Risk Algorithms

Request

1. Following the Risk algorithms data study conducted in 2021, have you conducted any follow-up data gathering exercise up to this day? Please provide records relating to any such exercise. Please provide records, results, conclusions and policy implementations of any other study on “risk algorithms”.
2. Please provide records, results, conclusions and policy implementations of the “best practice study” referred to in this Placing data and insights at the heart of the Commission’s regulatory approach blogpost: “Marcus Boyle also outlined a best practice study into the use of algorithms, highlighting the need for openness and cooperation in an area which has in the past been too competitive and secretive.”
3. How many times has the Gambling Commission, in its compliance assessments since 1 October 2022, sought from operators “disclosure of how player risk models are developed, what proxies for harms are used, results of back-testing, methodologies utilised, and risk exposures for different product verticals and player categories” (as referenced in the blogpost cited in question 2)?

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 following information in relation to previous work on “risk algorithms” and “harm reduction algorithms”. Specifically:

1. Following the Risk algorithms data study conducted in 2021, have you conducted any follow-up data gathering exercise up to this day? Please provide records relating to any such exercise. Please provide records, results, conclusions and policy implementations of any other study on “risk algorithms”.
2. Please provide records, results, conclusions and policy implementations of the “best practice study” referred to in this Placing data and insights at the heart of the Commission’s regulatory approach blogpost: “Marcus Boyle also outlined a best practice study into the use of algorithms, highlighting the need for openness and cooperation in an area which has in the past been too competitive and secretive.”
3. How many times has the Gambling Commission, in its compliance assessments since 1 October 2022, sought from operators “disclosure of how player risk models are developed, what proxies for harms are used, results of back-testing, methodologies utilised, and risk exposures for different product verticals and player categories” (as referenced in the blogpost cited in question 2)?

The Gambling Commission can confirm as follows:

Question 1 and 2:

The Gambling Commission can confirm that our work on algorithms was paused, and therefore we have not conducted any follow-up data gathering exercise. Instead of resuming this work, the Commission took forward work in relation to customer interaction guidance, financial vulnerability checks, and the financial risk assessments pilot.

Please see the following webpages which may be of assistance:

Remote customer interaction - consultation on guidance document - The Gambling Commission - Citizen Space

Summer 2023 consultation – Proposed changes to LCCP and RTS: Consultation Response - Topic 4 - Financial vulnerability checks: Consultation Response and Financial risk assessments pilot: Consultation Response

Question 3:

The Commission holds no information falling within the scope of your request. However, the Commission can confirm that an integral part of any compliance assessment is to understand what controls are in place to meet customer interaction requirements. This will include understanding what controls are put in place to identify harm and to evaluate the effectiveness of those controls. This is a standard part of any assessment that covers safer gambling controls. The Commission have published numbers of full assessments conducted, and reviews of customer interaction processes will have been conducted for all of those assessments.

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 a new tab), Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.

Information Management Team
Gambling Commission