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The Responsible Gambling Strategy Board’s advice on the National Strategy to Reduce Gambling Harms 2019–2022

The Responsible Gambling Strategy Board’s advice on the National Strategy to Reduce Gambling Harms 2019–2022


Good policy is underpinned by sound evidence. That in turn requires good data, a sizeable, consistent and reliable flow of funding and a large enough pool of researchers able and willing to respond to invitations to tender for commissioned research, or prepared to identify useful research topics on their own initiative.

The present arrangements, though considerably improved over the last few years, fall short in all three respects:

  • much more data is available, but often only in response to ad hoc requests which frequently encounter difficulties because of concerns about confidentiality, data protection or other issues. Sorting that out afresh on each occasion takes time and introduces an unnecessary inhibition on potentially useful research
  • the majority of funding for commissioned research is either supplied voluntarily by the industry or becomes available through regulatory settlements. The latter are, by their nature, unpredictable and irregular
  • there is resistance on the part of some potential researchers to accepting funds voluntarily provided by the industry and routed through GambleAware because of concerns that the source of funding may present conflicts of interest and compromise the integrity of the research. Steps have been taken to establish more transparent governance arrangements and to make clear that there is no industry involvement in the published research programme. There has, in consequence been some limited success in widening the pool of potential researchers. But there is still some way to go.

In addition, the current arrangements for delivering research directly underpinning the national strategy involve an unnecessary two-step process which requires GambleAware to commission and manage projects on behalf of the Gambling Commission (which writes the research briefs and sets the research questions with advice from the Responsible Gambling Strategy Board).

We believe these arrangements need to change. It is unusual for a statutory regulator to rely on a charity to carry out research commissioning on its behalf. Dividing responsibilities between three different bodies creates inefficiencies which can delay the pace of progress and an additional tier of decision making is created by GambleAware’s Research Committee.

In our view the new strategy should require:

  • a change of responsibilities. The Gambling Commission should take responsibility for directly commissioning the research necessary to underpin the strategy, rather than doing so via a third party (GambleAware), and resource itself accordingly. The commissioning of other research relevant to gambling should be undertaken by arms-length bodies, such as the National Institute for Health Research (NIHR) and the Economic and Social Research Council (ESRC)
  • a repository of regularly updated anonymised data, accessible to UK and international researchers under agreed governance arrangements, covering, for example, information on staking patterns, frequency of play and levels of losses. Some work is already in hand on how best to achieve this68
  • better arrangements for collating research, promulgating the findings and assessing the implications for policy and practice.


68 Research is being carried out on patterns of play (opens in a new tab) which will provide recommendations on the data which could be made available in such a repository

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