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ABSG progress report 2020
Published: 26 June 2020
Last updated: 19 August 2021
This version was printed or saved on: 20 March 2023
Online version: https://www.gamblingcommission.gov.uk/report/progress-report-on-the-national-strategy-to-reduce-gambling-harms
The Gambling Commission published the National Strategy during a year of rapidly growing interest in gambling related harms. The range of organisations now taking an active role represents a significant step forward, and there has been some progress in both priority areas of prevention and treatment.
Much more, however, still needs to happen to achieve the objectives of the National Strategy. Failure to make progress on the issue of gambling related suicide must be urgently addressed.
Our priority recommendations for year two include establishing a safer gambling league table and key baseline metrics from which to set targets and measure progress. Government, regulators, industry, the NHS and third sector organisations should agree areas of responsibility for ensuring these metrics are in place.
There needs to be an acceleration of efforts to involve people with lived experience in the delivery of the National Strategy.
To make faster progress on treatment, the NHS should lead the creation of a national treatment strategy working in partnership with the third sector. Agreed care pathways between the NHS and other providers are essential to the development of equitable services and there needs to be rapid implementation of quality assurance processes to monitor existing provision.
Greater progress is also required to secure more effective arrangements for commissioning research – particularly on the measurement of gambling harms. We recommend that initial engagement with research councils is built upon to increase their involvement on this area.
We continue to urge progress on a statutory levy to underpin all of this work with sustainable, independent funding. Without the levy, progress will be limited.
The COVID-19 pandemic has created unprecedented challenges to almost every aspect of life in Britain. Gambling activity is no exception and the exhortation to “Build Back Better” is as relevant to the goal of safer gambling as it is elsewhere in society.
The Advisory Board for Safer Gambling (ABSG) is responsible for reporting annually on the progress of the National Strategy to Reduce Gambling Harms.
This is the first Progress Report1, setting out our views on the achievements and the gaps to date, concluding with our recommendations for the second year of the Strategy2.
The findings are relevant to a wide range of audiences – particularly those partners involved already in the implementation of the National Strategy.
This report contributes to the objectives of the National Strategy by highlighting:
A more definitive list of activity related to the National Strategy is set out in the Gambling Commission’s quarterly Implementation Updates3. These documents set out more detailed project-by-project progress updates. These explain the range of activity being delivered by multiple partners in support of the National Strategy4.
As such, this report is best read in conjunction with these updates. This report is not intended to be a definitive record of all activity delivered in relation to the National Strategy. Under the previous National Strategy, progress reports from this Board included a detailed list of projects in progress. With the change in responsibilities for publishing the National Strategy now resting with the Commission, these detailed governance documents are now also produced by the Commission. The role of the progress report is to highlight high-level successes, gaps and recommendations.
In April 2019, the Gambling Commission launched the National Strategy to Reduce Gambling Harms in London. Launch events in Cardiff and Edinburgh followed in June. The Strategy was welcomed as a significant milestone in efforts to address harms from gambling. It placed public health approaches firmly at its centre, providing new opportunities for better and faster progress5.
The National Strategy was launched during a year when many other new developments in addressing gambling harms were underway:
Partners - National Strategy to Reduce Gambling Harms launched.
Political - House of Lords Committee opens inquiry on gambling-related harms.
Partners - NHS LTP Mental Health Implementation Plan.
Regulatory - Gambling Commission launch of industry challenges.
Partners - GambleAware announce intention on pulling back on research commissioning (HOL Committee).
Political - APPG report on online gambling harms.
Political - New government formed with commitment stated to review the 2005 Gambling Act.
Regulatory - ABSG provide Gambling Commission with formal advice on statutory levy.
Regulatory - Gambling Commission Board agree to develop formal arrangements for involving people with lived experience in its work.
Regulatory - National Audit Office report on gambling regulation and protection of vulnerable people.
Partners - Implementation group meetings in Scotland and Wales.
Regulatory - Gambling Commission implement online credit card ban, GamSTOP and LCCP changes on customer interaction.
Regulatory - Gambling Commission sets out guidance to operators on protection of customers during the Covid-19 lockdown.
In March 2020, the UK Governments introduced lockdown measures in response to the COVID-19 pandemic. This had an almost immediate impact on many of the projects that were underway and moved the public and political focus away from gambling harm. As a result, the publication of this report, along with the Commission’s own update on the progress of the Strategy, was postponed until June 2020.
The COVID-19 crisis has had a direct impact on gambling, with widespread cancellation of sporting events and closure of all premised based gambling outlets. We have yet to obtain data to give a full picture of the nature and extent of online gambling activity in this period7.
The consequences of these unprecedented changes have yet to be evaluated, but there are likely to be long-term health, social and economic impacts and exacerbated inequalities. Online gambling activity has increased in importance, which will mean more data on gambling patterns is now available to operators han ever before. However, challenges of availability of data means that reliable baseline estimates from which to measure recent changes are limited. This highlights the need for a fresh look at metrics that can help to identify those most at risk and do more to keep customers safe. The impacts of COVID-19 and “build back better” for the gambling industry will be reported on in ABSG’s 2021 Progress Report8.
Harvard Professor Malcolm Sparrow9, whose work on harm reduction in other sectors is well documented, suggests identifying key harms and agreeing on ways to measure them provides an effective catalyst for change. This approach helps to create common goals and improve coordination across multiple stakeholders. It is not enough simply to report on activities and timelines. Projects need to report on outcomes, and what has been achieved in reducing harm.
A key recommendation in this report is that specific metrics for measuring harm reduction need to be in place for the National Strategy as a whole, as well as for individual projects so evaluations can help measure the contributions being made. Where gaps exist, for example in establishing baseline data, efforts need to be made to address these, and responsibilities for collecting data assigned to specific organisations. DCMS has recently reinforced its commitment to doing whatever it can to ‘free up data sources across government’ that will contribute to this goal10. We provide proposals for what these metrics should look like in Annexes 1 and 2.
This paper is structured as follows:
For every strategy, effective governance and oversight are essential to success. The National Strategy for Reducing Gambling Harms has required new structures to be formed. Some of these are not yet fully in place and some have been delayed by the impact of the COVID-19 crisis.
This section describes the progress and challenges in creating the necessary infrastructure to deliver the National Strategy, including implementation structures, involvement of people with lived experience, funding and research.
The National Strategy was published by the Gambling Commission. Its implementation, however, relies on the involvement of a wide range of organisations, including central and local government departments, public health bodies and the third sector. Specific approaches to implementation are required in England, Scotland and Wales to reflect the jurisdiction of different bodies at national level. Key developments include:
The establishment and operation of the strategy implementation groups in Scotland and Wales represents significant progress towards three country impact.
Different ways of working across countries provides opportunities to test or accelerate alternative approaches. If well evaluated, this will provide evidence on what works, and what might be scaled-up.
Shared across all three nations, however, is the need for greater ownership by government departments – including those responsible for health and public health. This is vital if the range of required actions to reduce harm are to be delivered.
The Gambling Commission is publishing quarterly implementation updates on the National Strategy11. These provide information on new activities and their status.
There are, however, notable gaps in governance and oversight reporting for the National Strategy:
Implementation groups in England, Wales and Scotland are ideally placed to take responsibility for these actions. These groups are, however, still in formation, and are still some way from considering and agreeing impact metrics and forming risk registers. As these groups take further shape over the next twelve months, we recommend that addressing these gaps is prioritised. The recommendations in this report will contribute to this.
We also note the National Audit Office recently highlighted a lack of clear impact measures in its report on gambling regulation13. The Gambling Commission has accepted the recommendations in the NAO Report and is working to develop a new measurement framework. We recommend the Commission’s work is used to catalyse wider action on metrics for the National Strategy.
The National Strategy made a clear commitment that people with lived experience would be at the heart of delivery. More work is needed to embed this approach and create formal involvement by people with lived experience.
Key steps taken so far include:
Despite these actions, greater pace is required to achieve the vision for involvement set out in the National Strategy. One year in, there is little evidence of specific decisions where people with lived experience have been involved in co-producing decisions or exerting influence on the actions that have been taken. Since March 2020, there have been a number of initiatives that signal greater involvement has begun16. Creating an approach that represents a wide range of experiences is also a challenge. There continues to be gaps, for example among women, young people, and those from black and minority ethnic groups.
The purpose of this programme is to put people with lived experience at the heart of implementation of the National Strategy in Scotland.
The work to date includes a mixture of engagement activity and preparations to co-produce arrangements for a Lived Experience Forum in Scotland. The challenges created by the Covid-19 pandemic have meant that engagement has had to be reframed and delivered virtually, including:
The project has worked in close partnership with the Glasgow City Whole Systems project addressing gambling harms18, Third Sector Interface (TSI) networks, Self-Management Network Scotland. It has become embedded into the initial discussions of the Implementation Group for the National Strategy in Scotland (SIG) and hosted an International Futures Forum (IFF) three horizons session with SIG members, including Scottish Government to frame the implementation plans within a person centred, public health approach. Through ‘active implementation’ this will help ensure these voices are part of the decision-making processes for the strategy.
In addition, the programme is scoping with academics in the field of gambling harm the establishment of a PhD on engaging people with lived experience, planning an outcomes focused, co-created evaluation of the programme, and gathering a collection of ‘Digital Voices’ stories in print and a range of digital media.
The project aims to have established a lived experience forum within Scotland by Winter 2020/21. This will ensure people with lived experience are fully involved in action to reduce gambling harm and inform the delivery of the National Strategy.
ABSG19, the Gambling Commission20, and many other stakeholders, including parts of industry21, have advocated the need for a statutory levy to replace the existing voluntary arrangements. This would provide sustainable funding for independent research, and long-term delivery of prevention and treatment services through statutory bodies working in partnership with accredited third sector organisations.
Although the voluntary system remains in place, the National Strategy is being delivered in an environment where funding arrangements are in a state of transition. With 2019/20 seeing significant developments in funding arrangements:
Uncertainty remains about the future of the funding system for research, prevention and treatment. A continuing reliance on a voluntary system, wherever that may be situated is, in our view, not sustainable24. Concerns continue about independence, predictability and the quantum of funding, and in the absence of a levy, there are significant limitations on the scale of action that can be taken25. Activity to reduce gambling harms must still compete with other priorities in statutory health and public health budgets, and the financial impact of the COVID-19 pandemic on businesses and public services is likely to be significant.
The National Strategy to Reduce Gambling Harms recognises that the concept ‘problem gambling/gamblers’ does not lend itself to expressing the broader social and economic causes, manifestations and impacts of harms from gambling to individuals, as well as their friends, families, communities, employers and financial institutions.
As stated earlier, measuring harms is difficult, but progress has been made in recent years. There are a number of detailed frameworks that define gambling harms26,27,28. However, now that gambling is recognised as a public health issue, participation and harm should be reported as key public health indicators at a level useful to local authorities. In order to achieve this in England and Wales30,31, we recommend that their respective Public Health Outcomes Frameworks include gambling related metrics and that Scotland use their own well-established public health outcomes to obtain comparable data32.
Focused research can further contribute to much needed new intelligence. Longitudinal cohorts can provide information on a range of broader social, cultural and economic influences and impacts. A scoping study for a longitudinal study has been completed to explore this33 and there are also opportunities to utilise existing UK longitudinal cohorts34. Adequate funding and appropriate research governance are now required so these next steps can be taken.
There is also a need for epidemiological research to ensure that local level data is collected on gambling participation, attitudes and impacts as part of local authorities’ wider public health responsibilities. Local data is most likely to lead to local action to address harms. Reducing inequality is a core function of public health and local information on age, sex, ethnic, geographic and income differences in participation and risk of harm is urgently needed to underpin effective prevention strategies and support the development of targeted and effective interventions.
Establishing baseline data is key to measuring progress and requires endorsement and support from government departments, regulators and third sector organisations.
The Strategy makes a clear commitment to developing an evidence-based approach to harms reduction. There are outstanding challenges with both infrastructure and delivery still to be addressed.
Based in Ontario, Canada, GREO has established a strong reputation for knowledge exchange and dissemination of findings from academic literature. In June 2019, GREO obtained funding from a regulatory settlement to provide support to the National Strategy.
Since then, they have provided dedicated support focused on the Research to Inform Action and Evaluation enablers. This has led to a number of outputs, including:
GEO has also delivered ‘evidence exchanges’ on the following topics to support policy development and to help inform stakeholders in the National Strategy:40
The success of the National Strategy requires action from multiple stakeholders and the whole spectrum of operators from across gambling industry has a critical role to play in reducing harm by the way it implements measures to protect its customers.
Past performance has been mixed41. There have been good examples of progress, such as improving the prominence of gambling management tools and some short term increased prominence of safer gambling tools within marketing42. However, enforcement cases by the Gambling Commission over past years have frequently identified similar failings - operators have systematically either missed obvious warning signs of harm, or have failed to take appropriate action when these signs have been displayed43.
We doubt whether the gambling industry has yet achieved the capacity and culture to give us confidence they are ready to fully engage in the delivery of the National Strategy. Making further demonstrable progress on changes to industry culture would be a key indicator of change.
The National Strategy seeks a clear collective prevention plan, applying the right mix of interventions and targeting prevention activity where it will have the most impact.
A ban on gambling with credit cards was introduced in April 2020. In addition, a number of changes have been made to the Gambling Commission’s licensing conditions and codes for gambling firms in 2019/20. These include:
It is encouraging that the Gambling Commission is now taking steps to evaluate the impact of the credit card ban. We look forward to the results of this evaluation later in the strategy period – and hope this can be used as an opportunity to lead by example in the evaluation of what works in reducing gambling harms. The evaluation should also provide valuable information on any unintended consequences from this policy change – for example increased borrowing from payday lenders.
The strengthening of ‘customer interaction requirements’ is positive – but evaluating the impact of this change on consumers will be essential. A key next step will be to accelerate work on ‘affordability checks’ and making further improvements to identify whether consumers are vulnerable to harm based on analysis of their data. This is central to avoiding gambling harm, and action will be needed to set clear standards and demand consistent approaches across the industry. The existing approach has seen too many instances where several operators’ practices have fallen significantly short of required standards44.
In October 2019, the Commission issued the following new ‘challenges’ to the gambling industry:
We welcome the focus of these activities on priority issues, which, if meaningful action is taken, have the potential to reduce gambling harms46.
There are clear risks associated with an approach that rests on voluntary engagement and co-production with the industry. However, testing this co-production approach is worthy of exploration, and provides the industry with opportunities to demonstrate improvements.
The Commission must ensure that the industry is held to agreed timetables and outcomes before proposals are tested with a wider stakeholder group, in particular with those who have experienced gambling-related harms previously. There must be transparent accountability for progress in these four areas. If the progress is not adequate then the Commission will be right to act on its commitment to introduce alternative and robust regulatory requirements to protect consumers from harm.
Engaging the financial services sector has been a significant positive development. Banks, including HSBC, Starling, Monzo, Halifax and Barclays are now offering customers the option of blocking gambling transactions47. NatWest has formed a partnership with GamCare to offer counselling services within its premises48. Other activities are being funded to further develop the preventative role that could be played by the financial services sector.
The Money and Mental Health Policy Institute, funded by a regulatory settlement, is using its expertise to help facilitate actions in the financial sector to reduce gambling harms50. The project will draw together and disseminate best practice – this will be done through events and workshops, with best practice shared through a virtual hub.
In addition, GambleAware has provided funding to the Personal Finance Research Centre at the University of Bristol to establish the Money and Gambling: Practice, Insight, Evidence (MAGPIE). This will carry out research on the effectiveness of approaches used by the financial services sector to reduce gambling harms, and help develop the role to be played by this sector51.
Both projects have agreed a research partnership to ensure learning and activities are co-ordinated. The projects will explore how to build on existing responsibilities of financial services firms to help protect vulnerable customers and ensure organisations that are well placed to help people manage their money and avoid financial harm have the support and tools to do so.
There are a number of wider initiatives, such as the Vulnerability Registration Service52, which offer consumers the opportunity to opt out of contact from a wide range of services. This may have application in reducing gambling harms. There may also be further opportunities to explore lessons that can be learnt from data analysis in the financial services sector to identify where and how consumers become vulnerable to harms53.
Gambling with Lives has drawn significant attention to the links between gambling and suicide and suicide ideation. Its work has helped focus attention on the seriousness of this issue and the need for urgent action54.
The Commission published a package of research and analysis on this topic in May 2019. This work was undertaken with input from those with lived experience and included analysis of data from the Adult Psychiatric Morbidity Survey from 2007, the most recent and complete data available at the time55.
The report made a number of recommendations. However, there has been no progress towards achieving any of these. There has been no commissioning of the psychological autopsy study, no confirmation on inclusion of gambling related suicide measures in the forthcoming Adult Psychiatric Morbidity Survey for 2021, no inclusion of gambling disorder in coronial codes, and no progress on steps to ensure awareness raising and training on gambling related suicides amongst coroners is mandated. This failure to make progress on an issue that takes young lives is unacceptable and needs to be urgently addressed.
The National Suicide Prevention Strategies and Action Plans in England, Scotland and Wales67 give no prominence to the risk of suicide from gambling activities and nor do they explicitly utilise people with lived experience in campaigns to reduce gambling related suicides.
Annual Office of National Statistics data on suicide registrations are published each year, and the 2019 Cross Government Suicide Prevention Workplan sets out an ambition to reduce the overall number of suicides by 10% by 202157.
This is an area where rapid progress on establishing baseline metrics on gambling related suicide is needed and where government departments such as the Home Office, the Department of Justice, the Department of Health and Social Care, local authorities and third sector organisations and their equivalents in Scotland and Wales could make a significant contribution to obtaining data. For example, directing a qualitative review of existing coroner records to identify gambling related suicides, inclusion of gambling disorder in coronial codes, and the re-introduction of gambling in the 2021 Adult Psychiatric Morbidity Index.
The National Strategy makes clear that reducing gambling harms is a public health issue. Positive examples of this being put into practice are found in the Greater Manchester and Glasgow city area public health pilot projects.
The Greater Manchester Combined Authority (GMCA) is delivering a programme of work to embed a public health approach to reducing gambling harms across Greater Manchester. This pathfinder project is funded by a regulatory settlement and will aim to show how local level approaches can help reduce harms caused by gambling58
The partnership includes ten local authorities who will work together to:
Activities in development include early identification of gambling harms in university students – including student welfare, financial advisers, student unions and student GP practices. Also in development are plans to ensuring each local authority has delivered awareness raising sessions with front line staff. The partnerships work will be informed by people with lived experience of harm.
To build on this, action is needed to embed gambling in existing public health policy. A key step would be to include gambling metrics in the Public Health Outcomes Framework59. This is reported annually for all local authorities in England and Wales60 and is key to local policy making and health and wellbeing strategies61. An example of this can be found on the Public Health Wales Observatory webpages, which provides interactive profiles of particular public health concerns and their impacts at health board and local authority level62. Formally including gambling metrics here would mean local authorities would better understand both participation and harm in their populations so they can develop prevention strategies and respond to those experiencing harm. Equivalent action would be required in Wales and Scotland, such as the Scottish Schools Adolescent Lifestyle and Substance Use Survey, could be utilised63. Achieving this would require a co-ordinated approach to ensuring local level data is collected across Great Britain.
Initiatives have also been developed to target groups at higher-risk of gambling related harms.
The Commission on Crime and Problem Gambling was set up by the Howard League for Penal Reform following a regulatory settlement. The Commission on Crime and Problem Gambling is made up of academics, professionals and people with lived experience of addiction. Launched in June 2019, it will run for three years and aims to answer three questions:
The first stage of its work was a review of the evidence of links between crime and problem gambling across six areas (Australasia, USA, Canada, Germany, Scandinavia and the UK)65. The literature review has revealed useful insights.
Prevalence of problem gambling among prisoners (a population excluded in the Health Surveys) is internationally recognised as being higher than that of the general population. Evidence suggests problem gambling rates are five to ten times higher in prisons than in in the general population. Research also suggests there is little treatment and support for problem gamblers in prison, There is also some evidence of resistance to undertaking treatment whilst in prison as a result of the stigma attached to gambling addiction.
As the review continues it will collect further evidence from the UK and other jurisdictions and make recommendations on steps that can be taken to reduce gambling-related crimes and to support those who are affected.
Although the project set out above targeting higher-risk groups is positive, there is a gap in wider ‘universal’ prevention initiatives. Much prevention activity remains unproven. The ‘When the fun stops, stop,’ campaign has been challenged for lacking impact and focusing too strongly on promoting the message that gambling is fun66. There is some emerging evidence which supports this67.
There needs to be further activity focusing on children and young people68. Young people consider gambling to be an increasingly normalised presence in their lives69 with gambling harms associated with a significantly increased risk of health issues such as depression and anxiety. Types of gambling that are available to young people have been shown to be associated with disordered gambling amongst adults70. Young people are increasingly likely to experience gambling in the context of video games, eSports and skins betting71.
The value of activity focusing on children and young people is highlighted in the recommendations of the Royal Society for Public Health (RSPH) ‘Skins the game report’72. The Department for Education has announced that gambling as a risky behaviour will be included in the schools PHSE curriculum in England from September 202073. The government in Wales has set a similar approach74 but there are no indications as yet on how the impact of these measures will be evaluated.
GambleAware has launched its ‘BetRegret’ Campaign – which focuses on promoting awareness of risky behaviours – such as gambling when drunk or bored. An evaluation of the campaign is currently underway and we look forward to the publication of its findings75. New awareness raising initiatives led by those with lived experience are at proof of concept stage and we will report on its progress in 2021.
The National Strategy aims to help all those affected by gambling harm to access effective high-quality treatment and support wherever they live, with positive outcomes.
The recognition of gambling harms in the NHS England Long-Term Plan76 and subsequent Long-Term Plan for Mental Health77 provided a key driver for a greater focus on gambling harms in the NHS.
Over the past year, practical progress has been made through the opening of new clinics in Leeds, with new services open in Manchester and Sunderland, and a specialist clinic for children and young people in London78. NHS England has committed to opening up to 14 clinics across England.
The creation of these clinics has started to embed the process of treating gambling harms within the NHS. This is a positive start – but there are still weakness in commissioning, referral pathways and infrastructure. The focus for next year must be on:
The NHS Northern Gambling Service (also known as the Northern Gambling Clinic) is part of Leeds and York Partnership NHS Trust. It provides specialist addiction therapy and recovery to people affected by gambling addiction. This NHS service comprises a team made up of registered psychologists, therapists, psychiatrists, and mental health nurses and people with lived experience. The team works in collaboration with other services, including third sector specialist services, GP practises, local authority services, and debt advisory services, signposting to support and advice where this is needed.
The services are delivered in parallel with services provided by GamCare and funded by GambleAware.
Through clinics in Leeds, Salford and Sunderland, these services can be accessed by people across the North of England and Northern Midlands. It is used by people with gambling addictions who may also be experiencing depression, anxiety, trauma, and suicidal feelings. The support offered is also available to people affected by someone else’s gambling – such as family, partners, and carers.
The core programme includes eight to ten sessions of cognitive behavioural therapy (CBT), sessions with family and friends, follow up after these sessions have ended, support with tackling all the impacts of gambling addiction, and connecting with others who have had similar experiences.
Unlike the NHS, third sector treatment provision for those with gambling disorders is subject to internal quality assurance. As yet there is no nationally agreed external quality assurance process in place, and a lack of comparable outcome data.
In March 2020, the Care Quality Commission (CQC) finalised the first stage of its inspection regime for treatment providers in England, which included people with lived experience on the core team. Using the same quality assurance regime in NHS and third sector provision will provide comparable indicators on standards of service. For NHS organisations, CQC inspections include questions relating to research activity within the organisation. We would hope to see this included in gambling treatment provider inspections to support the further development of evidence informed practice.
Despite reference to NICE guidelines work being implemented in 2020 there is no confirmed date for this work to be completed80.
A number of pilot activities have commenced – these have engaged a wider range of organisations in the delivery of treatment and support than previously, and expanded the range of places and environments where harms can be detected and support offered.
These pilot projects will provide opportunities to learn about what works, and build capacity to treat and support those experiencing gambling harms. Examples of such activities include:
Much positive treatment activity is now being funded via regulatory settlements. This funding sources works well to fund relatively small scale, time-limited projects. There remain fundamental structural weaknesses in the system of funding to allow successful pilots to be rolled out and embedded into mainstream health service provision86.
Care pathways are still not well defined between different parts of the treatment system, for example between the NHS and GamCare and its partners, nor is there clear agreement on thresholds for onward referral, and which service offers what level of treatment and support and follow up. This is impeding progress on delivering the right treatment at the right time.
Leeds Beckett University was commissioned to evaluate the current GambleAware-funded treatment and support system. The first phase of this evaluation will focus on setting up and evaluation framework to assess the effectiveness of the treatment system and referral pathways. This will report in mid-April 2020, with the implementation of the systems evaluation against this framework then continuing until Summer 2021. A subsequent phase, looking at treatment outcomes at a provider level may not start until 2022.
The work being carried out by Leeds Beckett University is important and will provide useful evidence. The timeframes for this work, have been significantly delayed, which means the evidence the project hopes to produce will not be available until late in the current strategy period.
One implication of this is that decisions about the expansion of treatment will need to be made without this evidence from evaluation of existing services.
GREO are currently undertaking a rapid review of international evidence on international best practice for treatment and support of gambling harms87. This follows the failure of a research project by University of Huddersfield, commissioned by GambleAware to answer the same questions88. When complete, the GREO work will help make greater use of international research.
The delays and failures of these research projects limit opportunities to take evidence-based decisions about future treatment provision. This suggests there are weaknesses in the current system of commissioning and quality assurance of research via a small charity funded by voluntary industry donations.
‘We must avoid making what is measurable important, and find ways to make the important measurable’ - Robert MacNamara
One of the weaknesses of the first year of the Strategy has been the absence of a clear line of sight between the strategic priorities, the implementation plan, and measurable outcomes to show impact. Since February 2020, the Commission has been working on a wider set of impact measures, which may well be aligned with some of the recommendations outlined in this report.
ABSG proposes two overarching recommendations to address the gap:
Both recommendations are explained in the framework for measuring harm reduction and create a league table measure progress by operators sections.
Gambling harms have a negative impact on individuals’ lives and on society as a whole. Action is needed to measure these and ensure the strategy is achieving an impact on the most significant areas of harm.
As the National Strategy moves into its second year – a clearer articulation of the priority harms to measure should be created. This new framework would be designed to improve how we measure impact of the National Strategy. It would also address some of the concerns raised in the National Audit Office (NAO)Report89 about an absence of measures to demonstrate the impact achieved by the Gambling Commission through its regulatory work.
With reference to published descriptions of harms, we have identified those that constitute the greatest priority because of their impact on individuals, families and communities:
Recommended priority gambling harms:
Progress will require:
We should start by establishing baseline data, with a view to setting targets for harm reduction over time. The harms prioritised above will require actions by specific agencies.
The National Strategy is also clear that projects should be evaluated for impact. Through these evaluations, ideally, we would like to see evidence of impact in these high-level areas of harms. This will often be challenging, as impact of harms will often be significantly downstream of the intervention itself. But focusing on some priority areas would give these evaluations increased focus on priority areas of harm.
We know from other regulated sectors that transparency is an important driver of change. The National Audit Office report stated that a wider range of tools are needed to drive change92. For online gambling, the opportunities for using data are a particularly important area to focus on. We recommend, therefore, the Gambling Commission introduces a ‘safer gambling league table’ to be populated by new mandated metrics from the industry.
Our key recommendation is that operator data is published in a league table format with aim of increasing transparency and, through this, incentivising greater progress towards a safer online gambling market. Details of what this would include for online and land-based activities will differ, but the principle of increasing transparency applies to both.
Publishing data in this way is used routinely in other regulated industries to maintain and improve standards. Examples include:
In all of these examples, the transparency created by publishing data means regulated businesses are open to increased scrutiny, not only by the regulator, but from a wider range of stakeholders and the public as a whole. This scrutiny means that businesses are incentivised to maintain higher standards – this can help them attract customers, protect share value and demonstrate corporate values.
At this stage we do not have firm view on the specific metrics which should be included in the league table. In a data rich sector, such as online gambling, there is a wide range of possible options, and different gambling activities would require different metrics in order for comparisons to be meaningful. We recommend a working group is established to agree these. This group should be made up of a wide range of experts from across the sector, and must include people with lived experience. The Commission would also need to examine unintended consequences of these metrics and any potential perverse incentives they might create.
We propose four categories of metrics to be considered as a starting point: affordability checks, Gross Gambling Yield metrics, time spent gambling online and warning labels. Each of these are discussed below – but these and other options should be considered in more detail by the working group tasked with identifying the most effective safer gambling metrics.
At their evidence session in the House of Lords96, industry leaders asked the Commission to take the lead on affordability checks, suggesting there should be a standard across the industry. The GVC CEO, suggested that “if we can tackle the [affordability] issue and get it right then the numbers of problem gamblers would come down significantly”
Whilst there appears to be broad consensus on the need for affordability checks, there is less agreement on how best to develop such standards. Industry leaders view their own internal processes as commercially sensitive.
There is little agreement on what constitutes ‘affordability’ or level of spend, and there will of course be wide variation across different gambling activities. Another barrier to progress is finding ways to monitor a single customer spend across operators. However, the Commission could consider a number of options;
Gross Gambling Yield is the amount retained by operators after payment of winnings (before the deduction of operating costs). Any profitable gambling business is built upon the creation of GGY. Gambling expenditure (i.e., losses) has been shown to be a strong predictor of gambling-related harm97. Even small increases in gambling expenditure are linked to gambling-related harm, providing evidence that gambling-related harm is broad-based and is not limited to a small fraction of gamblers. An operator could reduce its per-customer GGY either by decreasing its house-edge, or by encouraging customers to play more slowly or for shorter amounts of time. These are all game design features operators may be incentivised to maximise without the use of such a league table metric.
The Commission routinely publishes overall GGY for all operators. We propose the Commission goes further and requires more detail on GGY. The risk of harm is greater where a large part of revenue derives from a small number of players.
Proposals for consideration by the working group might include:
Gambling-related harms are not always financial – time spent gambling, at the expense of time with family, friends, or in employment are often highlighted as significant causes of harm98.
To recognise this, we recommend an operator league table also includes metrics on time spent gambling. Total time spent gambling online per week, or average time spent gambling online for the top 10% longest playing customers, would provide a good insight into potentially harmful periods of play.
The effectiveness of warning labels and safer gambling signposting is not clear cut, and research on this is mixed99. However, in the interests of promoting greater transparency and accessibility, we advocate further exploration is undertaken of both warning labels and safer gambling messages. Unlike the three categories above, this category would not involve operators publishing their own data but would involve the Commission in making an assessment of operators’ performance and publishing the results.
Operators would be ranked according to the number of products displaying clear and demonstrably effective warning labels on their products. In addition to clear displays of warning labels, operators could also be ranked on the prominence of their signposting to helplines, or use of pop-ups.
The categories above are a starting point – methodologies for calculations will need further exploration and consultation and consideration given to how to weight the different metrics in a composite score to determine league position. In the longer term, the Commission could consider using star ratings and/or financial incentives (a percentage of licence rebate if an operator achieves a certain rating on the safer gambling league table).
There are a number of metrics that have been collected through survey methodologies for many years. Although there continues to be debate on whether the term ‘problem gambling/gambler’ and its associated metrics are of value100, we recommend the Commission continues to use these widely used tools as one of a number of measures until other validated metrics emerge to replace them.
The Commission and its partners should continue to replicate these in order to record changes in behaviour, frequency, characteristics, recognising such methodologies depend on self-reported measures that have inherent weaknesses and may not necessarily provide us with the metrics we need to assess impact.
We should, however, review the metrics collected to identify where new forms of data should be included. We should also review what data could be provided from other sources – e.g. data from financial services or social media companies, etc. This will tell us more about real time behaviour – as opposed to behaviour reported through surveys.
There is an imperative to ensure the voice of those with lived experience is included in new ways in any such approach. This is an area where the Experts by Experience Groups will provide an important steer.
In any work on data, the impact of COVID-19 on gambling behaviour must be considered. This will have an impact on behaviour recorded in statistics collected this year. For example, participation rates will fall. Use and variety of online products will increase. Figures on average spend will be distorted compared with previous years. It will be important to review the metrics and decide which ones will best inform us on how and where harms have been reduced.
We welcome steps already being taken by the Gambling Commission to understand the impact this will have – for example the COVID-19 tracker to explore initial impact101.
This section summarises the key recommendations in relation to:
ABSG’s key recommendations are:
ABSG’s key recommendations are:
Our key recommendations are:
The National Strategy was launched in April 2019 amidst a mood of shared optimism. Since then, much progress has been made, but there is much more still to be done before any substantial claims can be made on its success. Reducing harms requires a societal response.
The health and care system’s response to the COVID-19 crisis has highlighted how much cross-agency working can be done differently and better if there iscommitment to a shared goal102. It has also exposed the gaps in systems and processes that need to be addressed for the longer term.
The response to gambling harms requires whole system changes. Government departments, regulators, and the third sector need to commit to establishing baseline measures on specific harms.
The Commission has taken a hugely important step in setting out the National Strategy. It now needs to take a lead on industry metrics and the creation of a new safer gambling league table to accelerate and standardise promises of progress and to implement specific targets. This may be challenging in a post pandemic environment where industry focus will be on increasing revenues, but nevertheless essential to progress on reducing harms.
However, other partners in the Strategy need to do more. Government led initiatives such as inclusion in the Public Health Outcomes Framework, the Adult Psychiatric Morbidity Index, NICE guidelines and care pathways will be essential to progress on early identification, treatment provision, outcomes measurement and quality assurance. The third sector’s contribution is essential to campaigning, awareness raising and the provision of prevention and treatment provision in partnership with statutory bodies.
Researchers in the UK and further afield will be needed to continue to find answers to many of the outstanding research questions that remain and require urgent attention. All of these initiatives will be strengthened through the increased involvement of those with lived experience.
Finally, we would urge further progress on a statutory levy to underpin this work. Without it, there cannot be sustainable independent funding for research, prevention, education and treatment.
|Goal||Data source||Measurement||2020 KPI||2021 KPI||Responsible for action||Actions to deliver result|
|Reduce number of problem and moderate gamblers||Health Survey (Published in 2021)|
NHS data/third sector
|Baseline = PG:0.7% 340,000|
Moderate risk Gamblers: 1.1% 550,000
|Baseline data from clinics||50% reduction by year end||GC statistics|
|Replicate Health Survey Industry,|
NHS and third sector harm reduction strategies
|Zero gambling related suicides|
Zero suicide ideation
Banks (via exploring open banking)
Adult Psychiatric Morbidity Index
|Coroner recorded suicides|
Bank mortality data
Inclusion in 2021 survey
|Identify baseline numbers|
Include in 2021 survey
PHE Harm reduction strategy published
Survey results published
|GC funded pilot|
|Agencies provide access to data for analysis and to amend guidelines|
|Establish baseline data on gambling related homelessness, loss of employment, bankruptcy||Local authorities|
Bank data on loss of employment
|Baseline data||10% reduction||PHE. Local authority, third sector organisations||Data collated by local authorities in partnership with third sector|
|Establish baseline data on gambling related crime, prison sentences number in custody suites||Courts police, prisons||Number of gambling related crimes, sentences||Baseline data||10% reduction||Courts, police, prisons||GC funded project|
Courts, police, prisons
|Establish baseline numbers: domestic abuse and partner violence cases associated with gambling||Courts, police, third sector e.g. NSPCC, Refuge||Numbers||Baseline data||10% reduction||Police, courts,|
NHS and third sector
|GC funded project|
|Establish baseline data on gambling-related debt||Financial services sector|
Trussell Trust (Food banks)
|Numbers||Baseline data||10% reduction||GC|
CAB and third sector
|GC funded project|
|Establish data on gambling-related mental health||NHS, mental health support services, mental health charities – e.g. MIND||Numbers||Baseline data||10% reduction||NHS and third sector||GC funded project|
|Goal||Data source||Measurement||2020 KPI||2021 KPI||Responsible for action||Actions to deliver result|
|Prevent children being exposed to gambling marketing||Operators and affiliates||Marketing to children by industry and affiliates||50% Reduction||100% reduction||Industry and affiliates||Industry and affiliates change in strategy on children|
|Gambling recorded on the Public Health Outcomes Framework||PHE||Gambling indicator on PHOF||Goal agreed||Measure in place||PHE, Local authorities||Project initiated by PHE|
|Establish pilots in whole systems harm reduction approach||Glasgow Manchester London pilots||Est. Baseline local gambling harm profiles (e.g. QOF, local area risk profiles)||3 pilots underway||10 % change||Local authority and third sector||Guidance for local authorities on how to incorporate a system wide approach to gambling|
Establish baseline measures
|All young people receive teaching on gambling harm||PHSE programmes in schools||PHSE outcome measures||50% of schools||100% of schools||Local authorities||Local authorities and third sector|
|Standards for limits on losses introduced||Affordability checks||Standard set for all operators (e.g. loss limit set at £XX per month)||50% compliance by year end||100% compliance by year end||Operators|
GC Compliance Team
|Submit data to GC|
|Goal||Data source||Measurement||2020 KPI||2021 KPI||Responsible for action||Actions to deliver result|
|Increase numbers in treatment||NHS and third sector providers||Number receiving treatment (baseline currently estimated at 2%)||7%||10%||NHS and third sector||Implement single item screening tool across system|
Agree care pathway
Implement across system
|Create quality assurance checks for treatment provision||CQC||CQC standards (including research activity)||50% of all providers inspected and approved||75% of all providers inspected and approved||CQC in England|
|Inspections by CQC, HCI Scotland and HI Wales|
|Create a single item screening tool||NHS primary care, local authority and third sector providers||Single item screening question||50% uptake in primary care settings||100% uptake in primary care settings||Primary care networks, Local authorities and third sector organisations||Agree screening tool|
Test in pilot settings
Publish and disseminate
|Create agreed care pathways||NHS, PHE, third sector||Care pathway||In place in 50% of settings||100% of settings||NHS, PHE third sector||Agree criteria|
|Increase treatment for those in custody||Third sector providers||Numbers in treatment in custody||7%||10%||Third sector||Third sector interventions|