GambleAware Annual Conference - Tim Miller Speech
04 December 2024Speech by Tim Miller
This speech was delivered by executive director Tim Miller at the GambleAware Annual Conference on 4 December 2024.
Please note: This is the speech as drafted and may slightly differ from the delivered version.
Hello everyone and thank you for that introduction. The topic for this final part of the conference is ‘Building the best possible new system’. Now, as the gambling regulator, our statutory role does not give us the expertise to speak with authority on the design of treatment and support systems - so I will not do that this afternoon. However, when we established the National Strategy to Reduce Gambling Harms back in 2019 we deliberately sought to take a system-wide approach. So I hope that some of the reflections that I have today, drawing upon those experiences during and after the National Strategy, may provide food for thought for those that will be leading the design of the new system under a statutory levy. And the two areas I want to focus upon today are collaboration and evidence.
If you produced a word cloud of all of my recent speeches, I suspect that the word ‘collaboration’ would be right at the centre in a very large font. That is not accidental - the Gambling Commission is committed to a collaborative approach wherever possible. With operators to raise standards; with our fellow regulators both at home and abroad; and with others whose work can help make gambling safer, fairer and crime free.
And for that reason we also are really supportive of the theme GambleAware picked for today’s Conference. As we continue to move from the voluntary funded, treatment and prevention systems we have today towards a system funded by the Statutory Levy, a commitment to working together will remain important. And that should include working with the widest range of voices, including all of those with the knowledge and insights; skills and experience that will be needed to make the future system a success.
The National Strategy was successful in shifting the landscape from what was often a quite disparate and, at times, unhealthily competitive environment towards one where there was a greater willingness to engage with different voices. It was, for example, during the life of the National Strategy that we really saw the voice of lived experience become much more embedded in many organisations.
However, as we have got closer to a statutory levy becoming a reality, it has sometimes felt that attempts to exclude certain voices have grown. Our experiences from the National Strategy would suggest that such an approach would be a mistake.
We must continue to hear the voices of those with lived experience of harm and remember that those experiences are varied and highly individual for different people. We have spent significant time listening to people that have experienced harm, and affected others, through our Lived Experience Advisory Panel and in other environments. What is clear is that no one person, no single group can reflect the diverse range of lived experiences. So it will be important for the future system to take an inclusive approach to hearing such voices.
We must also ensure we hear the voices of all consumers, including those that are gambling without experiencing harm. If the future system wants to genuinely take a preventative approach then understanding why many people do not experience harm, and where appropriate seeking to replicate that experience, is an equally important part of preventing harm. Some of the most effective insights on how gambling can be safer could actually come from those that have not experienced harm.
We must ensure that we hear the voices of those working in existing services. Whilst many have rightly pointed to some of the gaps and limitations in the current system I have also regularly heard from people who have been greatly helped by existing services or who currently rely upon such services. It is clear, just from looking around the room today, that there is a tremendous amount of passion, skill and experience within the services that are currently being offered. Whatever future structures and systems look like, being able to draw upon many of those whose work is already making a difference seems really key to the success of whatever comes next.
And finally we must also hear relevant voices from within industry. Now, do not misinterpret what I am saying here - industry should not be in a position to make decisions about how treatment and support services are designed. Equally, research should be demonstrably independent in how it is commissioned and operated. People need to be confident that the levy system works in a way that is not influenced by commercial considerations. However, that does not mean that industry has nothing of value to add.
As is the case in financial services, our regulations increasingly require operators to ‘Know Your Customer’ for both social responsibility and anti-money laundering purposes. If we consider there is value in gambling companies building up such a knowledge base on consumers for harm prevention purposes then why would we want to exclude that knowledge from informing a wider system that has harm prevention as a core aim?
Done in the right way, with transparency and openness, including the broadest range of voices does not need to compromise the independence of the system. Instead it helps to ensure that everyone is pulling in the same direction and that decisions are taken on the basis of the best possible evidence base. Which brings me to my second area of focus.
At the Gambling Commission we are clear that better evidence leads to better decisions and better decisions will lead to better outcomes. And from developing and improving our official statistics through to working collaboratively across the landscape to minimise the gaps in the evidence base more widely, this is an area we have made real strides in the last 12 months and are looking to achieve even more in the year ahead.
It was for this reason, in the Summer of 2023 that we launched our Evidence Gaps and Priorities programme. The programme set out six key themes where we wanted to make a concerted effort to strengthen the evidence base. They are:
early gambling experiences and gateway products
the range and variability of gambling experiences
gambling-related harms and vulnerability
the impact of operator practices
product characteristics and risk
illegal gambling and crime.
The programme is not just about laying out areas where the Commission will look to make progress though. It is designed to highlight to others where we as the regulator see real benefit in new research being carried out. I hope that this programme will play an important role in helping to shape the research carried out under the forthcoming levy.
I also wanted to highlight the massive amount of work that has gone into developing and launching our new Official Statistics for Participation and Prevalence – the Gambling Survey for Great Britain (GSGB). It has been years of work, it is the largest survey of its kind in the world and it is already giving us a wealth and depth of data that we have never had before. There is, of course, more work to do to strengthen our approach but we are confident that we have in place a methodology that will help us to track trends in gambling behaviour in the years to come.
Importantly we have also sought to be transparent in the development of the GSGB over the years, on the potential limitations of the methodology as well as its strengths. Because we recognise that no one number can be conclusive. No single data set will give you the whole picture. That is why for us Official Statistics are important but are just one part of the evidential jigsaw.
One of the strengths of the National Strategy was that it drew in a much wider evidence base than we had previously seen. Whether helping to formalise the evidence that comes from lived experience of harms, whether encouraging the financial services industry to share their data alongside that from the gambling industry, whether bringing in new research techniques such as the real-world testing used by the Behavioural Insights Team. All of these have helped to improve our knowledge of the problems we are trying to fix and our understanding of what works.
So it will be essential that the future system is able to draw upon the widest possible evidence base and research techniques when making decisions. That system will also need to ensure that evidence is used in a way that is robust, credible and transparent.
Challenging the misuse of official statistics is sadly taking up more and more of our time. Our recently published data on children and young people was a prime example of that, where much of the coverage fell pretty wide of the mark.
Sometimes the misuse is an accidental but well-intentioned act. A genuine attempt to write in an accessible way that ends up oversimplifying a necessarily complex and nuanced picture.
Sometimes it occurs due to a lack of care. An attention-grabbing headline that does not properly reflect the content of an otherwise well considered article.
Other times it would appear to be a more deliberate misuse of data - where perhaps a strongly held belief is being cloaked in the selective use of the evidence base.
Whatever the reason, it is vital that all of us are fastidious in the way we use evidence. That means using accurate definitions; it means not selectively picking and choosing data that supports a desired outcome; it means being open about where decisions are still needed to be taken despite evidence that may be inconclusive - what we would call the precautionary principle.
And so the lesson for a statutory levy funded world is that there can be no place for the misuse of data and evidence in a system that wants to deliver services and insights that will actually meet needs and that work in practice.
Building the best possible new system will be challenging. There will likely be some false starts and some missteps. But if the system is built on a strong foundation of robust evidence and seeks to encourage the widest possible collaboration then the challenges faced can be easily overcome. I for one am excited to see what comes next!
Thank you.
Last updated: 4 December 2024
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