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Request date: 17 August 2023
This version was printed or saved on: 29 May 2025
Online version: https://www.gamblingcommission.gov.uk/about-us/freedomofinformation/enhanced-and-frictionless-checks
Any advice provided by the Gambling Commission to the government, or made in internal discussion, relating to the claim made in the white paper that just three per cent of account holders will be affected by "enhanced" checks.
Any advice provided by the Gambling Commission to the government,or made in internal discussion, relating to "frictionless" checks and, in particular, the assertion in annex A of the white paper that 80 percent of accounts meeting the spend threshold would undergo frictionless checks.
Any emails sent by Andrew Rhodes and Sarah Gardner to the DCMS and gambling minister on the subjects listed in points 1 and 2 above.
Thank you for your request which has been processed under the Freedom of Information Act 2000 (FOIA).
In your email you have requested:
Any advice provided by the Gambling Commission to the government, or made in internal discussion, relating to the claim made in the white paper that just three per cent of account holders will be affected by "enhanced" checks.
Any advice provided by the Gambling Commission to the government, or made in internal discussion, relating to "frictionless" checks and, in particular, the assertion in annex A of the white paper that 80 percent of accounts meeting the spend threshold would undergo frictionless checks.
Any emails sent by Andrew Rhodes and Sarah Gardner to the DCMS and gambling minister on the subjects listed in points 1 and 2 above.
In response to parts 1 and 2 of your request:
Section 21 of the FOIA provides that information is exempt where it is reasonably accessible elsewhere.
The advice the Commission provided to Government can be found on our website at the following link:
The advice relating to checks can be found in the section titled “Online protections, players and products” on pages 20-32 of the PDF document.
In relation to part 3 of your request, unfortunately there will be a small delay in providing you with this part of our response.
We will provide you with a response as soon as possible.
Please do accept our apologies for this delay.
Thank you for your request which has been processed under the Freedom of Information Act 2000 (FOIA).
In your email of 17/08/2023 you requested:
On 19/09/2023 we responded to parts 1 and 2 of your request, advising that the advice the Commission provided to Government can be found on our website at the following link:
In relation to part 3 of your request, we advised that there would be a small delay in providing you with this part of our response.
On 20/09/2023, you wrote to us informing us that - In terms of points 1 and 2, the reply has not answered the question regarding "internal discussion". As such your request has now been reconsidered in its entirety.
I can confirm that the Commission does hold information falling within the scope of all of your request. However, this information is not stored in a central location and requires a manual review across several Gambling Commission information storage areas, including high volumes of email correspondence.
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 may contain relevant information and would need to be checked individually.
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 narrow your request, we may be able to provide some data by working up to the time limit.
Until we are able to process the search and retrieval of the information you have requested, that can be provided within the statutory time limit, we are unable to ascertain if other exemptions will apply to the material retrieved, 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.
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