Financial assessment of Football Index

Request

On 26th February 2020 during the financial assessment of Football Index Person F confirmed that the Market Maker had been spoken to on 25th February. Please provide redacted transcript of that conversation together with any slides that were presented. It can be presented in the same way as the detailed financial assessment. ICO have ruled this in the public interest and any failure to disclose will be presented to [REDACTED] immediately. As [REDACTED] was conducting Market Making activities in his role as Head of Trading at this time then also please provide any details of the 3rd party Market Maker (LP001) owned by Index Labs Limited “market making policy” which must have been referred to you and if not why not.

Response

Thank you for your request which has been processed under the Freedom of Information Act 2000 (FOIA). Please accept our apologies for the delay in responding to you.

In your email dated 18 July 2023 you requested the following information:

On 26th February 2020 during the financial assessment of Football Index Person F confirmed that the Market Maker had been spoken to on 25th February. Please provide redacted transcript of that conversation together with any slides that were presented. It can be presented in the same way as the detailed financial assessment. ICO have ruled this in the public interest and any failure to disclose will be presented to [REDACTED] immediately. As [REDACTED] was conducting Market Making activities in his role as Head of Trading at this time then also please provide any details of the 3rd party Market Maker (LP001) owned by Index Labs Limited “market making policy” which must have been referred to you and if not why not.

Please find attached a copy of the draft Market Maker Policy. Personal information relating to identifiable individuals has been redacted from the Policy.

We have reviewed the transcript of the meeting that was held on 25th February, and it is our view that the transcript is exempt from disclosure in its entirety and S40(2) Personal Information is engaged.

The Data Protection Act 2018 requires the processing of personal data to be fair and lawful. The Commission considers that any disclosure of the transcript would disclose the personal data of a third party, It would therefore be disproportionate for us to publicly disclose this information unless there is a strong public interest in doing so. This individual in the position of Market Maker has a legitimate expectation that their personal information will not be disclosed in the context in which it is held.

On balance, there is no legitimate public interest in disclosing this information and it would not be fair to do so.

This information is therefore exempt under section 40(2) of the Freedom of Information Act 2000.

I can confirm that there were no slides presented in the assessment. During the assessment, the representatives of BetIndex shared a screen with participants where they demonstrated the system.

Review of the decision

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Information Management Team
Gambling Commission
Victoria Square House
Victoria Square
Birmingham B2 4BP

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