection (2):

  • d) the purpose of ascertaining a person’s fitness or competence in relation to the management of bodies corporate or in relation to any profession or other activity which he is, or seeks to become, authorised to carry on.

The Commission is of the view that this exemption applies for all of the information that you have requested. Having acknowledged that the requested information is exempt under section 31 it is necessary that I consider a public interest test to identify whether there is a wider public interest in disclosing this information as opposed to maintaining the exemption.

The Commission acknowledges that there is a legitimate public interest in promoting the accountability and transparency of public authorities. Fulfilling this request may increase public awareness of work carried out by the Commission and support them in their choice of operator. Further to this, increasing confidence in the Commission as a regulator.

However, the Commission relies on a variety of sources sharing information in order to function as a regulatory body. Discussing within the public domain information which has been passed to us may deter these sources from sharing important material with us, as such prejudicing our regulatory functions.

The Commission requires license applicants to make full and candid submissions both at application stage and throughout the life of the license. We provide assurance that we will respect the confidentiality of information that we are provided with.

Finally, releasing information at this level of detail is likely to also reveal the techniques the Commission uses. This could severely hamper the effectiveness of the Commission’s processes in future.

Having considered the balance of the public interest, the Commission is of the view that the balance of the public interest lies with maintaining the exemption. The Commission recognises the importance of having sufficient information in the public domain to support consumers with their choice of operator. However, disclosure of the information would be damaging to the Commission as a regulatory body which ultimately serves to protect the wider public interest

Kind regards

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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