Alongside the Government’s anticipated work on evidence gaps identified in Public Health England’s review, the Gambling Commission unveiled its Evidence Gaps and Priorities (the “Document”) last month on 23 May 2023. The publication duly follows the topic of research, education and treatment (“RET”) set out in the White Paper (Chapter 3: The Gambling Commission’s powers and resources) and the aim for the Gambling Commission to “build on the expansion of datasets it collects from operators for regulatory purposes to develop a rich resource that will strengthen the evidence base on gambling and inform data-led regulatory action”; inclusive of an exploration on how anonymised regulatory data can be shared with researchers.

Nevertheless, Tim Miller (Executive Director of Research and Policy) underlines in his introduction, that the Document is “not only about the Commission and what we need to do…[but also] about highlighting the challenges ahead and asking the questions that need answering. Answering those questions is something we can all play a part in.”

The Document sets out six existing areas or “evidence themes” that the Gambling Commission will prioritise in making a concerted effort in to strengthen the evidence base. We set out below a summary of and links to each.

1. Early gambling experiences and gateway products

About: understanding early gambling experiences and journeys of those aged 24 and under, otherwise vulnerable and generally, including engagement with and the influence of new non-gambling products that share similarities with gambling.

Gambling Commission on what is needed: increased research with “a longitudinal aspect” and linked operator data with a focus on younger gamblers for the exploration of patterns in remote, regulated gambling (although the Gambling Commission does not specify from whom).

Gambling Commission example research questions:What prompts different people to start gambling? How does gambling behaviour change over time as children become young people and young adults? What is the impact of major betting events, such as the World Cup or Grand National, on new gamblers?

Gambling Commission focus: continuing research with children and young people, with an expansion to cover 17-year-olds; building on research to explore the gambling journeys of young people to further develop understanding of how consumers are introduced to products and activities that are new to them.

2. The range and variability of gambling experiences

About: further exploration of customer journeys including, gambling habits and behavioural changes over time; the wider context of the individual customer, their life and how gambling overlaps with other behaviours and experiences.

Gambling Commission on what is needed: a mixture of data sources to explore them, with qualitative research; access to a wide range of anonymised datasets.

Gambling Commission example research questions:  What do we know about the spectrum of gambling activity and what constitutes ‘safe’ gambling? How does gambling fit into a gambler’s wider online activity or life? How and why do people’s gambling habits and behaviours change over time?

Gambling Commission focus: use of the new Gambling Survey for Great Britain to improve understanding of gambling participation at a national level and in sub-groups of interest; building on the key parts of the Path to Play framework to add depth and insight; developing strong foundations for future research, for example establishing recontact samples for longitudinal research.

3. Gambling-related harms and vulnerability

About: gaining a better understanding of the different ways that consumers can experience harms; an ability to identify consumers who may be more vulnerable or at risk of experiencing harms.

Gambling Commission on what is needed: “significant resources to investigate many of these sub-topics [which] is likely to require a blend of evidence from longitudinal, co-produced research with people with lived experience of gambling-related harms, account data and in-depth qualitative sources to gain a better understanding.”

Gambling Commission example research questions: Which individual circumstances (situations or demographics) increase vulnerability to gambling-related harms? What’s the relationship between gambling-related harms and different co-morbidities? What is the impact on ‘affected others’ (adults and children) of gambling-related harms? What interventions are effective in reducing gambling-related harms?

Gambling Commission focus: using the Gambling Survey for Great Britain to produce robust statistics on who is experiencing gambling-related harms; qualitative research with consumers with experience of gambling-related harm; using Gambling Commission datasets and wider evidence to identify groups that may be at greater risk of harm.

4. The impact of operator practices

About: understanding the influence of common operator practices on consumer behaviour; assessing the effectiveness of interventions designed to detect and reduce gambling harms.

Gambling Commission on what is needed: various sources of data including operator-held account-level data suitable for detailed analysis, qualitative data, and potentially longitudinal data.

5. Gambling Commission example research questions: How can marketing and safer gambling practices be incorporated effectively together as part of a seamless player experience? How well do consumers understand information (for example, about offers or products) provided to them by operators? How effective are harm detection algorithms used by online operators? What are the factors that drive and influence consumer’s perception of whether gambling is fair and can be trusted?

Gambling Commission focus: gaining greater access to operator-held account-level data to further explore the impact of operator practices.

6. Product characteristics and risk

About: improving understanding of which products and behaviours carry greater risk of harm, for whom, and why; gaining a deeper understanding of how consumers interact with different products and links to gambling harms; identifying areas of new or emerging risk and building a strong understanding of changes in the market.

Gambling Commission on what is needed: Research that identifies markers of harm and increased risk, with examples including examining real-time account activity data, opportunities created through data linkage, or robustly evaluated product trials in live environments.

Gambling Commission example research questions: Are certain product characteristics associated with gambling-related harms? Do some product characteristics disproportionately affect certain types of gamblers? How can gambling products be designed to mitigate the riskiness of game characteristics without compromising enjoyment? How do people’s patterns of play vary between products?

Gambling Commission focus: gaining greater access to operator-held account-level data to further explore patterns of play; using secondary analyses of existing datasets to further our understanding of product risk.

7. Illegal gambling and crime

About: understanding links between gambling and criminal activity; understanding crime as a dimension of gambling-related harm; improving knowledge of the extent and impact of the unregulated market.

Gambling Commission on what is needed:  Given the secretive nature of criminal activity, a requirement for more specialised and focused research methods, with greater reliance upon new and existing partner organisations and new tracking techniques identified within the gambling landscape section.

Gambling Commission example research questions: What is the extent of criminal activity to fund gambling activities? What is the size of the illegal market, and what’s the impact on British consumers? What is motivating consumers to gamble on the illegal market? How easy is it for consumers to tell that they are using an unregulated operator?

Gambling Commission focus: research into consumers’ understanding and use of unlicensed illegal gambling operators; using the Gambling Survey for Great Britain to develop understanding of the commission of and victims of crime as a dimension of gambling-related harm.

In order for this projected work to be impactful, it will be important for the Gambling Commission to emphasise effort on the aspects for which it has been criticised. It has acknowledged this in part through acknowledgment of the need for more qualitative data, including increased longitudinal research. However, this needs to be more than just lip service and as the Document already recognises, these efforts must work in conjunction with other areas of evidential weaknesses highlighted in the White Paper in respect of gambling research. These include: making full use of the UK Research and Innovation (UKRI) funding to increase the number of studies on gambling behaviour, with the aim of attracting wider interest from academic and research institutions in order to generate more high quality and peer-reviewed research.

In addition, it could be inferred from the White Paper that Government views the Gambling Commission’s main strength in relation to RET to be its access to datasets it collects from operators. Therefore, it will be interesting to see the development of the Gambling Commission’s focus in this area (as highlighted in sections 4 and 5 above) not only in terms of scope and methodology but also its exploration on how anonymised regulatory data can be shared with researchers.