Office for Statistics Regulation Correspondence
Request
'Please can you provide copies of all correspondence (and related memoranda) between the Office for Statistics Regulation and the Gambling Commission between 1st January 2024 and the present date?'
Response
Thank you for your request which has been processed under the Freedom of Information Act 2000 (FOIA).
In your email you have requested:
'Please can you provide copies of all correspondence (and related memoranda) between the Office for Statistics Regulation and the Gambling Commission between 1 January 2024 and the present date (7 February 2025)?'
Please see the attached information held by the Gambling Commission we are able to disclose falling within the scope of your request.
Within the disclosed information is a communications strategy for how comms was overseen during the publication of the Gambling Survey for Great Britain (GSGB) Annual Report launch (page 23-33). Within this strategy is a ‘think/feel/do’ matrix. This matrix usually considers the shift from ‘current position’ to an anticipated ‘think/feel/do’ if good comms is delivered. In this instance an error occurred meaning the ‘think’ column was a commentary on how audiences may be thinking in the build up to the GSGB Annual Report being released rather than the future state. This does not alter how we communicate in general or in this case in particular.
The following exemptions also apply to some of the information that we hold.
Section 40(2)
We have redacted from the attached, information relating to identifiable individuals that would constitute personal data. This includes names.
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 documents 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.
Section 22
We also consider some information is exempt under section 22 of the FOIA. The exempt information is to be published by OSR shortly in their light touch review of the GSGB.
Section 22(1) of the FOIA (“information that is intended to be published in the future”) provides that information is exempt if:
a. the information is held by the public authority with a view to its publication, by the authority or any other person, at some future date (whether determined or not),
b. the information was already held with a view to such publication at the time when the request for information was made.
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.
Arguments in favour of disclosure
It is recognised that there is a legitimate public interest in promoting the accountability and transparency of public authorities and in Government Departments providing information they hold that falls within the scope of an FOI request as quickly as possible.
Arguments in favour of maintaining the exemption
However, this needs to be balanced with the public interest in the Commission ensuring the maximum time/cost effectiveness; providing this information in response to a FOI request is not the most time/cost effective way of placing this information in the public domain when it will be published in due course by the OSR.
Weighing the balance
Having considered the above factors, the Commission is of the view that the balance of the public interest lies in maintaining the exemption. There is no outstanding public interest in releasing this information prior to its intended publication by the OSR. Given the necessary preparation and administration involved in publishing the information, we consider that OSR’s timetable for publication is reasonable.
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 new tab), Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.
Information Management Team
Gambling Commission
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