Updated: Feb 10
The Review of the Gambling Act 2005 Terms of Reference and Call for Evidence was published on the 8th December 2020. As well as omitting a critical discussion around the extraordinary significance of gambling-harm on the population, there are several issues with the Government's policy paper that require commentary.
Ministerial Foreword: "The government also recognises the essential public health elements to any discussion of gambling, and separately to this Review the Department for Health and Social Care will continue work to expand and improve the treatment of gambling-related harms alongside other addictions like drugs and alcohol."
The government fails to recognise here that public health is centred around prevention and reducing harms on a population-level, as opposed to simply treating individuals who are suffering the most severe form of harms.
3: "According to the latest data collected across Great Britain, approximately 0.5% of the adult population are problem gamblers, defined as meeting particular thresholds of harm in a problem gambling screen. This rate has remained broadly steady around or below 1% for the past 20 years and now equates to about 300,000 individuals whose gambling is also likely to cause harm to those around them."
Depending on the choice of study design, between 4.0% and 13.2% of adults suffer significant harm (own gambling) in the past 12 months. The last gold-standard gambling prevalence survey in Great Britain, BGPS 2010, found that approximately 8.5% of adults (4.56 million individuals using a 2020 population estimate) were "vulnerable" gamblers in the past 12 months. It estimated the prevalence of problem gambling at 1.2%.
The Government have used prevalence statistics that were estimated using self-completion forms in a health care survey. Health care surveys have been shown to be less effective at capturing gambling-harm than gambling-specific prevalence surveys (gold-standard). For example, in 2007, a gambling-prevalence survey and a health-oriented survey measured gambling-harm at 7.3% and 3.2%, respectively.
3: "Additionally, 1.4 million adults are low risk gamblers, who are not likely to be experiencing harm but have engaged at least sometimes in a behaviour like chasing losses."
We are perplexed by the lack of understanding around gambling-harm in low-risk harm gamblers, especially considering that on a population level, there is expected to be more harm in low-risk harm gamblers than harm in problem gamblers. Furthermore, the Gambling Commission has previously provided clarity on how to interpret the term low-risk gamblers. According to the Gambling Commission: "The term ‘at-risk’ can imply that people who are classified as low or moderate risk gamblers on the PGSI are not experiencing harm now but will do in the future when in fact they are showing some signs of problematic behaviour now but remain below the threshold for ‘problem’ gambling."
12: "In August 2019 they instituted a ban on televised betting advertising during live sport before the watershed, and in September this year they committed to ensuring that at least 20% of their TV adverts are to promote safer gambling. The Betting and Gaming Council, which represents approximately 90% of the non-lottery gambling industry, has committed to drive up safer gambling standards across its members."
From Aug - EOY 2018 to August - EOY 2019, Betting and Gaming Council results show that the total number of gambling ads viewed across all channels fell by 11.3% (15, 222 million views to 13, 499 million views). While exposure to BGC gambling advertising on TV may have fallen by about 10% (led by decreases in sports-related gambling advertising on TV), there is no evidence to reflect that this was a real reduction in overall advertising. This is because the ban is not comprehensive (excludes sponsorships, online casinos, lotteries, bingo, and scratch cards, and non-BGC gambling companies, which are not subject to the voluntary industry commitment) and is only for TV (15% of industry ad spend).
52: "Children’s participation in gambling has been falling over time. The Gambling Commission’s 2019 research found that 11% of 11-16 year olds surveyed had spent some of their own money on gambling activities in the last seven days, down from 23% in 2011."
In 2019, past week gambling was reported to have declined to an all-time low of 11% from a peak of 23% in 2011. Despite this, the percentage of underage problem gamblers, at risk-gamblers, and social gamblers were reported close to the 10-year high at 1.7%, 2.7%, and 31.0%, respectively.
53: "Conversely, problem gambling rates among 11-16 year olds have remained comparatively stable, with 1.7% (equating to around 55,000 individuals) classified as problem gamblers in 2019. This is towards the lower end of the range of rates of adolescent problem gambling seen across other countries. A 2016 review of recent research found European adolescent problem gambling prevalence ranged from 0.2% to 12.3%"
Although the Government is right to suggest that 1.7% of 11-16 year olds are expected to be problem gamblers, the omission of a further 2.7% who also suffer significant gambling-harm leads to an incomplete view of gambling-harm in this age group. In total, 1 in 20 suffer gambling-harm due to their own gambling in the past year (4.4%, 142, 000 children).
In 2019, the percentage of 11--16 year olds who had gambled in the past 12 months had reached 36%, up from 30% in 2015. The Government should recognise that significant numbers of children break the law to gamble, and that this is a very worrying picture.
A more detailed look into the cited review, would have shown that only one study reported a problem gambling prevalence of 0.2% in Europe and that this was a postal survey of 17 years old in Norway. The Government should not try to compare results between studies that involve different age groups (European adolescent studies go up to 24 years old, whereas studies in Great Britain are of 11-16 year olds in secondary school) and between studies that are otherwise methodologically different.
61: Problem gambling rates among 16-24 year olds are lower than among those aged 25-34, but there have been instances of individual young adults suffering substantial gambling harm at a time of significant change in their life, for instance moving away from home or managing money for the first time (perhaps including a student loan).
In line with expectations and literature from overseas, the last gold-standard prevalence surveys in Great Britain demonstrated that problem gambling rates are highest among 16-24 year olds.
What else is missing?
Gambling-harm is an equality and diversity issue, as individuals from the BAME community are disproportionately affected and are disproportionately less likely to access treatment services
Issues with self-exclusion from non-online gambling
The need to safeguard children from family member's gambling and in particular to prevent children from going hungry due to gambling-harm