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Request date: 8 March 2023
This version was printed or saved on: 9 May 2025
Online version: https://www.gamblingcommission.gov.uk/about-us/freedomofinformation/information-on-grosvenor-casinos
I am writing to request information regarding the gambling operator Grosvenor Casinos located at 84 Hill St, Birmingham B5 4AH. I am currently in a dispute with this operator and I am seeking to obtain essential details about their operations and procedures in order to pursue a resolution through the appropriate channels.
In order to facilitate this, I require specific information regarding the operator's management or ownership, as well as any licenses, permits, or enforcement actions relevant to their operations. I am seeking to ensure that my legal rights and interests are protected throughout the dispute resolution process.
Thank you for your request which has been processed under the Freedom of Information Act 2000 (FOIA).
In your email you have requested information regarding Grosvenor Casinos located at 84 Hill St, Birmingham B5 4AH. Including; the operator's management or ownership, as well as any licenses, permits, or enforcement actions relevant to their operations.
Gambling operators are required to hold a licence from the Commission in order to offer facilities for gambling to customers located in Great Britain. The Commission goes through a licence application process as part of this and makes an assessment of suitability against criteria set out in the Act. Part 5 of the Gambling Act 2005 details the Commission’s statutory functions in relation to the licensing requirements. The Licence conditions and codes of practice (LCCP) set out the requirements all licensees must meet in order to hold a Gambling Commission licence.
Licence Conditions and Codes of Practice
Section 21 of the FOIA provides that information is exempt where it is reasonably accessible elsewhere.
We publish registers of licensed businesses and individuals here:
Register of gambling businesses - Gambling Commission
The publicly available licence details for Grosvenor Casinos located at 84 Hill St, Birmingham B5 4AH t can be viewed here:
Premises - Grosvenor Casinos (GC) Limited - Gambling Commission
Premises - Gambling Commission
When we receive licence applications an assessment is made on whether a business will uphold the licensing objectives and also the suitability of the applicant to carry out the activities that the licence allows. As part of this assessment the Commission will request the following evidence to support the application and the individuals who are relevant to the application, such as:
Details with regards to how we process a licence application can be found on our website:
Apply for a licence to operate a gambling business
These checks are carried out to ensure that we meet our obligations under the Act and our Statement of Principles.
Statement of principles for licensing and regulation
Once licensed, gambling operators are subject to ongoing compliance requirements and are subject to regulatory action should they fail to meet their licence requirements.
Information collated as part of this process is used to assess whether a person or entity is fit to hold a licence
I can confirm that information falling within the scope of your request is held. However, the Commission is of the view that any information in relation to specific operators, other than what is made publicly available, is exempt from disclosure under section 31(1)g of the FOIA (‘law enforcement’) and therefore will not be released.
Section 31
Section 31(1)(g) exempts information whose disclosure would, or would be likely to, prejudice the exercise by any public authority of its functions for any of the purposes specified in subsection (2).
The Commission considers the subsections below apply and therefore the information is exempt from disclosure:
Public interest test
The factors the Commission has considered when applying the public interest test have been detailed below.
Arguments n favour of disclosure:
Weighing the balance
The Commission acknowledges that there is a public interest in promoting the accountability and transparency of public authorities and the importance of having sufficient information in the public domain to support consumers with their choice of operator, however, disclosure of the information would be damaging to the Commission as a regulatory body which ultimately serves to protect the wider public interest.
It is important that the public are assured that the Commission is carrying out its functions in ensuring that any individuals/organisations who are involved in providing gambling facilities to the public have undergone the necessary assessments and will uphold the licencing objectives ensuring that consumers are protected.
However, there is a strong public interest in preserving the processes that the Commission has in place to assess operators’ compliance with the LCCP and identify any operators who will be unable to comply with the licensing requirements. The public trust that the Commission has robust processes in place to assess operators so that when they use the services provided by an operator, they are confident that there has been sufficient scrutiny of that operator to ensure that they are protected. If this information were released it would undermine that confidence.
We consider that the public interest is better served by withholding this information, ensuring that consumers are protected through our processes rather than releasing information about our processes which in our view will not benefit the public as a whole.
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
I am writing to request an internal review of the Gambling Commission's decision in relation to my Freedom of Information (FOI) request dated [Date of your original request] concerning Grosvenor Casinos located at 84 Hill St, Birmingham B5 4AH. My request sought information on the casino's management or ownership, licenses, permits, and any enforcement actions relevant to their operations.
The response I received on [Date of the response] cited Section 31(1)(g) of the Freedom of Information Act 2000 (FOIA) as the reason for withholding specific information about the casino. While I appreciate the public interest test undertaken by the Gambling Commission, I believe that there are further arguments in favour of disclosure that merit reconsideration.
Firstly, I contend that transparency in the gambling industry is of paramount importance for maintaining public trust and confidence in the regulatory process. As such, disclosure of the requested information could contribute to an enhanced understanding of the Gambling Commission's assessment and oversight of licensed operators, as well as the measures taken to uphold the licensing objectives.
Secondly, while I appreciate the concerns raised about potentially undermining the Commission's compliance assessment processes, I argue that disclosure of certain information about the casino's management or ownership and any enforcement actions does not necessarily reveal the specific techniques or practices employed by the Commission. The release of such information, in a redacted or anonymised form, if necessary, may still serve the public interest in promoting accountability and transparency without jeopardising the Commission's enforcement capabilities.
Thirdly, providing the requested information could improve public knowledge of the standards and requirements that licensed operators must meet. This increased awareness may encourage other gambling operators to maintain compliance and adhere to the Licence Conditions and Codes of Practice (LCCP), thus fostering a safer and more responsible gambling environment.
Fourthly, disclosing the requested information could allow members of the public to make informed decisions about their patronage of gambling establishments. By understanding the casino's management or ownership and any enforcement actions taken, potential customers can make choices aligned with their personal values and concerns.
Fifthly, the release of information on enforcement actions could serve as a deterrent for non-compliant operators, demonstrating that the Gambling Commission takes its regulatory role seriously and that failure to meet the required standards has consequences. This would further enhance public confidence in the Commission's ability to protect consumers and maintain a fair and transparent gambling industry.
Sixthly, access to the requested information may empower local communities and stakeholders to engage more effectively with the casino and its management. This could foster stronger relationships between the casino and the community, leading to improved social responsibility and better overall outcomes for the area.
Seventhly, transparency in the disclosure of enforcement actions may stimulate industry-wide improvement by highlighting areas of concern or common issues. This could encourage other operators to review their own practices and policies, ensuring a higher overall standard of compliance within the gambling sector.
Eighthly, revealing information about the casino's management or ownership could contribute to a more thorough understanding of the industry's corporate structure, facilitating public scrutiny and debate on the implications of such arrangements. This increased transparency might promote a fairer and more responsible gambling environment by discouraging monopolistic or unethical practices.
Ninthly, providing the requested information could enhance the credibility of the Gambling Commission as a regulator, demonstrating its commitment to openness and transparency. This would contribute to increased public trust and confidence in the Commission's ability to effectively regulate the gambling industry and protect consumers.
Tenthly, the release of information related to enforcement actions could provide valuable context and insights for researchers, academics, and policymakers, assisting them in identifying trends, patterns, and areas requiring further study or intervention. This information could, in turn, contribute to the development of more effective gambling policies and regulations, ultimately benefiting the public at large.
Eleventhly, the disclosure of information regarding licenses, permits, and enforcement actions could help the public make informed decisions when choosing to engage with a particular gambling establishment. This increased awareness might lead to better consumer choices and higher levels of satisfaction with the industry as a whole.
Twelfthly, by sharing information about the casino's management or ownership, it may promote a culture of accountability within the gambling sector. Operators may become more diligent in ensuring compliance with regulations and adopting best practices, knowing that the public and other stakeholders are aware of their identities and affiliations.
Thirteenthly, the release of information could contribute to the prevention of criminal activity and money laundering within the gambling industry. By increasing transparency, it becomes more difficult for unscrupulous individuals or groups to exploit the sector for illicit purposes, thereby safeguarding the integrity of the industry and protecting consumers.
Fourteenthly, providing the requested information may encourage more robust dialogue and engagement between the Gambling Commission, the public, and other stakeholders. This open exchange of information and ideas can lead to improved regulation, better policy development, and a more collaborative approach to tackling industry-wide issues.
Fifteenthly, the disclosure of information about the casino's management, ownership, licenses, permits, and enforcement actions might inspire confidence in investors and financial institutions. A transparent and well-regulated industry may be seen as a safer and more attractive investment opportunity, potentially leading to increased capital investment and economic growth within the gambling sector.
Sixteenthly, increased transparency could lead to a greater understanding of the gambling sector by the public, resulting in a more accurate perception of the industry's role and impact on society. This could help counteract any misinformation or misconceptions about the industry and foster a more informed public discourse on gambling-related matters.
Seventeenthly, the release of information may encourage other gambling operators to improve their practices and voluntarily adhere to higher standards, knowing that their competitors are being held accountable. This could create a positive cycle of continuous improvement within the industry, benefiting both consumers and operators.
Eighteenthly, the disclosure of information about the casino's management or ownership could contribute to the identification of potential conflicts of interest or unethical practices within the gambling sector. This increased scrutiny can help maintain the sector's integrity and protect the public interest.
Nineteenthly, increased transparency about licenses, permits, and enforcement actions may encourage better collaboration and cooperation between various stakeholders, such as local authorities, law enforcement agencies, and consumer protection groups. This collaboration can lead to more effective regulation and enforcement measures, ultimately benefiting the public.
Twentiethly, disclosing information about the casino's management, ownership, licenses, permits, and enforcement actions could lead to improved risk management within the gambling industry. As operators become more aware of potential risks and regulatory expectations, they may be more proactive in identifying, assessing, and mitigating potential risks, resulting in a safer gambling environment for consumers.
Twenty-Firstly, the release of the requested information may contribute to enhanced public debate and decision-making regarding gambling policies and regulations. A better-informed public, equipped with accurate information, can contribute to more balanced and effective policy discussions that take into account the interests of various stakeholders, including consumers, operators, and regulators.
Twenty-secondly, providing the requested information may lead to increased media scrutiny of the gambling sector, which in turn can help hold operators accountable for their actions and ensure compliance with regulations. This heightened level of scrutiny may also encourage a culture of continuous improvement within the industry.
Twenty-thirdly, the release of information about the casino's management, ownership, licenses, permits, and enforcement actions may help to deter criminal organizations from attempting to infiltrate or exploit the gambling sector. This could help maintain the industry's integrity and protect consumers from potential harm.
Twenty-fourthly, the disclosure of information may contribute to better corporate governance within the gambling industry, as operators become more aware of the need to comply with regulations and adopt best practices. This could lead to improved operational efficiency and financial performance for operators, benefiting both the industry and its customers.
Twenty-fifthly, by sharing information about the casino's management, ownership, licenses, permits, and enforcement actions, the Gambling Commission may be facilitating the development of a more responsible gambling environment. This could contribute to minimizing gambling-related harm and promoting responsible gambling behaviours among consumers, ultimately benefiting society as a whole.
Twenty-sixthly, the release of the requested information could contribute to increased accountability and public scrutiny of the casino's management and ownership. By disclosing information about the casino's operations, the public and other stakeholders can hold the casino's management accountable for upholding the licensing objectives and responsible practices.
Twenty-seventhly, the release of the requested information may contribute to the development of best practices within the gambling industry. By understanding the regulatory requirements and enforcement actions taken against operators, other establishments can learn from these examples and implement improved processes and procedures to ensure compliance and responsible gambling practices.
Twenty-eighthly, increased transparency can promote a greater understanding of the challenges faced by regulators, such as the Gambling Commission, in ensuring compliance with regulations and maintaining the integrity of the gambling industry. This understanding can foster empathy, support, and collaboration between the public, operators, and regulators, leading to a more effective regulatory environment.
Twenty-ninthly, the disclosure of information about the casino's management, ownership, licenses, permits, and enforcement actions may contribute to the identification and prevention of money laundering and other financial crimes within the gambling sector. By understanding the operations and compliance of gambling establishments, regulators and law enforcement can better focus their efforts to combat financial crime and protect the public interest.
Thirtiethly, by providing the requested information, the Gambling Commission may be empowering consumers to make more informed choices about their gambling activities. When consumers have access to information about the management, ownership, licenses, permits, and enforcement actions of gambling establishments, they can choose to patronize establishments that adhere to high standards and responsible practices, fostering a more responsible gambling environment overall.
Thirty-firstly, providing the requested information could foster greater public awareness of the challenges and complexities involved in regulating the gambling industry. By disclosing the details of the casino's management, ownership, licenses, permits, and enforcement actions, the public can better appreciate the difficulties faced by regulators and the importance of their work in protecting consumers and maintaining the integrity of the gambling industry.
I, therefore, request an internal review of the Gambling Commission's decision to withhold the requested information, taking into account these additional arguments. I understand that this review should be carried out within 40 working days of the receipt of this request.
If the outcome of the review maintains the exemption, I would appreciate a detailed explanation of the reasons for upholding the decision. Should I remain unsatisfied with the outcome, I am aware that I have the right to apply to the Information Commissioner's Office (ICO) for a decision.
Thank you for your attention to this matter.
I am writing further to your Freedom of Information request dated 02/03/2023, which we responded to on 22/03/2023, and your subsequent request for an internal review received on 22/03/2023. We have now concluded our review and our findings are detailed below.
This internal review was conducted by someone who was not involved in the processing of your original request.
Your request was for information regarding Grosvenor Casinos located at 84 Hill St, Birmingham B5 4AH, including, the operator's management or ownership, as well as any licenses, permits, or enforcement actions relevant to their operations.
In our response we were able to confirm that we do hold information that falls within the scope of your request. The Gambling Commission does make some information relating to individual licencees available on our website. Specifically, the publicly available licence details for Grosvenor Casinos located at 84 Hill St, Birmingham B5 4AH t can be viewed here:
Premises - Grosvenor Casinos (GC) Limited - Gambling Commission
Premises - Gambling Commission
However, it was our view that any other information we hold regarding this licensee was exempt from disclosure and the S31 – Law Enforcement exemption applied.
Gambling operators are required to hold a licence from the Commission in order to offer facilities for gambling to customers located in Great Britain. The Commission goes through a thorough licence application process as part of this and makes an assessment of suitability against criteria set out in the Act. Part 5 of the Gambling Act 2005 details the Commission’s statutory functions in relation to the licensing requirements.
The Licence conditions and codes of practice (LCCP) then set out the requirements all licensees must meet in order to hold a Gambling Commission licence.
Once licensed, gambling operators are subject to ongoing compliance requirements and are subject to regulatory action should they fail to meet their licence requirements.
Information collated as part of this process is used to assess whether a person or entity is fit to hold a licence
The Gambling Commission exists to safeguard players and the wider public by ensuring gambling is fair and safe. The ways in which we do this and policies & procedures the Commission adheres to in order to achieve these objectives are published on our website:
Section 31 of the Freedom of Information Act 2000 (FOIA) (Law Enforcement) provides that information held by a public body is exempt if its disclosure would, or would be likely to prejudice the exercise of a public body of its functions for any of the purposes specified in subsection (2):
Once licensed, gambling operators are subject to ongoing compliance requirements and are subject to regulatory action should they fail to meet their licence requirements.
Operators are aware of the level of information published on our website. They have no expectation that any further information will be released into the public domain.
As explained, we do not release information relating to individual operators as, we rely on the exchange of information throughout our licensing and compliance processes to ensure that we are able to thoroughly review our licence holders. To disclose this information, at this level of detail would impact on the relationship that we have with operators.
In our initial response we conducted a public interest test with regards to the application of this exemption, where we acknowledged that there is a public interest in the transparency of the Commission and its processes, and that by releasing this information it could demonstrate the work that the Commission carries out to fulfil its functions.
However, disclosure of this information could impact on the free and frank exchange of information between the Commission and gambling operators. The Commission does rely on information being provided from a variety of sources to enable us to carry out our regulatory functions. Some of this information is provided to us on a voluntary basis and is provided on the understanding that this will not be disclosed further. Disclosing this information could discourage operators from sharing information with us in the future which would impact on our regulatory functions and ultimately on consumers.
When weighing up the public interest test, we did take into account that it is important the public are provided with the necessary information to enable them to be confident with their choice of operator and be assured that the Commission has undertaken the necessary work to ensure that operators are compliant.
However, we did balance this with the overwhelming importance of the Commission relying on information being provided by operators and the likely detrimental impact on the work of the Commission if we were to lose trust with operators which would impact our ability to raise standards and ultimately protect the wider public interest.
Having taken these arguments into consideration, it was our view that the public interest in withholding this information outweighed the public interest in disclosure as there is more than a 50% chance that prejudice to the Commission would be caused by disclosure.
The Commission also takes the view that disclosure is likely to reduce the overall standards in the gambling industry because releasing this information would undermine our relationship with operators as the information that they provide to us as part of the application process (which can include commercially sensitive information) is done so on the understanding that this will not be released into the public domain. If this information was disclosed, it would damage the relationship that we have formed with operators which would result in them being less likely to share information with us in the future which would undermine our regulatory functions and, as a consequence, have a detrimental impact on the wider public.
Release of the information that we hold relating to Grosvenor Casinos, aside from what is already available on our website, will have a direct impact on our statutory functions, by undermining the processes that we have in place to determine the genuine suitability of licensees which will ultimately impact on consumers. The Commission considers that disclosure of the requested information would provide other operators with information that could be used to undermine and circumvent Commission processes and reduce the possibility of any non-compliance being detected. The Commission’s concern is that this would result in operators or individuals using the disclosed information to present information in a manner which would avoid further scrutiny or be targeted at the particular factors which those assessing compliance with the LCCP are considering for evidence of compliance with the published framework. By releasing this information into the public domain, the Commission will be in a position where it will not be able to rely on the current processes and would need to introduce further processes which have not been disclosed to ensure that our processes remain robust and fit for purpose in order for the Commission to perform its statutory functions.
The Commission also takes the view that disclosure is likely to reduce the overall standards in the gambling industry because operators are able to second guess or predict what specific matters will be subject to a more detailed assessment, the resources that will be devoted to it and the methodology the Commission will use and may therefore tailor their responses in a strategic manner which would deprive the Commission of information which would otherwise have been provided and which would be relevant to the Commission’s assessment process. The more information about how the Commission allocates its resources and the activities it is concerned with, added with information on how it goes about its assessment processes, the better able an unscrupulous organisation will be to make an accurate assessment of the likelihood of particular information coming to the attention of that regulator.
There is a strong public interest in preserving the processes that the Commission has in place to assess licences and identify any operators who will be unable to comply with the licensing requirements. The public trust that the Commission has robust processes in place to assess operators so that when they use the services provided by an operator, they are confident that there has been sufficient scrutiny of that operator to ensure that they are protected. If this information were released it would undermine that confidence.
There is an expectation of confidence in much of how the Commission carries out its statutory functions, particularly as regards information it asks for to not only ascertain if a licence should be granted but to monitor this and check compliance.
We recognise that there is a public interest in promoting accountability and transparency of the Commission. It is important that the public are assured that the Commission is carrying out its functions in ensuring that any individuals who are involved in providing gambling facilities to the public have undergone the necessary due diligence checks and will uphold the licencing objectives ensuring that consumers are protected.
The information that is publicly available on our website clearly sets out the required standards that remote operator licensees are expected to comply with, therefore, it is our view that there is sufficient information publicly available about the assessment process to adequately address the public interest in this matter.
Upon review, we do uphold our original decision to engage the S31 exemption when considering the impact upon the Commission’s ability to perform its regulatory functions.
If you are not content with the outcome of your review, you may apply directly to the Information Commissioner (ICO) for a decision. Generally, the ICO cannot make a decision unless you have exhausted the complaints procedure provided by the Gambling Commission. The ICO can be contacted at: The Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.