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The Gambling Commission's Research Governance Framework.
Published: 30 April 2026
Last updated: 30 April 2026
This version was printed or saved on: 11 May 2026
Online version: https://www.gamblingcommission.gov.uk/standards/research-governance-framework
As an evidence-based regulator we collaborate with local and international researchers and organisations and have a duty to provide advice to the government about gambling behaviour in Great Britain, the manner in which gambling is carried out, the effects of gambling and the regulation of gambling and the National Lottery (opens in new tab).
We collect and analyse data to monitor changes that may have an impact on the regulatory framework and publish gambling industry statistics and gambling related research.
Research carried out and commissioned by the Gambling Commission seeks to aid the Gambling Commission’s legal obligation to:
Research also seeks to aid our National Lottery Statutory Duties which are:
Our Corporate Strategy 2024 to 2027 has identified the use of data and analytics to make gambling regulation more effective as a key area of strategic focus. This is especially important in an environment where rapid technological advances mean that licensees can offer increasingly complex and sophisticated gambling products and services to consumers.
We are committed to carrying out a rolling programme of research to significantly increase our understanding of the gambling market and consumer behaviour. Better evidence will lead to better regulation and as such to better outcomes for consumers, the public and licensees. We have established our priority research areas to ensure that our research is pertinent and impactful and addresses important gambling research questions. Through our research, we aim to build a robust regulatory evidence base in line with our licensing objectives. We have produced this research governance framework to explain and outline our approach to research which will continue to guide us in producing high quality research safeguards that the public trust, as well as protecting research participants.
Research governance is designed to ensure that the public can have confidence in the quality of our research, as outlined by the Government standards for analysis (opens in new tab) and the AQuA book (opens in new tab). Research is defined as all work of a research and investigation-based nature with the intent to generate evidence and analysis of gambling related themes and topics that includes research with human participants and research involving data about humans. For the purpose of this Research Governance Framework, research does not include:
This framework is based on the Concordat for Research Integrity (opens in new tab) (See also Guidance to implement the Concordat to Support Research Integrity within government (opens in new tab)) and the UK Research and Innovation (UKRI) ethics and integrity principles and guidelines.
We have also consulted the UK’s Research Integrity Office (UKRIO) Code of Practice for Research (opens in new tab).
Our official statistics are subject to the Office for Statistics Regulation (OSR)’s Code of Practice for Statistics (opens in new tab) which sets the standards that producers of official statistics should commit to, based around the 3 central pillars of trustworthiness, quality and value. In line with the code’s key principles, the Gambling Commission’s official statistics need to reflect the public interest as outlined in our public commitments, while protecting the confidentiality of individuals and of business information. It is our duty to ensure that our statistics are robust and reliable, based on the right data sources, with transparent judgements about definitions, methods, strengths and limitations of the statistics. We are committed to making our statistics equally available to all and publish our data in different formats to meet different user needs.
Further information on our statistics on the UK Data Service can be found in the Availability of research data on the UK Data Service. Finally, we have developed a user engagement statement to connect to users so their needs can be anticipated, and statistics kept up to date.
We have developed the research governance framework following engagement with stakeholders including academics, industry, other public bodies, the third sector and lived experience representatives1.
The research governance framework will be reviewed annually and may be updated to reflect policy updates, new initiatives or other changes to our approaches and procedures.
Standards for research such as the Code of Practice for Statistics and others that have been referenced in this framework will be updated by their respective owners (such as the Office for Statistics Regulation, UKRI, and so on). The links provided should signpost to the most up to date versions of these standards.
If you have any questions about this framework, please contact: research@gamblingcommission.gov.uk.
1Workshops were conducted in February 2025 with a variety of stakeholders to gain feedback on our evidence gaps and proposed roadmap topics. As part of the workshops, we also discussed matters of research integrity and governance. A further workshop was held at the Gambling Commission Spring Conference in March 2025.
We are committed to ethical research practices that promote a safe research environment where everyone involved is treated fairly and with respect. We believe that gambling research should maximise the benefits for individuals and society and minimise potential risks and harms. All researchers involved in a research project should ensure that co-production, collaboration or participant and stakeholder involvement in research meets and adheres to appropriate methodology and ethical frameworks, with considerations for responsibility, accountability, transparency, respect, expectations, management and sharing or use of the research.
Our gambling research should therefore comply with ethical requirements and other applicable guidelines such as:
Our overarching research principles that we set for all research carried out or commissioned by us are governed by these key principles.
Honesty, transparency and accountability in all aspects of the research including data collection and analytical methodologies, declaring potential conflicts of interests and acknowledging the use of tools such as emerging technologies. Any errors should be corrected as soon as possible (see Revisions and corrections policy). Research should follow clear lines of accountability and adhere to open research practices where possible.
Rigour and integrity are demonstrated by research that adheres to acceptable research standards including the use of appropriate methods, drawing interpretations and conclusions from research, and communicating findings. Researchers should be open about research limitations and how these impact the insights and recommendations made and be transparent about how methods and findings relate to the wider evidence base. Context dependent concepts like repeatability, representativeness, reproducibility, replicability, reliability, validity, trustworthiness, credibility, authenticity and meta-research are of equal importance to establish quality.
Care and respect are expected for everyone involved in the research process and should be extended to all participants in research. Care and respect must also be shown for the integrity of the research record.
As a regulator, we aim to be impartial and objective in the research we carry out or commission while keeping the legal obligation of the Commission in mind. Research should be designed to collect evidence that reflects a range of views and should aim to involve people with lived experience where appropriate and relevant. Research analysis and conclusions should seek to ensure that audiences receive a balanced view of the evidence we generate.
Research conducted in other countries, or collaborating with researchers and organisations in other countries, should comply with the legal and ethical requirements existing in the UK and in the countries where the research is conducted. Organisations and researchers based abroad who participate in our research projects should comply with the legal and ethical requirements existing in the UK as well as those of their own country. More guidance on collaborative working can be found in the UKRIO code of practice (opens in new tab) (PDF).
Researchers should maintain a critical approach to using AI and continuously learn how to use it responsibly to gain and maintain AI literacy. This includes being aware of the latest guidance on using AI and understanding what best practice looks like. Research teams should also familiarise themselves with the Concordat to Support Research Integrity and Generative AI (opens in new tab) (PDF), the Data and AI Ethics Framework (opens in new tab) and the Artificial Intelligence Playbook for the UK Government (opens in new tab)(PDF).
Further information for using AI in the public sector can be found at Artificial intelligence resources for the public sector (opens in new tab) (PDF). The Gambling Commission’s approach to using AI can be found on the The Commission’s approach to Artificial Intelligence.
Competing interests can inappropriately impact research design, delivery and outputs. Therefore, such conflicts of interest must be identified, declared, and addressed to avoid poor practice in research or potential misconduct. Conflicts of interest can occur within gambling research especially since gambling research often relies on data sharing or collaboration between stakeholders with different agendas or commercial interests such as other regulators, industry, third sector or other public sector bodies.
We, in carrying out or commissioning gambling research, must identify any competing interests and decide whether it is of a type and severity that risks compromising the validity or integrity of the research, in which case we should not proceed with the research, or whether it can be adequately addressed through declarations and/or safeguards relating to the conduct and reporting of the research. Our Managing Conflicts of Interest Policy sets out in detail:
The Policy applies to the following groups of people, although the requirements and processes may be different for each:
Competing interests should be disclosed at the project plan and ethical approval stage. Research Managers and the research team need to state any identified conflicts of interest (such as arising from personal or organisational considerations, funding, operator or other stakeholder influence, and so on) in the project plan. More guidance on potential conflicts of interests can be found in the UKRI Conflicts of interests (opens in new tab).
If the research project involves an external research provider or organisation, they must notify the Research Manager of any potential conflicts of interest. More guidance on conflicts of interest and procurement can be found in the GOV.UK Conflicts of Interest guidance (opens in new tab).
Once declared, the Research Manager, a representative from the Senior Management Team and the Research Governance Manager can assess conflicts of interest for impact on outcomes. If new conflicts arise during the study, they should be disclosed as soon as researchers become aware of them.
The Gambling Commission adopts the definition of Research Misconduct as stated in The Concordat to Support Research Integrity (opens in new tab) and detailed in Appendix 4.
Any concerns regarding questionable research practices or research misconduct by internal staff should be reported confidentially via email to the Research Governance Manager in the first instance. The Research Governance Manager will then report this to the Senior Management Team who will refer this to People Services if deemed appropriate. External research providers are responsible for monitoring and investigating allegations of research conduct involving their staff. We should be notified of any cases of research misconduct so we can determine any follow up action required.
Research projects that only use secondary data (anonymised) do not require ethical approval. They should follow the general principles of this Research Governance Framework and be based on robust data governance. If they result in an externally published output, this should be peer reviewed. A risk assessment is not required for such projects but may be produced if the Research Manager deems it necessary.
Research projects that involve human participants or non-anonymised data collected from human participants will require ethical approval. The following sections outline general considerations for ethical approval and the ethical approval process itself.
The following sections outline general considerations for ethical approval and the ethical approval process itself.
Researchers involved in one of our research projects will take appropriate steps to satisfy themselves that participants have exercised informed consent when deciding to take part in gambling research. Participants will be provided with the information they need to make an informed decision about taking part. This should include, but is not limited to:
This information must be provided in a way that is appropriate for the participant, particularly when carrying out research with children or vulnerable groups.
A range of our research projects and themes, such as our Roadmaps Evidence Themes 1 and 3 require the involvement of children, young people and other vulnerable persons. These participant groups require special consideration if they are to be participants in gambling research. Vulnerable persons might include people with identified higher Problem Gambling Severity Index (PGSI) scores or those with mental or physical health conditions.
Gambling research with children and young people needs to consider that these participants may not have the same mental capacity as adults to express their needs or interests or to give an informed consent to the research. Therefore, study designs and participant information need to be adapted accordingly (see also section 2.3.1 Informed Consent). Researchers working with children and young people need to be deemed suitable to do so by the research provider. Researchers must satisfy themselves that participants are enabled to give informed consent with special regard to the needs and capacities of people with vulnerabilities and children who may require gatekeeper permissions (whereby a gatekeeper may be a carer, parent or guardian). If a participant or gatekeeper cannot give informed consent, the participant should not be involved in the research. The research provider will record participants informed consent in appropriate ways subject to data protection and ethical considerations.
Researchers should ensure protection when collecting and processing children’s personal data. Any researchers who will be undertaking research with children and young people should follow UK Research and Innovation (UKRI)’s research with children and young people’s principles (opens in new tab). Researchers are recommended to also review ICO’s guidance on children’s personal data and processing (opens in new tab).
Researchers may consider whether incentives or rewards are required to mitigate against any expense of, encourage, or express thanks for, participation in a research study. Researchers must ensure that incentives are proportionate to the participant group, cost and benefit of the study, and include such proposals in the research project for ethical approval. We stipulate that incentives should not take the form of cash or bank transfers and could be in the form of gift vouchers or similar. Incentives should not be gambling related or provide an incentive to gamble. Reasonable travel and subsistence expenses for participants in research studies may also be covered. Any incentives would be handled by the relevant Research Manager or the external research provider and recorded in the respective project plan and/or workbook.
In any research project involving human participants, the dignity, rights, safety, and wellbeing of the participants must be the primary consideration. If at any point concerns are being raised (by anyone involved in the research project) that the research may place the human participants at risk or harm, the research must be paused. The relevant Gambling Commission Research Manager, a representative from the Senior Management Team and the Research Governance Manager will review the research activity to determine if it can proceed (with modifications if required).
There is a likelihood in all gambling research projects, that some participants may be affected by gambling harm. Therefore, all research participants in gambling research should be provided with information about relevant gambling support services if deemed appropriate. If, during the research process, any participants (especially children, young people and vulnerable persons) disclose that they are being harmed in some form (not caused by the research itself), the external research team should provide information and signposts for the most appropriate support service or helpline depending on the situation in a timely manner. They should also inform the Gambling Commission Research Manager if possible. The response may be escalated if the situation requires it.
Once it has been determined that a research project requires ethical approval, the Research Manager should discuss with the Research Governance Manager if the project requires the following.
Full ethical review for research projects that involve new participant recruitment. If the research project involves the recruitment of children, young people or vulnerable persons, the ethical review should consider their needs as outlined in section 3.2.2. The same applies if the research project involves sensitive topics that are deemed to have a higher risk of harm for participants (such as gambling research on topics such as problem gambling aspects, severe consequences of gambling harm and similar).
Light touch ethical approval for research projects that use pre-recruited participant panels for surveys, focus groups or similar. If the topic is particularly sensitive or the research focusses on vulnerable groups, the Research Governance Manager might advise that full ethical approval is needed for the research project, or parts of the project.
For research projects re-using human data that contains personal information (not anonymised), the Research Manager should submit a project brief together with a Data Management Plan and DPIA (if required) to the Research Governance Manager for ethical review and approval. Research projects re-using pseudo-anonymised data should check with the data owner at the outset of the project if the intended research fits with the original data collection purpose.
If the research project is carried out by an external provider who has their own ethical review process, the external provider should carry out their own ethical approval. They should then send a copy of this for our records. Unless the external provider uses an academic standard Research Ethics Panel or equivalent, we will also require a completed ethics checklist and the supporting documents as detailed above (if the project needs full ethical approval). The Research Governance Manager may request additional information from the external provider if necessary.
For ethical approval, the Research Manager should send to the Research Governance Manager: the project sign-off form and the risk assessment (if the external provider does their own risk assessment, this should also be included). The risk assessment for ethical approval should detail the potential risks to participants and the process for their mitigation.
For full ethical approval, the external provider also needs to complete the ethics checklist which is based on the UKRIO's Researcher Checklist of Ethics Applications (opens in new tab) (PDF). They also need to submit all supporting documents such as the participant information sheet and consent form for ethical approval.
Once the required documents have been submitted, the Research Governance Manager will organise the ethical approval process for the research project. The ethical approval will review the submitted documentation, with special focus on the safety and protection of participants and researchers, participant information and the informed consent process. For ethical approval to be granted, the reviewers need to be adequately reassured about:
The ethical review and approval will be carried out by one or more Gambling Commission colleagues who have been appropriately trained and who are otherwise not connected to the research project. An independent external reviewer might be consulted if deemed necessary. Human participants can only be contacted once ethical approval has been granted. Research re-using non-anonymised human data can only proceed once ethical approval has been granted. For any other research involving the Gambling Commission, as outlined in section 6, the external organisation and/or external research lead or academic partner is responsible for ethical approval. We will ascertain if any relevant ethical approval has been granted for an external project that we may be involved with.
Peer review of final outputs that are to be published externally is an important part of good practice in the dissemination of research findings. The peer review is about assessing if the research was conducted according to the principles and standards of good research practice as laid out in this framework. It is not about evaluating or commenting on the findings.
The peer review will be carried out for the final output(s) of a research project and will consider a range of questions, which can be found in our peer review checklist. Any output drafts submitted for peer review should be in copy edited, ready to publish format.
Once the final research project output is ready, it will be peer reviewed by our peer review trained staff who will not have been previously involved with the research project but will have a basic understanding of the project and will assess the project outputs using the prompts on the peer review checklist. The peer reviewer(s) will take note of any concerns including if there is any additional information that should be included. The annotated draft should then be returned to the Research Manager with comments and feedback within 5 to 7 working days unless otherwise agreed. The Research Manager should consider all the comments made by the peer reviewer(s). If they decide not to take a comment on board, a rationale for this should be provided. Once any required revisions have been carried out, a second draft may be sent for a second light touch review. An independent peer reviewer or a peer reviewer from one of our advisory panels may be involved in the peer review if deemed necessary.
For external research projects covered by section 6, the external research lead or academic partner is responsible for peer review if required.
The Research Governance Manager at the Gambling Commission is responsible for managing the research governance framework and providing advice on its implementation for relevant research carried out or commissioned by the Gambling Commission. The Research Governance Manager will arrange and coordinate peer review and ethical approval if required and report any issues to the senior management team.
The Director of Research and Statistics will be ultimately accountable for all research undertaken by the research and statistics team and will have final sign off on all research publications.
The Senior Management Team is accountable for research activity within their own teams and are responsible for only approving research activities that are fit for purpose and meet acceptable research standards. This includes checking that any external research providers (or other external research partners) either comply with the principles and standards of this framework or have their own research guidelines that adhere to acceptable research standards and principles.
Each research project has an allocated Research Manager with appropriate methodological and/or topic expertise. The Research Manager is responsible for:
The research project team are responsible for ensuring that any research activities that they undertake meet the requirements of this framework. The research team should consider any risks involved in the project and ensure that those risks are managed. The research team will help draw up the project plan and complete the ethics checklist if required. They will liaise with the external partner or research team if applicable.
Our expert groups may be involved in the various stages of the research process. This may include advising on and providing feedback for the research design or providing feedback or peer review for the research outputs. Peer review can only be carried out by someone who has not been involved in the research design or any other aspects of the research.
We have no responsibility for research projects undertaken by our staff that are not related to their role at the Gambling Commission, for example research for Masters or PhD projects or research undertaken as part of an honorary position that they may hold. The governance arrangements for these activities need to meet the requirements of the organisation that is supervising the research. For all projects that are undertaken within a (non-Gambling Commission) academic portfolio, our staff must notify their line managers before publication and, if relevant, a disclaimer should be added that states that ‘the findings and conclusions in the documents are those of the author and not necessarily those of the Commission.’
We may be involved in other external research, for example participation in:
The decision to be involved in any of these or similar activities should be based on the following considerations:
All research projects should be anchored in robust data governance. All personal data used in research projects must comply with the principles of the UK General Data Protection Regulation (GDPR) (opens in new tab), Data Protection Act 2018 (DPA 2018) (opens in new tab), and Data (Use and Access) (DUAA) Act 2025 (opens in new tab) as reflected in our contractual data processing schedules. The UK GDPR, the DPA 2018 and the DUAA 2025 also contain provisions for processing personal data for research purposes. These provisions refer to 3 types of research-related purposes for processing personal data, which are:
More information can be found in the Government Data Ethics Framework (opens in new tab). Researchers are recommended to follow UK Research and Innovation (UKRI)’s GDPR and research - an overview for researchers for additional guidance (opens in new tab).
The Commission has a responsibility to keep both personal data and non-personal data secure. Any potential sensitivity, for example personally identifiable data, will need to be identified in the data processing schedule. All researchers undertaking gambling research for or on behalf of the Gambling Commission will take all possible steps to protect the identity of, and data belonging to, people invited to take part in research during invitation, data collection, data storage, analysis and reporting in accordance with the relevant legislation.
Use of personal data in research is dependent on having appropriate safeguards in place (see Chapter 8A of the Data (Use and Access) Act 2025) (opens in new tab). These protect the rights and freedoms of the people whose personal data is being processed. Further information can be found in the ICO’s guidance on What are the appropriate safeguards? (opens in new tab).
Researchers should consider if they are choosing to use data anonymisation or pseudonymised data within their research. The UK Data Service information on research data management (opens in new tab), as well as the ICO’s Introduction to anonymisation (opens in new tab) provide further guidance on these processes.
Anonymisation allows data to be shared, whilst preserving privacy; personal data that has been anonymised is not subject to the DPA 2018. Data can be considered to be effectively anonymised when it:
Anonymous information rather than personal data has fewer legal restrictions. It is also easier to use anonymous information in new and different ways, as the data protection rules on purpose limitation do not apply.
Pseudonymisation replaces or removes information in a data set that identifies an individual. However, individuals can be identified by referring to other information held separately. Pseudonymisation does not change the status of personal data and remains in-scope of the DPA 2018 regulations.
Each research project that involves the collection of new data or the processing of non-anonymised human data requires the following documents.
A Data Management Plan (DMP) should include details on:
Research Managers should use our generic DMP and adapt it to each project. External research suppliers should also create a DMP for their side of data governance. This needs to be completed and submitted to the Research Governance Manager prior to ethical approval.
Researchers can refer to additional guidance in the Digital Curation Centre (DCC) Data Management Plan guidance (opens in new tab). Researchers may also consider the UK Data Service plan to share (opens in new tab) guidance.
A Data Protection Impact Assessment (DPIA) is recommended for any project which requires the processing of personal data that is likely to result in a high risk to individuals rights and freedoms. More information can be obtained from the Information Commissioner’s Office (ICO) Data Protection Impact Assessments (opens in new tab).
Should a DPIA be necessary for a project, this needs to be completed and submitted to the Research Governance Manager prior to ethical approval.
This research governance framework supports open research whereby research should be as open as possible and only closed when necessary. Open research helps to support and uphold transparency, openness, verification and reproducibility - improving public value, research integrity, re-use and innovation of research and data. As a minimum, all research should meet FAIR Data Principles: to make data Findable, Accessible, Interoperable and Reusable (opens in new tab). Unless there is a good reason not to do so, data and reports that do not contain confidential data should be made publicly available. For more information see also the Freedom of Information (FOI) Act 2000 (opens in new tab) and our Freedom of Information Requests page.
It is our duty to disseminate research outputs in a manner that reports the research and all the findings of the research accurately and without selection that could be misleading. It should be noted that there might be operational delays to publishing parts of the findings and data, resulting in not all outputs of a study being released at the same time.
Our publication calendar for our official statistics can be found at our When we release statistics and research page. Research outputs should be presented in a format understandable to the public with plain English summaries. Data relevant to findings should also be accessible if possible. More information can be found on our Using our official statistics and Availability of research data on the UK Data Service pages.
The publication of research results should include a discussion of the strengths and weaknesses of the analysis and the methodology as well as a disclosure of any conflicts of interests. Researchers must clearly acknowledge all sources used in their research (referencing). Research published on our website follows our accessibility guidelines.
This research framework also encourages:
The Research Manager is responsible for monitoring each research project to ensure that it is being carried out in accordance with the principles of this research governance framework, good practice, and any legal and ethical requirements.
If data corrections have become necessary, these will be carried out without delay and published as soon as possible, recording any changes that have been made and the reasons for these corrections. See also our Revisions and corrections policy and Quality Assurance for survey data.
The following questions are asked about general ethics considerations:
The following questions are asked about participant information and recruitment:
Consent forms will be assessed against the following statements.
The following questions are asked about data collection:
The following questions are asked about data management, documentation and curation:
The following questions are asked about data management, documentation and curation:
The following questions are asked about data management, documentation and curation:
Who will be responsible for:
Are there any organisational policies that are relevant to this research project?
The following questions are asked when peer reviewing research:
The Gambling Commission adopts the definition of Research Misconduct as stated in The Concordat to Support Research Integrity (opens in new tab):
Questionable research practices (QRPs): QRPs refer to minor infractions or research practices, including avoidable errors, which fall short of the definition of intentional research misconduct. They may arise due to a lack of knowledge or attention to detail, negligence, or deliberate action, and may occur where there is no evident intention to deceive.
Research misconduct: research misconduct constitutes the behaviours and deliberate actions that fall short of the research principles and guidelines outlined in this framework regarding the honesty, rigour, transparency, care and respect and accountability of the research. Misconduct can occur at any point in the research lifecycle. This may include:
Honest errors and differences in, for example, research methodology or interpretations, do not constitute research misconduct.