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ABSG Progress Report on the National Strategy to Reduce Gambling Harms - Year 3

ABSG - Year three Progress Report on the National Strategy to Reduce Gambling Harms

Published: 12 May 2022

Last updated: 12 May 2022

This version was printed or saved on: 3 December 2022

Online version: https://www.gamblingcommission.gov.uk/report/absg-progress-report-on-the-national-strategy-to-reduce-gambling-harms-year-3

Executive summary

Executive summary and key findings

In April 2019, the Commission-led three-year National Strategy to Reduce Gambling Harms was widely welcomed for strengthening its focus on population health, collaboration and placing the voice of consumers at its centre. Efforts towards better coordination and collaboration have brought benefits, including greater awareness of the need to diversify activities and approaches to prevention, treatment and research.

The National Strategy created a call to action that gave rise to over 400 actions by more than 40 stakeholder projects on gambling related harms. This progress report provides an opportunity to consider the National Strategy’s overall achievements and remaining challenges. Going further depends upon resolving barriers of funding, quality assurance and evaluation.

Key findings on progress over the lifetime of the National Strategy

Key achievements

Remaining gaps

Headline achievements and ABSG recommendations

Since our last progress report, the third year of the National Strategy has seen:

ABSG Recommendations

In August 2021, the Commission noted its continuing support for the priorities set out in the National Strategy beyond 2022. Strong coordination and collaboration will be required to carry this work forward to ensure the momentum created by the National Strategy is not lost. This must include decisions about future funding models and use of regulatory settlements. Recommendations are set out for regulatory actions and actions by other agencies and organisations, including increased resources for enforcement action and greater transparency and data sharing, population level actions and earlier interventions to reduce harms and improve access to treatment and support.

All recommendations are underpinned by the need for government leadership towards an integrated prevention and treatment system involving those with lived experience alongside healthcare, local authorities and third sector, independent research and evaluation, and an end to funding from voluntary contributions.

Part 1: Introduction

National Strategy to Reduce Gambling Harms - Overview

The National Strategy was published in April 2019 as a vehicle for collaboration to reduce gambling harms. The Strategy had two strategic priorities:

The National Strategy set out four enabling themes that were required to make progress on these priorities:

The Gambling Commission asked ABSG to take responsibility to provide the Commission with an annual independent report on its progress. The purpose of the ABSG progress report is to:

This report provides an opportunity to review the last year of the National Strategy, as well as the overall achievements since its launch in 2019. Looking at the overall impact provides the best opportunity to consider how its legacy can be sustained and built upon.

ABSG’s previous progress reports can be accessed by the following links:

The Gambling Commission collected and published progress updates from the partners involved in delivery of the National Strategy. These updates were published in an Action Map.

Part 2: Key Achievements and areas for further progress

Year 3 Key Event Timeline 2021/22

Notable developments in the delivery of the National Strategy are outlined as follows:

Key milestones – 2021/22

Key actions – 2021/22
Month Action Enabling Action
April Fast Forward expands education programme (opens in a new tab) to England and Wales Collaboration
April Affordability and customer interaction information (opens in a new tab) published as guidance for local authorities Regulation
April User consultation on National Survey of Health and Wellbeing (opens in a new tab) Research
May Evaluation published of the Gambling Support Service (opens in a new tab) Evaluation
July Research published by Behavioural Insights Team on design of safer gambling management tools (opens in a new tab) Research
August GambleAware publishes its strategy for 2021-26 – recognising the need for a levy and greater NHS leadership on treatment (opens in a new tab) Collaboration
September Glasgow Summit (opens in a new tab) brings together people with lived experience, government, local councils and other agencies to share learning on how to reduce harm Collaboration
September Gambling with Lives launches education programme in schools (opens in a new tab) Collaboration
October Howard League publishes ‘State of Play’ report on links between problem gambling and crime (opens in a new tab) Research
October Natcen and University of Glasgow appointed by the Gambling Commission to develop new methodology for collection of participation and prevalence data (opens in a new tab) Research
October Update from the Information Commissioners Office ‘Sandbox’ establishes the legal basis for testing a Single Customer View Regulation
November New guidance on gambling marketing and advertising (opens in a new tab) came into effect from the Advertising Standards Authority Regulation
November IFF, GamCare and University of Bristol receive grant to improve understanding of women’s lived experience of gambling harms (opens in a new tab) Research
November Publication of evaluation of credit card ban Evaluation
December Gambling Commission publishes annual enforcement report (opens in a new tab) setting out lessons learnt and case studies Regulation
January Research on harms experienced by women and launch of awareness campaign aiming to reduce stigma (opens in a new tab) Research
January Gambling Commission consultation covering dual regulation (opens in a new tab) Regulation
February Enforcement action taken by Gambling Commission and law enforcement partners against illegal online lotteries (opens in a new tab) Regulation
February NHS announces it will open gambling treatment clinics in Southampton and Stoke-on Trent (opens in a new tab) Collaboration

Key achievements over the lifetime of the National Strategy

This section looks back at the key achievements of the National Strategy since its publication in April 2019. Progress on the National Strategy’s prevention and treatment objectives are reviewed through the lens of the National Strategy’s ‘Enabling Themes’. In this section, we also highlight where further progress is required.

Strategic Objective: Prevention and Education – 2019/2022

Enabling Action – Regulation and Oversight

Summary

There are stronger regulations to address risk of harms, but repeated failures of industry compliance with current regulations continue.

Strengths

Progress has been made in relation to affordability, vulnerability and consumer interaction (opens in a new tab). The Gambling Commission’s proposals for more specific requirements on operators reflect repeated failures by the industry to conduct adequate Know Your Customer (KYC) and affordability checks, even when very large amounts of money were being spent.

The Commission has continued to increase its focus on compliance and enforcement. Its annual Compliance and Enforcement Report showed a record total of £32million in financial penalties had been paid by operators, and increased action had been taken on personal licence holders. The report shares lessons learnt through case studies. The system of regulatory settlements has directed resources towards activity to reduce gambling harms – further accelerating progress and collaboration between partners.

The Commission banned the use of credit cards from April 2020, designed to reduce risks to consumers of spending unaffordable amounts of money.

Regulatory controls have also been strengthened in relation to schemes for high value customers (i.e. those that lose the most money) and online game design.

The legal basis for progressing work on a Single Customer View (SCV) was set out in a report from the Information Commissioners Office (ICO) which confirmed customer data could be lawfully used in such a scheme The Advertising Standards Agency (ASA) has introduced additional restrictions on gambling marketing and advertising (opens in a new tab) – most recently introducing guidance covering how skill, community and risk is presented to consumers.

Research using banking data (opens in a new tab) has demonstrated that harm can be experienced by a wider range of consumers than just those spending the highest amounts or gambling most frequently. This points to the importance of implementing a SCV to protect all of these customers as well as those at the extreme end of expenditure.

Areas for further progress

The Commission has made limited progress identifying metrics to measure the impact and effectiveness of its regulation. There continues to be a lack of data and metrics to measure the overall impact of the National Strategy towards reducing gambling harms.1

The Commission’s 2021 Compliance and Enforcement Report demonstrates the same failures repeated by the industry. These often related to not carrying out appropriate affordability checks. Re-occurring patterns of non-compliance show the industry is slow to learn lessons and put protecting customers before commercial incentives. It is critical that new initiatives such as affordability checks and the development of a ‘Single Customer View’ (SCV) provide meaningful protections for consumers and data is not mis-used for commercial benefit.

There is a gap in suicide prevention activity in regulation and access to data from the gambling industry.

There have been positive examples of regulatory collaboration from the Gambling Commission with other bodies, such as the ICO. The recent Bet Index case and independent review, however, highlighted the need for continued improvement in regulatory partnership working. The Commission’s consultation on dual regulation (opens in a new tab) addresses some of the outstanding issues but further collaborative work is needed to improve consumer safety. This includes Government action on strengthening consumer protection on sports based products which share some characteristics of gambling such as synthetic shares and non-fungible tokens and use of cryptocurrency which fall outside of the Commission’s remit.

There has been limited progress by the Commission on the use of data to encourage improved compliance by operators. We welcome the new work exploring how data driven approaches can be used to drive up standards and achieve better rates of compliance (opens in a new tab).

Enabling Action: Collaboration

Summary

There has been a cultural shift towards wider collaboration enabled by funds from regulatory settlements and the start of efforts in embedding multi-agency population health approaches to preventing harms. However, national-level co-ordination requires Government-level leadership in the three GB nations.

Strengths

Public Health England’s Gambling Harms Review (opens in a new tab) in 2021 has created an opportunity for greater involvement from government agencies and third sector. This is a significant indicator of the progress made towards establishing gambling harms as a population health issue. The Office for Health Improvement and Disparities (OHID) (opens in a new tab) will be a key partner in activity to reduce gambling harms.

Delivery groups have been established to co-ordinate activity in Scotland and Wales. Strategy Implementation Group for Scotland and the Strategy Implementation Group for Wales bring together local and national government, public health, health and social care oversight and service commissioners.

The number of financial institutions offering blocking tools and support has increased. The Money and Mental Health Policy Institute has helped promote best practice – if adopted, this should improve consistency of activity across this sector. There has been significant new investment in Citizen’s Advice who are providing debt advisors with training to help identify and support those experiencing harms from their gambling.

Whole systems approaches to gambling harms prevention have been launched in Greater Manchester, Glasgow and Yorkshire and Humber. This has created an opportunity to build on the critical role played by local agencies in local communities through prevention activities. For example, in Manchester this has encompassed initiatives with football clubs, social clubs, embedding gambling within the Greater Manchester Suicide Alliance and Greater Manchester Police and crime plan (opens in a new tab). These all work towards moving the narrative from an individual to a population level. It reflects the community-based approaches common in addressing issues such as domestic abuse, alcohol addiction and social exclusion.

The Glasgow Summit (opens in a new tab) shared learning on how local agencies can tackle gambling harms, aiming to mainstream prevention work at local authority level, address stigma, and improve data coordination.

The Gambling Commission has created a forum for local authorities to share best practice – such as activity in Leeds, Sheffield and Birmingham to approach gambling harms in a similar way to that taken for drug and alcohol addiction.

The trade union, Unite, signed a Workplace Charter (opens in a new tab) incorporating ‘Bet You Can Help’ to support employers to reduce gambling harms in the workplace.

GambleAware launched a high-profile campaign highlighting the risks of gambling harms to women. The campaign uses insights from research which suggested over a million women are at risk of gambling harms (opens in a new tab) and stigma is a major barrier to accessing support (opens in a new tab).

Areas for further progress

There is still no strategic co-ordination group for activity in England. As gambling harms are increasingly accepted as a public health issue by all stakeholders, this should create the impetus for more government-level leadership with relevant government departments.

Suicide prevention requires a joined-up approach between agencies. At present, gambling is not recognised as a risk factor in national suicide prevention strategies. In Scotland, a new National Suicide Prevention Strategy (opens in a new tab) is being developed which creates an opportunity to address this. Similar action is needed in England and Wales. There are opportunities to make significant progress, for example by ensuring improved awareness and integration with NHS mental health services and other third sector organisations focused on suicide prevention.

There has been a significant increase in collaboration led by people with lived experience – this creates strong foundations to build on – including:

Progress is still needed to include gambling in the Public Health Outcomes Framework for England (opens in a new tab) and equivalent local data collection systems in Scotland and Wales. This is vital to ensure local authorities can identify and prioritise reducing gambling harms in local action plans as they do for other addictions.

Expansion of existing collaboration between financial institutions on sharing best practice on protecting consumers, agreeing minimum standards for early intervention across the sector.

Enabling Action: Evaluation

Summary

There is still an underdeveloped independent evidence base on what works in harm prevention. This applies to activities delivered by the industry, and to other prevention initiatives, such as education programmes and awareness campaigns. The voluntary funding system is a barrier to progress.

Strengths

An interim evaluation has been published on the impact of the Commission’s ban on use of credit cards. Results suggest the credit card ban had helped consumers gamble within their means and had not resulted in an increase in borrowing or illegal money lending.

An interim evaluation of TalkBanStop (opens in a new tab) suggests positive outcomes arising from the collaboration between GamCare, GamBan and GamStop, to raise awareness and provide clients with multiple tools and support.

The Commission published an ‘evaluation protocol’ and the Gambling Research Exchange Ontario (GREO) developed an ‘Evaluation Hub’ and created other resources to support evaluation activity.

Areas for further progress

The National Strategy’s Action Map contains very few complete independent evaluations. Reliance on a voluntary system of funding for research and limited access to data limits opportunities for independent evaluation of harm prevention activity. This means there is still a significant gap in knowledge about what works – particularly in relation to industry-led activity to prevent harm in its customers.

Utilising well established UKRC research governance, oversight and management processes to ensure independence and rigour would help to address this Evaluation of industry activity, such as ‘When the Fun Stops Stop’ has lacked independence and meaningful results on impact.2

The latest wave of the evaluation of GambleAware’s ‘BetRegret’ (opens in a new tab) campaign was published. Its results to date were inconclusive on the campaigns impact on people’s behaviour and levels of self-awareness.

Enabling Action: Research to inform action

Summary

Voluntary funding by industry continues to be the main source of funding for research. We recommend that this situation should not continue. Several independent studies have been delivered to improve collective understanding, but more are needed to create a robust evidence base.

Strengths

Public Health England published its Gambling Harms Review (opens in a new tab), bringing together a comprehensive review of current evidence. The Review estimated there are around 400 suicides related to gambling each year in Great Britain. Acknowledging the potential scale of this problem should act as a significant catalyst towards action.

The Commission is a member of NHS England’s Digital’s steering group overseeing the development of the National Study of Health and Wellbeing (opens in a new tab) (Formerly the Adult Psychiatric Morbidity Survey (APMS)). Inclusion of questions on gambling will provide new insights into links between gambling and suicide ideation and suicide, data that has not been collected since 2014.

The Commission appointed Natcen and the University of Glasgow to develop a new methodology for collecting data on participation in gambling and prevalence of problem gambling and incidence of gambling harms. This aims to achieve a more robust national dataset for official statistics.

The Howard League published their ‘State of Play’ report (opens in a new tab), emphasising the need for greater investment in awareness raising of gambling harms and diversion away from the criminal justice system where-ever possible through early identification and intervention.

A research collaboration between LAB Group and City, University of London is developing ways to identify consumers before their gambling becomes harmful. This highlights the potential of new technology (opens in a new tab) such as kinetic analysis and comparative linguistic analysis to use a range of gambling play data and other behavioural data to reduce harms.

GREO has provided a range of support to the National Strategy including a knowledge exchange hub (opens in a new tab) to synthesis research findings around policy themes such as patterns of play, measuring harms and industry-based interventions and the impact of advertising.

Research has been piloted to collect data on gambling harms. This builds upon earlier publication of a framework to measure gambling harms. Other collaborative research (opens in a new tab) is helping collect data on gambling harms and support early identification in the community.

Areas for further progress

There is little evidence that operators are applying findings from key independent research. For example, the Behavioural Insights Team (BIT) published research on ‘anchoring prompts’ which found that removing very high values in ‘drop boxes’ avoided consumers being nudged to deposit more money (opens in a new tab). Despite this finding from a randomised control trial, this practice is still widely used by operators. Regulatory controls appear necessary for this good practice to be adopted across the industry.

The system of voluntary funding still limits progress with independent research on gambling harms and solutions.3 This includes a lack of longitudinal research on the development of gambling harms in Great Britain and the characteristics of gambling products which can lead to harms.

GambleAware commence a commissioning process to award a £4million grant to establish a specialist Academic Research Hub (opens in a new tab) in gambling harms. GambleAware are also making further funds available to progress research on gambling harms experienced in different ethnic and cultural communities (opens in a new tab). These are initiatives which boost the research funding available, whilst leaving research funding dependent on voluntary funding from the gambling industry (opens in a new tab). This funding approach is out of step with protocols for other population health harms prevention and should not be sustained in gambling harms prevention.

The growth of online products like lootboxes and cryptocurrency trading has become a cause for concern. These products legally fall outside the Commission’s remit. Research and monitoring are needed to ensure the risks associated with these products are understood. Responsibility for this area of consumer protection needs to be allocated by Government to a body with appropriate funding and powers to address risks.

Strategic Objective: Treatment and Support (2019 – 2022)

Enabling Action: Regulation and oversight

Summary

The voluntary system of funding is a significant barrier to progress, limiting delivery, collaboration and appropriate quality assurance of treatment and support services. The treatment system requires a government-led strategy for a collaborative infrastructure in common with other addictions services.

Strengths

Development of National Institute of Clinical Excellence (NICE) guidelines (opens in a new tab) guidelines are in progress – albeit with publication of outputs not expected until 2024. This should provide a new framework for the identification, diagnosis and treatment of gambling harms across NHS bodies and third sector providers.

Transparency of funding arrangements is improving - for example through the published list of providers eligible to receive RET funding and GambleAware’s annual account of financial contributions.

There are a growing number of partners offering treatment and support in healthcare and community settings. Since 2019, NHS treatment clinics have grown from one to seven in England (opens in a new tab), including one dedicated to children and young people. Services offered by people with lived experience, primary care, third sector services and local authority services have also expanded, offering a wider range of community-based services to young people, women, family members, those from diverse ethnic communities, military personnel, those in custody. These are positive foundations to build upon, supported by appropriate oversight and resourced by sustainable and independent funding.

Areas for further progress

The reach of treatment and support services, whether healthcare or community-based, remains limited by inadequate resources and is patchy across Great Britain. There is a need to establish leadership by NHS bodies for governance and oversight of treatment services in collaboration with third sector organisations – and for accountability to rest with statutory bodies in the three nations. The Gambling Act Review (opens in a new tab) does not specifically cover treatment in its scope, but the review creates an opportunity for this gap to be addressed. The voluntary system of funding for treatment remains a significant barrier.

The timeframe for completion of NICE guidelines means that a lack of evidence-based treatment protocols will persist for several years. In the short-term, there is a lack of consensus between treatment providers on the most suitable referral pathways to meet needs. Clear and collaborative plans are required to co-ordinate expanding NHS provision with services provided by the third sector. This framework also needs to recognise the need for support for people affected by someone else’s gambling.

There is a lack of independent oversight of the quality of treatment services delivered by third sector organisations funded by GambleAware. Although a role for the CQC (opens in a new tab) is being explored, this is yet to come to fruition leaving a significant gap in quality assurance.

Enabling Action: Collaboration

Summary

The treatment system requires a government-led strategy for a collaborative infrastructure, in common with other addictions services and whole systems, placed based approaches.

Strengths

Whole systems approach in Glasgow and Manchester create opportunities to further embed collaborative approaches to promoting access to treatment.

The need for leadership by NHS bodies in the three nations is now more widely acknowledged – notably in GambleAware’s three-year strategy (opens in a new tab), as well as new initiatives by OHID, DHSC and Public Health Scotland and Public Health Wales. The three nations have different approaches to delivery, reflective of wider differences in their health and care infrastructures.

Treatment is becoming better integrated with primary care services. For example, the Primary Care Gambling Service (opens in a new tab) is now offering treatment sessions including Cognitive Behaviour Therapy, family therapy, group therapy and signposting to specialist services and social prescribing opportunities. Royal College of GPs (opens in a new tab) has endorsed a new gambling competency framework for GPs, the first stage in the development of a curriculum and training programme for GPs, and gambling is now included in the NHS electronic records (opens in a new tab) and in one widely used primary care online screening tool.

The Glasgow Summit (opens in a new tab) on tackling gambling harms provided an opportunity for collaboration on the development of treatment networks in Scotland, utilising local authority, community based, and peer led approaches.

Areas for further progress

Referral pathways (opens in a new tab) between treatment providers require further clarification to ensure that people can access the right services to meet their needs and that the skills of all partners are fully utilised. This requires agreement between all stakeholders of referral pathways and thresholds for each point along the treatment/referral pathway, based on standardised assessments measures, training, triage procedures as well as secure mechanisms for shared records. Research led by people with lived experience has created new recommendations on key features of care pathways (opens in a new tab), but further implementation of these is required.

There is an over reliance on a single point of entry to accessing treatment – with the majority of referrals still coming from the National Problem Gambling Helpline. There is limited evidence of a significant volume of referrals being generated from other sources (opens in a new tab)4 - as would be expected with comparable addiction treatment and support services.

The voluntary system of funding treatment and support continues to create challenges to collaborative efforts and is a significant barrier to progress in raising standards, creating consistency and improving access. The principle of 'No Wrong Door' (opens in a new tab), well established across other treatment and support systems, needs to be in fully in place for those experiencing gambling harms.

Enabling Action: Evaluation and Research to inform action

(Assessed together as closely linked in relation to treatment)

Summary

There continues to be limited evaluation on what works in treatment and support services and a need for robust independent evaluations of specific interventions. There is limited independent research on treatment and support comparable to research activity in other addictions, suggesting that the voluntary funding arrangement is a major barrier to progress.

Strengths

The Public Health England Gambling-related Harms Evidence Review (opens in a new tab) identified new findings to inform the formation of treatment services in the future – these included:

Areas for further progress

There is a lack of research on the reasons behind recurrence and the provision of follow-up support (opens in a new tab), and the accessibility of data from operators and the financial institutions to improve understanding of products, play, spend and associated risk factors.

There is a lack of data on access to treatment compared to other addictions services. For example, the Public Health Dashboard (opens in a new tab) for England gives data by local authority on access to treatment for drugs, alcohol, but no equivalent data for gambling services.

Significant gaps still exist on the evidence base for treatment. A review of 1080 studies by the National Institute of Health research (NIHR) (opens in a new tab) identified poor quality reporting on treatment studies, high attrition rates, lack of evidence of ongoing support and no studies of interventions to support relapse. Only 30 studies met the criteria for inclusion in the review.

Part 3: Recommendations

Recommendations

As the work to reduce harms expands and diversifies, oversight of all the activities to deliver the National Strategy cannot continue to be led by the Commission in the same way. It will have an ongoing role influencing and collaborating with other government agencies, local authorities and the third sector, but will turn towards investing a greater part of its resources in core regulatory activity.

We recommend that the Commission should continue to take a lead role in prevention and education work focusing on the gambling industry and collaborate with other government departments and regulators such as ASA, Committee of Advertising Practice, Financial Conduct Authority (FCA), Department for Education (DfE) and the OHID, Public Health Scotland and Public Health Wales. The Commission should also continue to collaborate with the third sector and Local Authorities on the wider prevention work that is necessary to keep consumers informed and safe.

The Commission’s new focus on enforcement and data driven regulation (opens in a new tab) will lead to greater demands on operators to comply on safety standards and embed safer gambling practises into on-the-ground business cultures and new technologies. All of these actions will be set within the UK Government’s move towards more agile regulatory regimes (opens in a new tab) where more power is delegated to regulatory bodies to achieve better outcomes for the public.

We recommend that by 2023 treatment and support activity should be overseen by other government departments – Department for Health and Social Care (DHSC), Office for Health Improvement and Disparities (OHID), NHS England, Population Health Directorate, Scottish Government, Public Health Scotland, Welsh Government, Public Health Wales, working in partnership with local authority and third sector organisations.

Funding for treatment, prevention and research should no longer rely on voluntary donations. ABSG previously recommended a statutory levy set at 1%. Regulatory Settlements have been a vital source of funding for activity linked to the National Strategy. Clarity on how funds will continue to be made available for innovation and evaluation is essential to sustained progress.

Recommendations on regulation

We make the following recommendations in relation to the Commission’s responsibilities and remit, building on its own statement published in August 2021:

Regulatory action

Consumer safety

Regulatory research

Recommendations for an effective multi-partnership approach to prevention and treatment

We make the following recommendations in relation to other UK Government departments’ responsibilities for public health, treatment and research priorities.

Recommendations to continue development of an effective multi-agency approach

Primary prevention

Our recommendations on upstream population level interventions that aim to keep people safe and reduce the risk experiencing harm:

Secondary prevention

Our recommendations on early identification of harm and provision of support and treatment to prevent further harm:

Treatment

Our recommendations on effective treatment to reduce the impacts of harms:

Research

Our recommendations on wider research priorities:

Funding

Our recommendations on funding arrangements required to increase progress and impact: