Politically Exposed Individuals
Request
As per the Act, I am requesting the following information:
- The number of politically exposed people identified in due diligence carried out on white label license holders and partner.
To avoid the Commission being asked to comment on a particular operator, the scope of this request covers all white label agreements currently in place.
Knowing your commitment to privacy, I do not request identifiable details, but merely wish to know the number of PEPs on the relevant records.
Response
Thank you for your request which has been processed under the Freedom of Information Act 2000 (FOIA).
In your email you have requested:
The number of politically exposed people identified in due diligence carried out on white label license holders and partners.
In order for the Gambling Commission to establish whether information is held relating to politically exposed people identified in the due diligence carried out on white label licence holders and partners, a review would need to be take place across a number of our systems and records as this information would not be stored in a central location.
Section 12 of the Freedom of Information Act 2000 (FOIA) makes provision for public authorities to refuse requests for information where the cost of dealing with them would exceed the appropriate limit, which for public authorities, such as the Commission, is set at £450. This represents the estimated cost of one person spending 18 hours in determining whether the department holds the information, locating, retrieving and extracting the information.
We estimate that it would take in excess of 18 hours to determine appropriate material and locate, retrieve and extract any relevant information in reference to your request as there is a high volume of records which will need to be individually reviewed to establish whether we hold relevant information.
When a public authority applies the Section 12 exemption to a request, the FOIA guidance specifically states that a public authority should avoid providing any information found as a result of a search as it denies the requestor the right to express a preference as to which parts of the request they may wish to receive within the appropriate time limit. Guidance on the application of section 12 can be viewed here:
The Information Commissioner’s Office (opens in a new tab)
If you are able to refine your request, we may be able to narrow the number of records that we need to search. Until we are able to process the search of the information you have requested, we are unable to ascertain if other exemptions will apply to any material identified which would also prevent disclosure.
Please note, any refined request would be processed as a new request and the 20 working day statutory time limit would apply.
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