Unauthorised account openings
Request
In accordance with the Freedom of Information Act, I request disclosure of any statistics you may have gathered about:
i) unauthorised account openings, and
ii) systematic bypassing of Gambling Commission terms and conditions by the absence of any ID verification process, and
iii) any report of audit carried out on Bet365Group of its account opening process and verification, or the relevant Gambling Commission terms and conditions relating to account opening checks
Response
Thank you for your request which has been processed under the Freedom of Information Act 2000 (FOIA).
In your email you have requested disclosure of any statistics you may have gathered about:
i. unauthorised account openings, and
ii. systematic bypassing of Gambling Commission terms and conditions by the absence of any ID verification process, and
iii. any report of audit carried out on Bet365 Group of its account opening process and verification, or the relevant Gambling Commission terms and conditions relating to account opening checks.
Parts one and two of your request have been interpreted as being for information about the gambling industry as a whole. Our role is to consider if a gambling business has breached their licence conditions, and we will take regulatory action where appropriate. We use evidence from a range of places, including from gambling customers, to build cases against gambling businesses. Information provided to us helps inform our work to raise gambling industry standards and make gambling fairer and safer.
As such, whilst I can confirm that the Gambling Commission does hold information falling within the scope of your request, this information is not stored in an extractable format. We would be required to review large volumes of information, stored across several areas of the Commission to fulfil your request.
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.
The information that you have requested is not held in one central location. We estimate, in order to identify, locate and retrieve the information relating to the above request, 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.
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:
If you are able to refine your request, we may be able to narrow the number of records that we need to search.
Until we are able to process the search of the information you have requested, we are unable to ascertain if other exemptions will apply to any material identified which would also prevent disclosure. For example, S31 – Law Enforcement provides an exemption for information that the Commission holds where disclosure would reveal the methods and techniques the Commission uses as part of the assessment process. Disclosure of this information could seriously impact the Commission’s regulatory activities; this is strongly not in the public interest.
Please note, any refined request would be processed as a new request and the 20 working day statutory time limit would apply.
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