Legal Services Framework Agreement

Request

I would be most grateful if you would provide me, under the Freedom of Information Act, details in respect to the contract below.

Legal Services Framework Agreement (2022):

https://eur03.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.contractsfinder.service.gov.uk%2FNotice%2Fa1c98337-2807-46d8-a1c1-ccdd82c142a8&data=05%7C02%7Cfoi%40gamblingcommission.gov.uk%7C1578139f58054b2cd0b708dedc313582%7C7dddff921de64835996384e7cc44cea2%7C0%7C0%7C639190301221151230%7CUnknown%7CTWFpbGZsb3d8eyJFbXB0eU1hcGkiOnRydWUsIlYiOiIwLjAuMDAwMCIsIlAiOiJXaW4zMiIsIkFOIjoiTWFpbCIsIldUIjoyfQ%3D%3D%7C80000%7C%7C%7C&sdata=%2BVyd4Id%2B%2FHPtsp912jgUWrwTwGFRWn1H6MDVoP%2FFZm8%3D&reserved=0

The details we require are:

1. What are the contractual performance KPI's for this contract?

2. Suppliers who applied for inclusion on this framework and were not successful at the PQQ & ITT stages

3. Actual spend on this framework (and any sub lots), from the start of the contract to the current date, including a split of spend per supplier

4. Could you please provide a copy of the service/product specification given to all bidders for when this contract was last advertised?

5. Is there an extension clause in the framework and, if so, the duration of the extension?

6. Has a decision been made yet on whether the framework is being either extended or renewed?

7. Who is the senior officer (outside of procurement)responsible for this contract?

Response

Re: Gambling Commission response to your request

1. Thank you for your request, dated 7th July 2026, which has been processed under the Freedom of Information Act 2000 (FOIA).

2. In your email, you have requested information in relation to our Legal Services Framework Agreement 2022.

3. The Gambling Commission (the Commission) response to your request is set out below.

Question 1: What are the contractual performance KPIs for this contract?

4. No information is held falling within the scope of this part of your request. Key Performance Indictors (KPIs) were not included in the contract.

Question 2: Suppliers who applied for inclusion on this framework and were not successful at the PQQ & ITT stages.

5. 10 formal submissions were received by the Commission.

6. The information as to the unsuccessful applicants is considered to be commercially sensitive and is exempt under section 43(2) of the FOIA.

7. Section 43(2) applies to information the disclosure of which would, or would be likely to, prejudice the commercial interests of any legal person (an individual, a company, the public authority itself or any other legal entity). A commercial interest relates to a legal person’s ability to participate competitively in a commercial activity.

8. The information requested was generated through the application process relating to the framework agreement. Disclosure of the requested information identifies those unsuccessful bidders in the process which if disclosed could impact on the future commercial activity of the applicants as unsuccessful bidders and is information which could be used by competitors in the future for their own advantage and the disadvantage of the unsuccessful bidders.

9. In addition, the disclosure of this information could negatively impact the Commission’s future ability to attract a wide range of suppliers into such processes. As such the disclosure of this information would be likely to prejudice the commercial interests of the applicants and the Commission.

10. This exemption is a qualified one and the Commission has considered whether the public interest in disclosing this information is outweighed by the public interest in protecting the commercial interests and withholding the information.

11. In this case, the Commission considers that the public interest favours maintaining the exemption and withholding the information. In coming to this decision, the Commission has considered the factors in favour of disclosure.

12. 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. There is a legitimate public interest in members of the public having confidence the Commission is being open and honest with the data it holds so that it can be held to account. Further, this disclosure may encourage stakeholders to work with us and contribute to our programme of work, increasing confidence in the Commission as a regulator and its ability to uphold the law.

13. However, the Commission considers that publishing specific details of unsuccessful applicants does not contribute to the overall understanding of the framework agreement. Disclosing the information could discourage the broadest range of applications for any future framework agreements which would likely prejudice the Commission’s ability to have confidence in the strength of the competition and rely on the competitive process to ensure that its service provision can effectively assist the Commission in carrying out its functions to monitor and regulate the gambling industry.

14. Looking at all the circumstances of the case and the nature of the request, there is more than a 50% chance that prejudice would be likely to be caused to one or more of the parties by disclosure.

Question 3: Actual spend on this framework (and any sub lots), from the start of the contract to the current date, including a split of spend per supplier

15. Please see below breakdown of total spend relating to each supplier on the contract between 14 February 2023 -28 February 2026, which represents the length of the contract relating to this framework.

16. Seven suppliers, listed below in no particular order, invoiced the Commission over this period, as follows:

• Supplier One - total £620,443
• Supplier Two - total £251,802
• Supplier Three - total £740,100
• Supplier Four - total £134,945
• Supplier Five - total £448,060
• Supplier Six - total £6,208,217
• Supplier Seven - total £6,026

17. This figure includes invoices received during this period – this does not include invoices submitted outside of the contract expiry date and which could be attributed to other contracts.

Question 4: Could you please provide a copy of the service/product specification given to all bidders for when this contract was last advertised?

18. Please see the attachment containing information falling within the scope of your request.

Question 5. Is there an extension clause in the framework and, if so, the duration of the extension?

19. Please see the attachment containing information falling within the scope of your request.

Question 6. Has a decision been made yet on whether the framework is being either extended or renewed?

20. I confirm that Lots 1 and 3 were not extended. Lot 2 was extended until 13 Feb 2027.

21. I confirm that information is held in relation to this part of the request but is exempt from disclosure under section 40(2) of the FOIA (personal data).

Question 7: Who is the senior officer (outside of procurement) responsible for this contract?

22. The Data Protection Act 2018 requires personal data to be processed lawfully, fairly and in a transparent manner in relation to the data subject. It is the view of the Commission that disclosing the personal information of the senior officer responsible for this contract would constitute the disclosure of personal data and would contravene this principle as the individual is not a senior public facing role, and the disclosure of their name in relation to this contract could subject the individual to unwarranted disruption from their day-to-day work. Disclosure of their name in this context is therefore not considered fair.

List enclosure here: • Attachment 2 - 022 - Scope of Services (v1)_Redacted

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

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