A call on behalf of the Health and Social Care Committee for government to review the Gambling Act yet again rests in part on Swedish suicide data, the applicability of which industry sources have called into serious question, and even the authors of the research do not trust. And yet, UK stakeholders hold on to the model like an imperial measurement – except it has no clothes on.
Industry experts are continuing to sound off on an unhinged request on the part of a cross-party group of MPs for government to issue yet another review of the Gambling Act.
A letter sent on behalf of the 11 – mostly Labour – members of the Health and Social Care Committee to cabinet last month issued the recommendation, based in part off statistics which seemed to suggest as many as 496 suicides in the UK every year were caused in large part by the consequences of gambling addiction.
Talk about MPS being out of touch – the database they frame their recommendations on have been disproven, disowned and as good as debunked by experts and even the authors themselves. But they are, after all, only mere politicians, they can’t possibly be expected to grasp facts and evidence, and even do a little bit of background research.
Partner Melanie Ellis of the the Northridge law firm is among those raising issue with the politicians, labelling this suggestion “frustrating,” calling the numbers quoted in the letter as having been “debunked.”
The data appears to have been drawn from a 2023 report by the Office for Health Improvement and Disparities, and has major limitations. Firstly, the OHID copped to the fact that it had no idea as to the annual number of gambling-involved suicides, with its guesstimate being anywhere between 117 and 496.
But even this crap-shoot is likely far-off the real mark: as it’s essentially a population-adjusted rip-off of a Swedish study, the participants of which were already in-patients suffering from mental-health issues.
“The hospital patients whose records were analysed in the ‘Swedish study’ suffered from a wide range of diagnosed mental and physical health conditions,” Dan Waugh of Regulus Partners underlined to iGamingBusiness earlier some weeks ago. “As a group, they were at elevated risk of self-harm, regardless of the presence or absence of gambling disorder.”
That issue aside, the fact the OHID just blanket copied-and-pasted the suicide-rate of a completely different country, one with an entirely separate sociological and regulatory environment, was swiftly denounced by none other than one of the OHID’s very own expert consultants.
“We cannot extrapolate from Swedish studies, from Norwegian studies,” UCL psychiatrist Dr Henrietta Bowden-Jones said pre-publication of the OHID report. “It doesn’t work.”
Meanwhile, for his part, Waugh has acknowledged that whilst problem gambling can form part of the milieu behind any one person’s decision to throw in the towel, that final, fateful decision is often informed by a multi-varied list of problems, often including alcoholism and drug addiction, which can be nigh-on-impossible to unpick.
The issue, he said, is “one that demands context…[and] understanding this can be helpful when it comes to devising self-harm prevention strategies.”
The search for gambling related suicide statistics
“Do you promise to give us the stats and nothing but the stats, so help you god?” No.
Back in August 2024, Coinslot started the process of investigating the number of gambling-related suicides following a flurry of references to a mythical 496 a year figure that was emerging as the base point, mainly from gambling charities and the NHS.
It was requoted by politicians who should know better, by the zany anti-gambling groups, who do know better, and many in the media, who obviously know better but never let a good story get in the way of the truth.
Part of our research was to consult the Gambling Commission for their understanding of the actual level – after all, suicide and gambling harm was a major consideration in their deliberations on regulation, as it was the new government’s action on the Gambling Act Review.
So important was the suicide issue that in April last year it became a condition of a licence that operators must advise the Commission of anyone who has committed suicide of those who attend or have attended their venue, or any of their family members or friends.
It was a highly criticised condition, but the Commission took a hard line on its decision to push it through.
At the time of Coinslot’s FOI request on suicide numbers, that licence condition was already six months into its declaration stage – and by our estimates based on the popular debunked methodology that everyone seems keen to use, the Gambling Commission should have received information on circa 250 gambling-related suicides. And currently, now 15 months on from the launch of the reporting process, and of course using the ludicrous methodology of the bastardised Swedish model, there should be some 620 gambling related suicides since the Commission introduced its licence condition.
So, where are we at with the number of gambling related suicides per year?
Bear in mind, there are MPs who have recently written to the government insisting they revisit the GAR on the grounds of these guestimated suicide numbers; and there are also councils and mayors looking to change licensing policies on the basis of these numbers.
But while the calculus has been discounted by the original authors who consider them irrelevant for use in the UK, they have still gained currency here.
And without any foundation.
Given the weight of importance assigned to suicide figures, and the fact that the Gambling Commission has, as basic and ill-structured as it is, a reporting process for compiling gambling related suicides in the UK, Coinslot asked for their figures to be released.
We include here the full reply from the Gambling Commission to our FOI request on the data they have so far collected and whether it can be put into the public domain.
Wednesday 23 October 2024. By email: ks@sjc.co.uk
Dear Mr Scott,
Freedom of Information Response
Thank you for your request which has been processed under the Freedom of Information Act 2000 (FOIA).
In your email you have requested:
1. How many suicides have been reported by licensees – in accordance with the guidance provided by the Commission – between 1 April 2024 to date?
2. When the Commission will publish this data and if not why?
3. Is the Commission sourcing this information from other sources?
Firstly, it should be noted that the Gambling Commission do not investigate gambling related deaths or suicides; it is for the coroner to decide a cause of death. The Commission however will consider instances where there appears to be a regulatory breach. More information about our compliance and enforcement approach can be found on our website.
In 2019, the Gambling Commission published an analysis of existing data indicating the link between problem gambling and suicide, which was funded by GambleAware. As a result, the Commission approved a regulatory settlement project, under which the Samaritans and GamCare have been working together to develop more in-depth guidance for gambling businesses to sit alongside the Commission’s requirements for the gambling industry to ensure operators are responding appropriately to risks of harm to their consumers. This work builds on evidence from our compliance and enforcement casework.
As of 01/04/2024 a change in the LCCP came into effect that means operators are now required to inform us when they become aware of customer deaths if there is evidence of a link to suicide, such as contact from the customer warning that they may take their life.
Where we identify that a suicide might have links to gambling, we will fully investigate the actions of the operator the person was gambling with.
The purpose of collecting information from gambling businesses is for regulatory purposes, in two key areas:
• To inform our compliance and enforcement work.
• To inform policy development (for example, on licensee interaction with their customers, customer use of gambling management tools and our knowledge of gambling across multiple gambling businesses).
It is not the purpose of the provision to create a comprehensive or robust data set to establish the number of deaths by suicide.
When a report is made, we consider the information available and may undertake further enquiries to determine whether there is evidence of regulatory failure in the licensee’s processes for identifying customers who may be experiencing or are at risk of experiencing gambling harm, and acting to prevent that harm. Where we identify failings, we consider appropriate regulatory action on a case-bycase basis.
We do not and cannot use the information provided by gambling businesses to measure deaths by suicide associated with gambling or act as a proxy for such figures. This is because gambling businesses will not always be aware when a person who has gambled with them has died by suicide and so the reported figures may not be complete, and also because the figures will not be able to tell us which deaths by suicide were associated with the customer’s gambling, which is a highly complex assessment beyond the remit of gambling businesses and the Commission.
Once the Commission has considered at least one full year of data, we will release information about the number of reports we have received (noting that this does not equate to the number of deaths).
This will be for the purposes of transparency about our work following the introduction of this new requirement and as part of our commitment to review the requirement once it had been implemented to continue to assess its proportionality and value for regulatory purposes.
Section 22(1) of the FOIA (“information that is intended to be published in the future”) provides that information is exempt if:
a) the information is held by the public authority with a view to its publication, by the authority or any other person, at some future date (whether determined or not),
b) the information was already held with a view to such publication at the time when the request for information was made,
This is a qualified exemption, therefore, the Commission must consider whether the public interest in maintaining the exemption is greater than the public interest in disclosing the requested information.
Arguments in favour of disclosure
• There is a legitimate public interest in promoting the accountability and transparency of public authorities.
• There is a public interest in Government Departments providing information they hold, that falls within the scope of an FOI request, as quickly as possible.
Arguments in favour of maintaining the exemption
• Releasing the data after one full year of operation will enable us to consider how to present the data to ensure that its purpose, and meaning is explained, and the context of our wider work is reflected (such as other relevant data sources).
• Premature publication of this data could lead to an incomplete and unclear picture emerging and would be likely to cause prejudice to both our compliance and enforcement work and policy development.
• Providing information as quickly as possible needs to be balanced with the public interest in the Commission ensuring the maximum time/cost effectiveness; providing this information in response to a FOI request is not the most time/cost effective way of placing this information in the public domain when it will be published in due course on the Commission website.
Weighing the balance
Having considered the above factors, the Commission is of the view that the balance of the public interest lies in maintaining the exemption. We recognise that there is a public interest in promoting the transparency and accountability of public authorities in a timely manner However, there is no outstanding public interest in releasing this information so soon after the introduction of this LCCP reporting requirement.
Taking into consideration the necessary preparation and administration involved in disclosing information of this nature, prior to the intended publication, without any accompanying context and commentary, we consider that our publication timetable is reasonable.
Finally, where you have enquired about the Commission sourcing this information from other sources; the Commission does not actively source this type of information from anywhere elese. However, as the industry regulator, our role is to consider if a gambling business has breached their licence conditions and we will take regulatory action where appropriate. We use any information received from a range of places, including from gambling customers, and other third parties to build cases against gambling businesses. Information provided to us helps inform our work to raise gambling industry standards and make gambling fairer and safer.
