Participation in Financial Risk Checks
Request
Please can you supply copies of all correspondence between the Gambling Commission and every gambling operator the Commission contacted regarding participation in the Financial Risk Assessments pilot programme? This information is requested for the period January 2024 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 every gambling operator the Commission contacted regarding participation in the Financial Risk Assessments pilot programme, for the period January 2024 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.
The Commission can confirm that information is held falling within the scope of your request. However, we consider that disclosing this level of detail in relation to gambling operators 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 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).
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.
Arguments in favour of disclosure:
- It is recognised that there is a legitimate public interest in promoting the transparency of the Commission and in making information available to the public.
- The quality of communication between stakeholders may improve if there is an expectation that the information may be made publicly available.
Arguments in favour of maintaining the exemption:
- An extensive range of data is already available to the public in order to give a necessary level of understanding of this programme of work.
- Detail of individual companies does not contribute to the understanding of our work. We consider that disclosing the information could discourage individuals from engaging with certain operators in future.
- Providing specific, identifying information could lead to comparisons being made between organisations, leading to unjustified inferences being made without the full context.
- 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. Publication could therefore allow for misinterpretation and manipulation of the research.
Weighing the balance
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 the organisations.
We recognise that the subject of your request is a live matter of public interest which is the reason we have planned to continue to provide details of our decisions and the reasons for those decisions through policy consultations, consultation response documents and through publishing other 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 update – July 2026 (opens in new tab)
Blog - Financial risk assessments pilot update (opens in new tab)
Blog - Financial risk assessments pilot – update on progress (opens in new tab)
Blog - Financial risk assessments pilot – update on Stage two (opens in new tab)
Blog - Financial risk assessments pilot – update on post-pilot analysis (opens in new tab)
Blog - Financial vulnerability checks: Insights from implementation (opens in new tab)
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