Health and Social Care Committee
Oral evidence: Gambling-related harms, HC 804
Wednesday 2 April 2025
Ordered by the House of Commons to be published on 2 April 2025.
Watch the meeting
Health and Social Care Committee members present: Layla Moran (Chair); Danny Beales; Ben Coleman; Jen Craft; Josh Fenton-Glynn; Andrew George; Paulette Hamilton; Alex McIntyre; Joe Robertson; Gregory Stafford.
Culture, Media and Sport Committee member present: Jo Platt.
Questions 1 - 95
Witnesses
I: Lucy Hubber, Director of Public Health for Nottingham, Association of Directors of Public Health; Professor Heather Wardle, Professor of Gambling Research and Policy, University of Glasgow; and Professor Sam Chamberlain, Professor of Psychiatry, University of Southampton.
II: Professor Henrietta Bowden-Jones, National Clinical Adviser on Gambling Harms, NHS England; Andrew Vereker, Deputy Director for Tobacco, Alcohol and Gambling, Office for Health Improvement and Disparities; and Tim Miller, Executive Director of Research and Policy, Gambling Commission.
Witnesses: Lucy Hubber, Professor Heather Wardle and Professor Sam Chamberlain.
Chair: Welcome to the Health and Social Care Committee’s one-off hearing on gambling harms. We have two panels of witnesses today. The purpose of today’s session is to look at the wider gambling landscape, the public health response to gambling-related harms and what the Government and related bodies can do.
I ask our first witnesses to introduce themselves and what they do, starting with Professor Wardle.
Professor Wardle: I am Professor Heather Wardle. I am a professor of gambling research and policy based at the University of Glasgow. I was co-chair of The Lancet public health commission on gambling, whose report, published last year, looked at what a public health response to gambling might look like and made international recommendations. I have some copies of the report with me, if anybody would like one at the end.
Professor Chamberlain: Hi, I am Sam Chamberlain. I am a professor of psychiatry at the University of Southampton. My research work has been ranked in the top 10 globally in the field of gambling; clinically, I work in the NHS as well, and I founded and direct the NHS Southern gambling treatment service. To finish, I have no conflicts in relation to the gambling industry or its linked organisations.
Lucy Hubber: Hello, I am Lucy Hubber, the director of public health for Nottingham. I represent the Association of Directors of Public Health.
Q1 Chair: Thank you all. The first question is from me and is perhaps addressed to our eminent professors. Gambling products have changed quite a lot since the Gambling Act 2005 was passed. Could you give us a sense of what the landscape looks like now? Shall we start with you, Professor Wardle?
Professor Wardle: Sure. Since the Gambling Act 2005, we have seen the massive growth of online gambling and the intensification of products; they are available through smartphones 24/7, and the speed and the intensity of the products have sharpened. Previous products, such as sports betting, were essentially one-off events, but that is now transformed into continuous formats, through the in-play betting, for example. We have a fundamentally different landscape in access, availability, and the nature of the products—their speed, their intensity, how engaging they are, and how able they are to capture people’s attention. That is the fundamental change in the online environment.
Equally, we see changes in the offline environment. The land-based machines have adopted some of those practices, so on the B3 machines, the games are much more intensive than they were previously, and they are now much more focused on casino-style products.
Professor Chamberlain: I agree with Professor Wardle. I would also highlight what we see clinically, with patients often reporting online gambling as a problem because the products are so intrusive—they could be sending people messages in the middle of the night—with free bets and money. Over time, there is this tendency towards more addictive products in general, and I think the industry is well ahead of independent academics in knowing, and maybe understanding, what makes those products so addictive.
Yes, we have seen some shifts. The shift towards online means fewer bars to developing gambling problems. Whereas previously, people would have had to go physically to a casino, for example, now they can be doing it in bed at night. It is not good.
Q2 Chair: You started touching on the risks, saying an addictive product is now available in your bedroom. Are there any other risks in the new landscape that we should be aware of?
Professor Chamberlain: Would it be helpful if I give a brief overview of how gambling-related harms can impact on people?
Chair: Yes.
Professor Chamberlain: I will keep this concise, but it is very complicated. On the terminology, we have gambling disorder, which is the clinically recognised condition, but as Professor Wardle and others have highlighted in their research work, it is a spectrum of harms. In clinic, we see people at the more severe end of the harms.
Broadly speaking, however, gambling disorder and gambling harms affect people in different ways. At a personal level, it can lead to suicide, anxiety, depression and other addictions. In families, it leads to relationship breakdowns—it is devastating. In academic and employment terms, it is strongly linked to worse academic outcomes, academic drop-out, unemployment and, more broadly, homelessness. There are strong links with homelessness.
The knock-on impact in other services is also worth bearing in mind. If someone has become homeless due to gambling-related issues, charities have to try to help that person, so there is a knock-on impact. If people are presenting in suicidal crisis, that impacts our paramedics and frontline services. Those are some of the broad themes of harms, although they are wider than that, of course. For each person affected by gambling-related harms, there is likely to be a knock-on impact for family members and other parts of society.
Professor Wardle: You asked about categories of risk. It is also to do with the way the commercial industry now operates. Particularly with the move to online, those companies now capture a wide range of data on every single bet—behaviours they are able to model. They are able to profile you, target you and use that information—and they do use that information—to send bonus offers, to keep you engaged and to keep you re-engaging. In fact, a really pertinent statistic was cited in the White Paper: people who had the highest levels of harms reported receiving daily incentives—34% of them reported receiving daily incentives to gamble—and yet of those who did not experience any harms, only 4% reported getting the same amount of incentives. That shows how the targeting and profiling is happening. Also, there is now a much wider ecosystem for the commercial gambling industry, which extends into broadcasters, advertisers and financial institutions, which are all interested in making the commercial gambling industry viable and continue to be viable.
Q3 Chair: May I ask you about advertising? Before this session, I reflected on the fact that we turn on the radio or watch television and it is all gambling adverts—well, not all, but they seem to be pretty prolific. It seems to have gotten greater over time. Have we quantified how much advertising is going on in this space? Also, what are proportions offline and online—so television and radio versus the online incentives that get pushed to people?
Professor Wardle: The latest statistics that I am aware of looked at paid-for advertising in one quarter of 2021. That amounted to £91 million for one quarter, so you can see how much was being invested over the course of a year in paid-for advertising on your TV, radio and so on. That does not take into account all the streams of advertising—the social media advertising and the online advertising. I do not have data on the split between online and land based, but we certainly know that there is a great push, particularly through the online mechanisms.
Chair: Lucy, would you like to comment?
Lucy Hubber: The pertinent question here is, how does that advertising reach people? The Gambling Commission itself notes that about 80% of the population are exposed on a weekly basis to some form of gambling advertising. We know that that advertising is reaching children and young people, and it is normalising gambling at that early age.
Q4 Chair: We will come back specifically to that point later. The 80% refers to children and adults together—is that correct?
Lucy Hubber: It is the population, whether in TV adverts, sponsorships or online adverts. As you said, it is now almost impossible to access media of some form without being exposed. We know that that exposure leads to behaviour change and leads to prompting people to take action. We have really clear evidence of the influence that it has on children and young people.
Q5 Chair: I was going to ask a little about the gambler pipeline, where someone might start by looking at an advert and perhaps dabbling with a single bet. Can you take us on the journey of someone who started gambling because of an advert, but ended up in your clinic? I am quite interested to hear about that from you. First, if you want to comment on the previous bit, that would be great.
Professor Chamberlain: As well as the statistics, we have probably all seen it personally as well. I do not know about you, but since lockdown, I see pervasive adverts about gambling on television all the time, promoting very happy messaging about it being very sociable, even for games that involve no social contact. The other worrying thing is the sports. I know we are going to cover young people later, but they are seeing this all the time in adverts on television, and the football teams promoting gambling adverts in the daytime matches. It is extremely intrusive.
On the pipeline, it varies, depending on the person. Generally, I am of the view that there is no completely benign form of gambling. For all types of gambling, one or two people in every 100 will develop an addiction because of it, generally speaking, although of course some products are a lot more harmful than others. Even lotteries in the round are not benign; they have been linked to 1% to 2% of people developing a gambling disorder, based on international data.
Yes, often we see a progression clinically. Someone might start with the less addictive form of gambling, but that can act as a gateway because often the venues—be it the physical venues like the bookies or websites like the National Lottery website—have advertising. Yes, there are normal lotteries, but scratchcards are a more addictive product, so there are gateways there. Of course, some people are able to gamble without developing a problem—they do not progress to addiction. We need a lot more research to understand the protective and vulnerability factors behind that. We know a bit about that already, and maybe we will come to them later.
Chair: Yes, we will come to those.
Q6 Josh Fenton-Glynn: The interesting thing about the advertising is that it normalises gambling so much. I listen to a lot of sports podcasts, so I come across it quite a lot and yes, I can see its pervasive nature. The Government are introducing the prevention commissioner, looking a bit more at the public health side of this. Are we shifting to get the balance right between helping individuals and public health? I will start with Lucy for that one.
Lucy Hubber: If the Committee will indulge me, it is probably worth us understanding what we actually mean when we talk about a public health approach. The difference with the public health approach is that we are interested in populations and, as you rightly say, so much of the focus has been about treating individuals, those people at the top of that pyramid, but by that point, we are already experiencing significant harm along that spectrum of harm.
Taking a population-based approach, we need to understand what the need is in the population, the drivers of the behaviour, the populations that are at greatest risk of harm—I do mean risk of harm—and the evidence of what works. Those are the principles of taking a public health approach. I think that that is a significant shift of focus away from treating individuals the industry is telling us have problem gambling behaviour, to understanding that this is an addictive and increasingly normalised behaviour that is causing a lot of harm. It is worth noting that the public health harms are not the same as healthcare harms. There is the stuff that Professor Chamberlain sees in his practice, but we do not see the family breakdown or the homelessness that is a consequence of that, which impacts on other services. Significant harm is hidden.
We need to make sure that we understand that prevention—telling people that gambling is harmful—is not enough and that we need to support it with properly funded and supported regulatory activities, nationally and locally. A lot of work is going on in local authorities, led by directors of public health, trying to challenge licensing. The Committee might wish to consider that a current statutory duty is to permit betting premises, which feels a little like it works against public health. Directors of public health are not a responsible authority on planning licensing applications for gambling, so we have to work twice as hard to be able to influence that. The industry will always appeal a decision to overturn a licensing, so we have to work twice as hard on that as well. We could do lots locally on changing that sort of licensing, creating the environment differently.
I also think we can do quite a lot to make sure that the policies that are already in place are enforced. We have tremendous resources in local trading standards officers. With additional resource there, we could make sure that the land-based activities are being supported. I know we want to come back to children and young people, but increasing numbers of children and young people are using land-based activities. We cannot assume they are just gaming; they are physically gambling as well.
We also need to think about how we issue some of those counter-messages in terms of how we upskill the workforce to do some of the routine inquiry work and how, using the industry’s own tactics, we begin to challenge some of the normalisation around gambling.
Q7 Josh Fenton-Glynn: One element of public health is recognising patterns in populations. This is possibly to Professor Wardle, but my suspicion is that the people who have the best idea about the pipeline from placing a few bets to ending up placing a bet on your phone in the middle of the night are the people who hold the data—the gambling companies. I suspect that the answer is yes, but is there any more they could do to identify that pipeline?
Professor Wardle: I am not sure it is about what more the industry could be doing; it is about what more we could have in terms of independent research and oversight of those processes and systems. You asked whether we were moving towards a better system of regulation. We rely heavily on the industry to provide solutions to these issues. We rely on the industry to identify those people with whom interactions should be made, and we trust the industry to make those interactions. We have seen systemic failures in that, via the regulator and the fines they have issued.
We are also relying on the industry to implement their own voluntary codes on advertising and marketing. We assume that they stick to them, but they are frequently breached. You may put in complaints to the ASA about that, and the response is, “It is a breach of a voluntary code. We don’t have any authority.”
Q8 Josh Fenton-Glynn: Do you think that the “When the fun stops, stop” type of advert touches the sides?
Professor Wardle: No, absolutely not. There is research evidence that they have very limited efficacy and might actually, in some cases, be counterproductive.
What we need to be thinking about, with the opportunity we have with the levy, is being really systematic about changing our monitoring and surveillance system and making sure that we get that independence into the prevention system, so that we are not relying on an industry and companies that are, yes, doing their fiduciary duty by generating profits, but generating those profits from the people who are most harmed, to actually implement the solutions. That system needs to change.
Professor Chamberlain: I really welcome the shift towards the public health approach. To expand a little on some of Professor Wardle’s thoughts, what we have seen for decades is a lot of research, conducted with voluntary donations from the gambling industry, that has been very poor quality. We know from research work—for example, from Martineau and colleagues—that stakeholders can set out with really positive intentions. If you look at some of the experiences in Italy and Finland with regulating electronic gambling machines, there are good intentions, but then there is industry lobbying and things get watered down. Some changes are implemented from a public health point of view, but there is evidence from the research that they are ineffective.
We also see in review papers in the field that, generally, if the public health interventions are funded through voluntary donations and influenced by the industry, the interventions that get promoted are those that are least likely to be effective in reducing harms. We have an opportunity with the levy— provided that the funds are administered in a way that is ringfenced and protected from conflicts of interest and industry—to really make a difference by doing some good-quality research and rolling out public health interventions that actually help.
Q9 Josh Fenton-Glynn: Can I ask a slightly broader question? I am sorry to have gone entirely off my list of questions, Chair, but electronic gambling seems to be a particular problem area. Are there any places that have interventions that work at a public health level with this kind of gambling? Do any countries get it right?
Professor Wardle: There are lots of examples of different countries with different implementation that actually fare far better than us. For example, there are mandatory deposit limits in countries like Norway, Spain and a handful of others. They limit how much people can lose within a period of time. Particularly in Norway, that has proved to be quite effective as part of a suite of measures for handling rates of problematic gambling.
I do not think we can look at one country and say, “This country is doing it perfectly,” but lots of countries are doing some things really well. None the less, we do have much better evidence for the efficacy of those mandatory pre-commitments—those deposit limits.
Q10 Josh Fenton-Glynn: It feels to me like the marketing teams are masters at identifying people who are susceptible, but they are not doing the right thing.
Lucy Hubber: That is a really critical point. When we work with people with lived experience, one of the things they tell us—we hear this a lot—is that it feels like there is no escape and that they cannot find a space. Either they are contacted, as Heather said earlier, and are constantly bombarded with, “We haven’t seen you for a while. Where are you? Have some free bets,” or they turn on the television and so on.
What we know is that that the gambling companies really concentrate in areas of greater deprivation. We see massive density of gambling-related products in those areas with people who experience the greatest harm from it. Therefore, you cannot walk down your high street without gambling shops, gambling shop, gambling shop. The gambling companies do that because of the concentration of the land-based gambling machines.
There are the other actions that we can take, but we can also do something just about that constant exposure of our population. As we know, less exposure, less behaviour.
Josh Fenton-Glynn: I think that phrase is going to stick with me: “there is no escape.”
Chair: Yes, I feel the same. Thank you very much; that was very powerful. We will go to Andrew George for a quick question, and then we will go to Paulette Hamilton.
Q11 Andrew George: I just want to ask a more broadbrush and perhaps ultra-naive question—this is not even going out to the helicopter view; it is possibly satellite level. Where does gambling sit within the range of comparative addictions that exist? Sam, from your perspective, why should we pay particular attention to the addiction of gambling, as against drugs, alcohol, sex, pornography, chocolate or any other addiction? Other than the financial consequences, what should drive us to look at this particular addiction more than others?
Professor Chamberlain: That is a good question. My response would be that we know that certain substances, like alcohol, have addictive propensity for some people. Partly, that is because of their biological effects on the brain’s reward pathways—they kind of hijack the pathways that we have anyway, which can lead to addiction. That is one biological way of trying to understand this.
In terms of the behaviours, there are certain behaviours where people can get stuck undertaking them repeatedly and struggle to stop. But of all those behaviours, gambling is the one with the most evidence of being a recognised medical condition. We see case reports of gambling addiction basically dating back to ancient times; this is not anything new for us. Gambling disorder is recognised in both the international classification systems used by mental health professionals. So, it is already widely accepted and fairly widely studied in that sense.
As to whether we should be thinking about other types of behavioural addiction, we need a lot more research into that. Without wanting to go off on too much of a tangent, although this is relevant, one issue is the internet and the role it plays in feeding different types of problematic behaviours, including gambling.
The World Health Organisation is now starting to recognise other potential behavioural addictions, like gaming disorder. That has been listed as a disorder, whereas in the “Diagnostic and Statistical Manual of Mental Disorders”, which is the other main system we use, is not yet recognising gaming disorder as a full condition, but it has listed it as something that needs more study.
Gambling disorder is a place to start, because of the very high levels of harms that it is associated with, but also because it has been widely accepted as a mental health condition.
Chair: We need to move on to other questions, but if you weave in later answers, that would be great. We now go to Paulette Hamilton.
Q12 Paulette Hamilton: Thank you for coming this morning. I read some information that said that Greater Manchester combined authority’s gambling harm strategic needs assessment found that people living in the most deprived areas are more likely to participate in gambling. We know that people from certain groups—such as young people, men or people who have other addictions—are most likely to take part in gambling.
In the area I represent, the situation is terrible. We have 10 shops on one street that deal with gambling of one type or another. The planning system just seems unable to stop them opening, and even when planning says no, they appeal higher up and seem to get what they want, even with all this evidence.
So my first question to you guys—I would like all three of you to be quite succinct, but to answer it—is, how can OHID and the NHS ensure that their prevention and treatment interventions appropriately address existing health inequalities? Can we start with you, Professor Wardle?
Professor Wardle: Sure. I believe it is particularly about giving more powers to local authorities and addressing the systemic power imbalances between local authorities and the gambling industry. I have been an expert witness for local authorities on at least two cases where they have been attempting to resist the opening of a new gambling venue. Each time, they essentially run out of resources, because they do not have the money to pay the legal costs and fight it in the magistrates court. In the end, they settle and put conditions on the licence.
The gambling operators do not have those kinds of restriction on them. It is a fundamental power imbalance between the local authority and the operator, and the way the current legislation is framed does not support the local authority. I welcome the comments about cumulative impact assessments in the White Paper, but it is not clear how they will be operationalised, so it is very much about waiting and seeing.
On the things that you spoke about, we absolutely know that there is strong evidence that there is disproportionate access and availability of land-based gambling opportunities, particularly electronic gaming machines, in areas of greatest deprivation. We see the gambling industry making a disproportionate amount of its money from those who are in the most deprived areas. It is systematic, and it needs addressing.
Professor Chamberlain: Professor Wardle has covered local authorities, and I agree with that. Clinically, we need to be making sure that our services have extensive outreach for marginalised communities that might traditionally be hard to engage in both clinical practice and research. One good way of doing that is to involve people with lived experience in the clinics. For example, in our clinic we have a peer support worker who can help us with reaching out to those marginalised communities. Of course, it is an ongoing process of trying to engage with different groups.
Q13 Paulette Hamilton: The point I would like you to come to is this. We are looking at prevention, and I think you have covered it well, but there are also treatment interventions. How can we appropriately address existing health inequalities through treatment interventions?
Professor Chamberlain: I suppose by focusing on treatments for gambling disorder. It is about making sure that people are aware of the services that are available. Every part of England now has a treatment service that provides evidence-based treatments and that can see people fairly quickly. That is the clinical side: making sure people are aware that those services exist and reducing barriers to access. That is something we have been working very hard on as a service, and I know that others have as well.
The other thing we need to bear in mind is that a lot of the clinical trials and research studies that are conducted often exclude particular marginalised communities. From a research point of view, when we are doing those studies, we need the funders to insist, whatever funding mechanisms ultimately arise, that due consideration is given to making sure there is diverse participation of communities in that research.
Q14 Paulette Hamilton: Right. I am going to stretch you a little bit: how is what you have described actually meeting the needs of local communities? I do not think it is, but you could prove me wrong. Also—this is really important—what lessons are being learned? We know what is happening in local authorities and local communities, and we have talked about what is happening clinically, but how are we meeting and addressing needs, or learning lessons?
Lucy Hubber: They are really important questions. There has been such a concentration on getting good treatment, and it is fantastic that, as Professor Chamberlain said, we have rolled out this very medical model nationally for those people who have a formal disorder.
The next thing has to be that we move slightly away from that medical model and understand that we need a more socially based recovery model for people who are not at that tipping point of disorder. That is where we need to bring in some of that cultural competence. We have to understand that gambling and the harms from gambling are one of the most hidden forms of addiction. We now all recognise that smoking is addictive; people own their addiction to smoking. We are also increasingly understanding the impacts of alcohol. This is why, coming back to Mr George’s question, gambling is the next one.
It is a question not of, “Why this?”, but of, “Why not this?” One of the reasons is that this is one of the least understood areas. Local authorities have been leading the way in terms of understanding the lived experience of people—understanding those barriers to coming forward, understanding the stigma that is attached to this. So many of our services are geared up around the bulk of users—white men under the age of 45—but what we are seeing is a huge impact on children and young people; people from black, Asian and ethnic minority communities, where the stigma is greater; and, increasingly, women, so we need to make sure we have services that are suitable for both genders.
The Greater Manchester work has been identified. A large number of areas, including Nottingham, are leading the way on doing health needs assessments, and then developing local strategies. What we do not have is a good, independent research system that is pulling the learning from that. We have lots of local learning and an increasing number of networks where people are sharing the good practice of learning. With the levy and its requirement around research, I am hoping that we will focus some of that activity on understanding not just interventions that work well, but how we organise ourselves and how we regulate.
We must make sure that both the treatment and the research are independent of the industry, so that we are getting truly objective and reliable information to support this work. We have come to the nub of the question, which is really important: we still do not quite know all the stuff that we do not know, but we are learning it. It is piecemeal right now, and not part of a systematic, nationwide approach.
Q15 Paulette Hamilton: Brilliant. My next question is, I think, a good one. We know that ethnic minority groups are at high risk. We know that neurodiversity groups also have problems with the research that is going on and the fact that they are not identified enough. My second question goes to Professor Chamberlain and Professor Wardle: what other areas do you believe are under-researched and should be prioritised? And then to each one of you: which area in the country do you think is doing a great job at the moment? I have identified Manchester as an area that is doing really well. Let us start with Professor Wardle.
Professor Wardle: I will start with the areas. We have the Greater Manchester combined authority, the Association of Directors of Public Health in Yorkshire and the Humber, and a similar consortium in the north-east. They are all doing brilliant work and leading the way in providing resources to support other areas. The common factor that underpins the work of those areas is the resources they have been able to gain access to. Each one has had somewhere in the region of £800,000 of investment to lead that work. This is where, with the statutory levy, we absolutely need to be thinking about what the processes and systems are to support other regions to follow and implement that excellent work. That is the thinking that I know other people will be doing, and I hope that that strategy will flow through with the levy implementation.
On underserved research areas, there are numerous areas in which we could all do more work, but I would like to take a bit of a step back and talk a bit more about the monitoring and surveillance systems that we have in this country. We have such limited insight on the range and extent of harms that people experience. If we look at comparative areas, such as drugs, we see that they have really sophisticated surveillance systems that are standardised with principles and protocols across Europe. They have direct and indirect measurement of harms. In gambling, we have two surveys that people argue over, and we do not have a nationalised monitoring system for harms. We do not understand how many people who are interacting with the criminal justice system or the NHS are experiencing harms, because we do not have that infrastructure available to us. Again, with the levy, there is an opportunity to develop that. I absolutely think that that is where we need to be investing some of our resources, because once you have that infrastructure, you have the insight. It provides the bedrock of excellent research and enables you to go forward.
Q16 Paulette Hamilton: Thank you. Professor Chamberlain, you do not have to repeat what has been said, but if you have anything to add, I would love to hear it.
Professor Chamberlain: Understood. I have nothing further to add in terms of the areas that are doing great work. All the areas have a lot of scope for improvement.
I will just briefly highlight a few key research areas for the future. One is longitudinal research to understand why some people are more vulnerable to gambling-related harms, and how those harms change over time. That could identify new intervention targets. We do not have such a good longitudinal study base in the UK yet.
Another area is research into public education campaigns, so that they can be evidence-based and independent from the industry. We need training curricula for professionals from public health and healthcare backgrounds to raise awareness, so that people can be helped when clients are identified who might benefit from early support. We need controlled trials of interventions.
Lastly, we need something like a register. We have a really good example in the multiple sclerosis register: people who have experience of multiple sclerosis can take part in research, and they are followed over time. It is a very positive citizen science approach, and I would love to see that for gambling behaviours in the round, so that people can join a register and contribute data over time at a very large, unprecedented scale. Again, that would contribute towards identifying why some people are more vulnerable and what we can do about it.
Paulette Hamilton: Thank you. Lucy, do you have anything to add, or are you happy with what your colleagues said?
Lucy Hubber: I think my colleagues have outlined things excellently.
Q17 Jen Craft: I would like to turn to the impact on children and young people. Lucy, you have mentioned several times the issue of children gambling. First, I am interested in the ages that this encompasses. Is it those just under 18, or are we seeing younger and younger people getting involved? I know there are some safeguards in place, but of course people can find ways around them in the age we live in.
Professor Wardle, you previously noted that the evidence around adolescent gambling behaviours is incomplete and probably outdated. Could you speak to the ways young people gamble? Does that fall within the 10% of the industry that is not covered by its own internal regulator?
Professor Wardle: One of my areas of work was looking at the intersection between gambling and gaming, and how you have more gambling mechanics embedded within video games. Again, it is part of the normalisation. You are training this generation that this is the kind of risk you take and this is the kind of reward you might get, and embedding it with no age restrictions into things that are freely available. There has been a lot of focus on loot boxes—I know they have been discussed in Parliament before.
Q18 Chair: We are going to come back to loot boxes later. What is the youngest age we are aware of?
Professor Wardle: I have interviewed children who have been engaging with these kinds of products from younger than 11—particularly the ones embedded within video games, because if you play the game, it is a feature. We have seen them in games such as Fortnite and so on.
Let us not forget that we are one of the few jurisdictions in the whole world that legally allows its children to gamble on electronic gambling machines. There is no age restriction for category D machines, although I know that, in the White Paper, there was talk of closing down some of those things when parliamentary time allows. Of course, that means that you get very young children engaging in certain forms of gambling.
Q19 Jen Craft: Do you think the way the gaming industry interacts and operates is creating a generation of people who are hooked on this behaviour? Lucy, you have spoken a lot about children gambling.
Lucy Hubber: Again, I am going to bring us back to the point that it does not necessarily have to tip into a disorder. We are seeing a massive change in the normalisation of gambling—we gamble on everything. As was said earlier, it used to be that you would go to a casino or put a bet on a horserace, but you can now bet through a game. It is continuous; gambling is part of everything in life.
We know that, although we are doing something to protect children in the real world, they are actually really unprotected online. The evidence shows that it is the online adverts that really motivate and prompt a behaviour change in children and young people. We are creating habits early on. We do not yet have the evidence. As Professor Chamberlain said, we need a study that looks at the long-term impact that this will have.
We know from smoking, drinking and dietary habits that behaviours that are formed young will increase and exacerbate with age, so it is sensible to assume that we are beginning to create problems for future generations, among whom we will see increasing levels of harm. It is really important to recognise that that harm impacts across people’s life chances: it impacts on their ability to complete their education, to hold and support a job, to maintain a family and to keep a roof over their head.
This harm is greater and more diverse and diffuse than we see in almost any of the other addictions, in that it really does go into every quarter of somebody’s life. I am very concerned about the impact we are having, which at the moment is poorly understood, although we are seeing increasing numbers. About a third of children aged 11 to 16 are using some form of land-based gambling, according to our local estimates, so it is not just about the online activities. It is hugely concerning.
Q20 Jen Craft: Are the current safeguards around gambling advertising sufficient to protect young people and children? If not—I see you are all shaking your heads—what needs to change?
Professor Chamberlain: It is shocking. Data from 2020 found that up to 20% of children and young people who gamble already have some degree of problem gambling, or are at risk of developing that. Parents are often shocked when I talk about this, because they may not be aware of what is happening—it is stigmatised and often hidden.
The key thing that needs to be done is to radically change our approach to advertising in this country. As I mentioned earlier, gambling adverts appear on TV sponsorships of football matches and on the front pages of most of our newspapers—except The Guardian, which decided to stop advertising gambling a while ago. Other countries have bans either on all types of gambling adverts or on those for the more damaging types of gambling during the day, so that they appear only after the watershed, for example.
Changing regulation on that front is sorely needed. That is what will make the difference, because children and young people are being saturated with adverts. Even though it is illegal for companies to deliberately promote to children and young people below a certain age, the adverts are effectively everywhere. That is the problem.
Q21 Jen Craft: Is there an issue specifically around social media for younger people? The way they consume data is perhaps different from how our generation does. Does more need to be done around how young people interact with things like Instagram and TikTok?
Lucy Hubber: I would add YouTube into that as well because—again, it is a generational shift—young people get a lot of their viewing there. The Gambling Commission acknowledges that online adverts are more likely to be seen by children and young people. Companies are knowingly pushing the online activity.
The sort of measures they put in place increasingly include putting in safer messaging where they think about young people, but we know that that is not impactful, and the adverts themselves will be filled with things that appeal more to young people. They are using the tactics that appeal to younger generations: bright and shiny things, cartoons, lucky charms, and all the kinds of things that draw young people in and attract them. It happens across the spectrum of online engagement for young people. Social media is one route, but we must not forget the other forms of online activity, such as YouTube, where young people spend a lot of their time.
Q22 Jen Craft: Is it fair to say that the gambling industry is targeting children to create a new customer base? Or is that going a stretch too far?
Lucy Hubber: We can see from the adverts that there are things that very much appeal to younger children.
Professor Wardle: In other jurisdictions, countries have banned influencer marketing, slot streaming and so on, to try to get a bit of a grip on this. We have just done a review of all European gambling, advertising and marketing legislation. Comparatively, Britain has one of the most liberal regimes with the fewest restrictions.
Q23 Chair: Have the interventions worked? Have you done work to show that banning improved the situation? That is what we would be most interested in.
Professor Wardle: That is the next step. At the minute, we are mapping the terrain.
Chair: You do not know yet?
Professor Wardle: We do have some evidence from some countries. It is an evolving landscape, but that will be the next step on for us.
One of the critical things is obviously the relationship between gambling and sports. We talk about football all the time, but it is not just football—it is e-sports, for example. We did some research into the sponsorship of e-sports teams, and 50% of them have gambling sponsors and betting partners. They have key e-sports professionals doing YouTube and TikTok videos promoting the brand that supports their team. Obviously, that has clear appeal to young people, and it is very overlooked.
Q24 Jo Platt: I am guesting from the Culture, Media and Sport Committee, so I am interested in the 2019 Digital, Culture, Media and Sport Committee report “Immersive and addictive technologies”. A subsequent report in 2023 specifically mentioned loot boxes, but the Government rejected that recommendation. Do you think there is still a case for regulation, and if so, what could that look like?
Chair: Professor Wardle, you mentioned that earlier—this is your moment.
Professor Wardle: Yes, I did. There is still a case for regulation. I have a very good colleague who would be able to provide you with the details. The self-regulatory approach has not been working; he has been monitoring that and he is currently writing papers on the issue.
It all comes down to how you define what gambling is. Is it betting on something for the chance of winning something that is of value to you? Within these games, the things in loot boxes have immense value to the people who play them. They are not just this digital commodity, and it is not just like a sticker or a toy. Actually, these objects have value in the games and they are part of the game economy. They can be shared or traded, and in some games you can take them outside the game you are playing and use them as collateral in other systems. The skins in the loot boxes can then be bet on skin-betting websites. We have longitudinal evidence that shows that skin betting among young adults is as risky as online slots, for example.
There is a case for much stronger regulation that—coming back to what I said before—does not rely on self-regulation and voluntary action from the industry.
Q25 Jo Platt: Lucy, you have mentioned loot boxes; what is your take on what we should be able to do?
Lucy Hubber: I would probably defer to Professor Wardle, given her expertise. It is absolutely about the forming of early engagement, and it does reach much younger children. It is a bit like going to the penny falls at the seaside when you are a child, and normalising some of that. The level of risk is not understood, so you change people’s risk threshold through it. Children and young people do not understand, at the same level as an adult, what they are risking. It absolutely needs to be controlled, but I defer to Professor Wardle on what might be impactful in that way.
Professor Wardle: Mr George asked why we look at gambling—this is a prime example of why. Look at the complexity of the commercial ecosystem that underpins the provision of these products. You have this intersection between gambling and gaming. It is a vast ecosystem with very powerful members and corporations that want to promote these products.
The same is true for the gambling industry itself. If the alcohol or tobacco industries had real-time instant access to every time you took a sip of alcohol or a cigarette out of a packet, imagine what they might do with that information. This is why gambling is so important to look at: there is no other similar substance that has that commercial power underpinning its provision.
Andrew George: In the last 20 years.
Professor Wardle: Yes, in the last 20 years.
Q26 Gregory Stafford: Before I ask some set questions, I want to follow up quickly on the point about children and young people. Where do you see parental responsibility coming into this?
Professor Wardle: It is a really interesting question. Obviously, there is a role for parental responsibility and teaching your children about the risk with these products. Equally, anyone who has children, as I have, knows that it is incredibly difficult to understand and monitor constantly all the different products they are playing with and all the different features that are embedded within games. That is why there needs to be more support and regulation. If your child is going online, you need to be able to trust that they are going into a safe environment and that they are not going to be exploited by these commercial entities. There is absolutely a role for parental responsibility and having these conversations but, equally, it needs to be supported by corporations not taking advantage of children and young people.
Lucy Hubber: It is so complex and moving so quickly. We all joke about not being able to programme our video recorders and all the rest of it, because the generations move so quickly. We must not enter into the industry narrative about placing the responsibility on individuals. There is actually corporate responsibility around how we make sure that the risk of engagement in gambling-related activity is understood. Most of the stuff embedded in games does not say, “This is a risk; are you sure you want to do this?” It just looks like it is part of the gameplay. How much would that flag? When they were young, I did not sit next to my children while they were spending 45 minutes on a video game. I trusted that the game I had bought would have the safeguards in place. We have to be careful—
Q27 Gregory Stafford: I kind of get that, but my parents did not sit with me and say “Don’t smoke” throughout every single moment of the day; they did not give me cigarettes. They did not say “Don’t drink alcohol” when I was 11; they did not give me alcohol. My point is that we have talked about banning smartphones, but why would you not say to your children, “I’m sorry, but you’re not playing this game. You are not having a smartphone until you are responsible”? It seems to me that we are over-egging the pudding.
Professor Chamberlain: There is a role for parental responsibility. From the research, we know that family background in relation to gambling and other addictive products is an important contributing factor to whether or not children develop the addiction later on. It is important to have a nurturing family environment where there is open discussion. I do think parents should place limits on, for example, whether their children engage in gambling or use the internet too much. The challenge for parents is the education around that. As a parent, what should you do? There are not really guidelines in place.
Earlier today I discussed online screen time for children and where the limit should be with colleagues from the Royal College of Psychiatrists. Actually, we do not know because the independent research has not been done. There are independent materials on the internet to help parents and give advice on these issues in practical terms, but it is partly an educational thing as well. I am not saying that we need to immediately roll out education programmes in schools or parenting classes, but we should work with independent organisations to develop them and show that they work, and then roll them out.
There is a massive gap in terms of education, but we need to ensure that it is not industry players who go into it. We have seen that already with education in schools, which is often run by charities directly funded by the gambling industry through voluntary donations. It is quite concerning that they are not evidence-based.
Professor Wardle: Can I add something quickly? It is really difficult for parents to take parental responsibility if, as a nation, we have underestimated the risk and scale of harms, and there is not that level of awareness of the actual risk associated with these different products. Over the past 20 years we have seen a very persuasive framing of, “This is a tiny minority of people. It is a few disordered people; the rest of the population are fine.” It is then very difficult to expect parents in that context—the normative, majority context—to be able to take that responsibility.
Q28 Chair: What would you compare it to? This comes back to my colleague’s question earlier. We are underestimating the harm. What is the comparator for a layperson—something that we understand? What is gambling as bad as?
Lucy Hubber: It is as bad as alcohol and substance use in terms of its wider social harms and its impact on people’s mental health. It is about that cumulation. But it is as yet unknown. There is a real complexity. If you were to say to your children, “Don’t smoke,” and then discovered that cigarettes were hidden in sweeties, you would say, “Oh, that’s terrible.” If you were to say to your children, “Don’t drink,” and then discovered that alcohol was hidden in fruit juice, you would go, “Oh my God, that is terrible.” Gambling is hidden and embedded. It is hugely complex. It is not as simple as, “Don’t do a, but you can do b,” because it is pervasive.
You also cannot see it in the same way. You will see your child staggering home from the park having had a little bit too much to drink; you will not know that your child is sitting in their bedroom gambling with money that they may or may not have. They may or may not understand what they are doing. They will probably knowingly drink in the park, but they might not understand that they are gambling and running real risk. That is some of the difference in this.
There is absolutely a place for parental responsibility, but we also need to make sure that our population is geared up to be able to take some of that responsibility. Some of that is about us beginning to articulate and explain that in a different way.
Q29 Gregory Stafford: I am not sure that I entirely agree, but we will move on. Just so that I understand your background and context, do you or have you ever gambled?
Lucy Hubber: I played the penny falls in Skegness last week.
Professor Chamberlain: I bought lottery tickets when I was much younger, but at legal age. I have invested in the stock market—some would say that risk-type products could be a type of gambling.
Professor Wardle: Yes. I used to gamble quite regularly, particularly on the horseracing. In fact, I was probably one of the earliest female adopters of an online gambling account. I had one in 2000. I do not do that very much any more.
Q30 Gregory Stafford: Why is it okay for you to do it but not for others?
Professor Wardle: We are not saying that it is okay for us and not others. What we are saying is that there need to be greater restrictions on the way in which gambling is provided, marketed and regulated. The gambling that I did was very low limits and I could take or leave it. Most people in Britain who gamble do so in a way very similar to the way that I gambled. Often, with a lot of the things that we are talking about, people would say, “Fine. I’m not so committed to this thing that if you make it a little bit harder for me I will absolutely go and search for something else to do.”
I would also say that I had the experience of being that person who gambled my last £5 and then found that I could not afford to buy myself dinner that night. For me, that was the moment at which I said, “I am not going to continue doing this,” because it was causing me harm. I was very fortunate that I was able to do so. It was not as pervasive as it is now. It is about recognising that there are different ways that people can experience these harms, and putting protections around people.
Q31 Gregory Stafford: I will let the other two witnesses answer the question but, in the context of the White Paper and what you have just been talking about—that, for some people, gambling is perfectly fine and you are not seeking to ban gambling—what are the top two priorities that you would like to see roll forward if the new Government were going to implement only two things?
Professor Wardle: Rolling forward, I would like to see a different approach to advertising and sponsorship than the one they are taking. We need much more severe restrictions and greater protections at a population level, particularly for children and young people, but also for those who are harmed. We need to not normalise this behaviour. We think gambling is normalised because we see it so much in advertising, but when you look at the data, you see that only 16% of the population have bet on sports in the past year. It is a minority behaviour, yet we feel it is a majority behaviour. It puts a very different complexion on these things.
I would absolutely look at restructuring the way we focus on advertising and sponsorship, and I would look at having greater regulatory restrictions and protections around a wider range of products. I welcome the focus on online slots, but we need similar protections on land-based slots and on online casino products, which all have a higher risk of harm.
Professor Chamberlain: I am not of the view that we should stop everybody gambling, in the same way I am not of the view that we should stop everybody drinking. But we should have harm-reduction strategies and try to reduce the negative effects of gambling through the ways that we have discussed.
Regarding potential priorities from the White Paper, I think that much stronger regulation of advertisements and sponsorship would make a big difference. The other thing is the levy but, as I alluded earlier, the critical questions are: who is going to administer it, and what are the safeguards to make sure that it gets to the right people and that the decisions are not influenced by people with vested interests?
Lucy Hubber: I am not sure any of us have said that we want a ban on gambling. It is about creating the environment to reduce the exposure that might lead to harmful impacts. For me, the two things to create that different environment would be managing and controlling the advertising and sponsorship, and ensuring independent regulation and treatment services.
Gregory Stafford: I had another question on the levy, but I will hand over to Joe.
Q32 Joe Robertson: What is a safe level of gambling?
Professor Chamberlain: That is a very difficult question to answer. One could take the view that gambling has become unsafe when a person is experiencing significant negative consequences from it. There are various ways of defining that and various measurement tools that one could use. For example, one could use an instrument that has been validated for measuring gambling-related harms. If a person is scoring on that, they are engaging at an unsafe level. But “level” suggests “frequency” or “amount”—that is important but so are things such as loss of control, the ways in which it is impacting different areas of life and so on. That is partly why, as I say, it is a complicated question to answer.
Professor Wardle: Let me add that some of our international colleagues—in 14 different jurisdictions—have looked at providing lower-risk gambling guidelines. That is essentially saying, “What is the level of gambling above which you are at heightened risk?” Their recommendations are to gamble not more than once a week and not on two different activities, and not to spend more than 1% of your income.
We do not have an equivalent evidence base for the UK, but that was based on 14 different countries that all came out with roughly the same recommendations. That is not to say that gambling below those levels is safe, but that is the point at which risk starts to increase. From what Sam has said, there are lots of different complexities and considerations that need to be taken into account when defining what is safe for an individual person based on their context, circumstances and experiences.
Q33 Joe Robertson: The NHS health survey for England of 2021—which I think was the last such survey we have—identified 0.3% of people as being engaged in problem gambling. Is that a useful measure, bearing in mind it is the NHS’s own survey?
Professor Wardle: Yes and no, because in 2021 the health survey for England had to change its methodology, and it was capturing data collected during lockdown, so its estimates were much lower than previous health surveys. In fact, the 2021 health survey itself said not to use it to look at trends.
It is important to think about what is being captured in that statistic. Within that statistic, you are using an instrument. That is often something called the problem gambling severity index, which asks nine questions about a range of behavioural symptoms and some adverse consequences experienced from gambling. However, it does not capture the wider range of harms that people experience, or the harms to others.
The Gambling Survey for Great Britain included a much wider range of questions on adverse consequences from gambling, and we saw from that that an additional set of harms are not being captured by the questions in the health survey for England. So there is an additional set of people who are being missed by some of those metrics.
Yes, it is useful to capture some of this data, but it is also really important to recognise that the metrics are not capturing all the consequences and harms that are experienced. For that reason, we say that negative experiences of gambling have been undercounted and under-represented.
Q34 Joe Robertson: If a lot of the problem gambling is done at home, covid would surely have been a time when the figure could have been expected to be higher?
Professor Wardle: No, because you had about five or six months when land-based gambling was closed, and although we talk a lot about online gambling, land-based gambling is still really important. It captures about a third of GGY. Actually, what was really interesting during the lockdown period was that it was the first time when we saw downward movement in problem gambling estimates, through the Gambling Commission’s statistics, and that shows a relationship between supply and the movement of harms.
Q35 Joe Robertson: What should the goal of a prevention strategy be? Should it be to reduce gambling within the population, or should it be targeted more at the specific harms for a small percentage of people who gamble?
Professor Wardle: That is a really important question. To understand this, you really need to understand the nature of the relationship between population consumption and harms. Is it the case that the more that a population does of this thing, the more harms there are? We have some tentative evidence from Great Britain that suggests that that is the case. And once you know that it is the case, your focus is on shifting the population consumption curve downwards rather than just focusing on the so-called disordered few. I could see Lucy wanted to come in there.
Lucy Hubber: I could not agree more. If we just focus on the people who have already reached the threshold of being in whatever the top percentage is, we are missing that much larger proportion of people who will be experiencing harm on the way to getting to that threshold. I think that we have to take a population approach to helping people understand—as we do with almost all the other risks—how you balance the harms and benefits of the activity. We have to take a population-based approach, and that has to have a number of different factors to it. There are roles for treatment. There are roles for support. There are roles for awareness-raising activity. But there is also making sure that we have the independent regulatory approach that sits behind, to make sure that the environment in which all that is operating is well sighted.
Q36 Joe Robertson: This weekend we have probably the biggest mass gambling participation event in the UK, going back decades—the grand national. I guess most people would agree that that is probably low- risk gambling, given its cultural significance, but it is where a lot of children may first witness this idea of putting money down.
The problem I am identifying is that human beings are natural risk takers. Our entire banking system—our entire economic system—is based on gambling. The Chancellor has to make decisions on borrowing based on gambling, prediction and running risk. We need to be able to target the particular activity within gambling rather than gambling itself. This is what I am trying to tease out: whether that strategy is about addictive behaviours within a wider gambling sector, which is not in and of itself harmful, and whether we should be producing a kitemark-type system for companies that are providing a safe activity that is lawful.
Professor Chamberlain: Part of the problem with that approach is that many companies in the sector may have a range of products, and if the aim is profit, there will be a natural tendency to get involved in more risky or more harmful products, because we know from research that a sizeable proportion of profit for gambling companies is from people who have the addiction.
I will give an example: the National Lottery is run by a company under a licence that might not generate profit, but the same company is making money in other countries, for example, from addictive products, as you would expect a gambling company to do. I think it is unlikely that you would have a particular company that was engaging only in very, very low-risk types of gambling.
Professor Wardle: To come back to the point I made earlier, this is why it is really important to think about regulation of products based on their propensity for risk and that is proportionate to that risk. We have really good evidence on which products are the most associated with risk. They are the fast, continuous formats of gambling—your online casinos, their offline counterparts, your electronic gaming machines and your slot machines. The White Paper deals with online slots only, and to me that is one of the big gaps in it.
Q37 Joe Robertson: As we transition from a voluntary levy to a statutory one, how can we capture and keep the third sector knowledge in treatment? It is largely the third sector that has been providing treatment for those who are suffering harm from gambling.
I also want to touch on the point you made, Professor Chamberlain, about data gathering helping companies to target people. How can we use the levy to address that targeting of people who have identified themselves as being at risk, and ensure that the third sector knowledge of charities and so on is retained?
Professor Chamberlain: That is a really good question. First, the levy needs to be ringfenced and shielded from conflicts of interest in relation to the industry. You are quite right that there is a lot of expertise in the third sector. For example, we as a service work with GamFam, which is an independent charity. It has deliberately been avoiding taking voluntary funds from the industry. It is doing great work, and it is evidencing what it is doing. Many third sector organisations out there would be really keen to work with the NHS, for example, if the NHS is responsible for providing treatment.
The public health element is also important. That may sit separately with OHID, or however it is administered, but there are principles across it that relate to each funding stream, and they need to be really tightly controlled at each level to think about minimising conflicts of interest.
The funding needs to be ringfenced. For example, if you divert money to prevention or treatment through a levy, unless that is ringfenced at every stage—for healthcare it would be from what was NHS England, through to the integrated care board, through to the NHS trust—there is a risk of it being diverted away from gambling. I will defer to my colleagues, but I think you would see that for public health as well. If it is not guaranteed and ringfenced to tackle gambling harms, it might well end up being siphoned off to address budget shortfalls elsewhere.
Q38 Chair: I have one final question. I have noticed that all three of you at various stages, including in the very last answer, have mentioned conflicts of interest and vested interests in the way that the wider industry is engaging with this space. I am really struck by that—it was in almost every answer. Can you outline for us what that looks like? What are they doing? What should we be live to?
Professor Chamberlain: As a researcher who has never taken funds or voluntary donations from industry, what I have seen in this field is that it has been really difficult to do research into prevention, policy, education or treatment, because for decades in the UK we have had a situation where the only funding of any significance available to do those activities has been from the industry, through voluntary donations. In parallel, there has been a lack of funding from our trusted funding bodies—charities like Wellcome, the MRC and the NIHR have tended not to invest in research into gambling-related harms.
Q39 Chair: Does it necessarily follow that because the money came from that source, the research is not independent and done properly? I am trying to understand this.
Professor Chamberlain: I will pass to Heather in a moment. Certain organisations do have rigorous safeguards in place. If Wellcome is administering funds, that is a reputable organisation that thinks about conflicts of interest and is not closely linked to a particular industry. In pragmatic terms, the industry has been giving cash to one massive charity that has then been handing that money out to various organisations. I am not saying that all of that work is invalid, but many of the good researchers in the field of gambling would have not been prepared to take that money, because of ethical and other concerns. There has been a dearth of good-quality research over the last few decades.
Professor Wardle: For full disclosure, up until 2018 I did take funding from GambleAware, and I did quite a lot of work for GambleAware. That was prior to joining academia. Reflecting on those experiences, I would say that it is not necessarily about the way I did my research, but about how the research priorities and questions were determined in the first place, how they then reflected particular viewpoints and how the industry was consulted on what those questions might be. Then it was about control of the messaging from the outputs and the communication strategy around that.
Q40 Chair: So they would have an input in how you discussed a paper, for example?
Professor Wardle: Absolutely. I remember quite clearly having a conversation with the chief executive of my funder where I was asked to remove a particular key finding from a press release. For somebody who is in—
Q41 Chair: Which funder was that?
Professor Wardle: That was when I was with GambleAware. It is these kinds of things. It is not just about whether the research itself is biased—the research can be done quite well—but about the soft power that sits around it that shapes what research is done and how it is then communicated. You do not have that with the funding councils that Sam has talked about. I have since got a fellowship grant from Wellcome, and have had none of these experiences. I have worked for NIHR—again, none of these experiences. It is those kinds of thing that you also have to pay attention to, but that researchers do not talk about, so it is very difficult to actually evidence how these things are influencing the evidence base.
Lucy Hubber: Just to bring it out of research and into the real world a bit, I agree that we also see what Professor Wardle has just explained in the framing of the narrative around where treatment should sit. Again, it is about the personal responsibility—that that person has a problem—and we are not moving into understanding how the industry is contributing, too.
Q42 Chair: Would they bat away research questions that were about that? Is that what you are insinuating—that there are certain areas that they would not allow to be funded? Is that fair?
Professor Wardle: I think it is about the choice of the research question and how that research question is framed. One of the packages that I worked on was trying to understand the impact of FOBTs—fixed odds betting terminals. This is going back over 10 years ago. In the end, the way the research questions were framed very much moved us away from really understanding how harmful these products might be and towards looking at whether you can identify people who are playing in a harmful way.
Q43 Chair: If you did the questions that you thought were most useful as a researcher, would they pull the funding? Is that the insinuation?
Professor Wardle: It is commissioned funding: the research questions are set, and then they tender for that project.
Chair: I understand. Thank you.
Professor Chamberlain: I recommend the work of Jim Orford, because there are a lot of complexities in the area that you raise, and he has written a lot on that. I would also highlight what we historically saw with big tobacco in relation to how the narrative was influenced by funding.
Q44 Chair: Do you see a direct parallel between how big tobacco operated and how gambling companies are operating?
Professor Chamberlain: Yes.
Professor Wardle: Yes. We cover that in our reports.
Chair: That is very helpful. We will certainly take that into consideration. I thank our first panel.
Examination of Witnesses
Witnesses: Professor Henrietta Bowden-Jones, Andrew Vereker and Tim Miller.
Q45 Chair: Welcome to the second panel—much appreciated. We are running slightly behind, so we are all going to keep questions and answers snappy, aren’t we? We are also going to start by asking our panel to introduce themselves and what they do.
Tim Miller: I am Tim Miller. I am executive director of policy and research at the Gambling Commission, and I also oversee the Gambling Commission’s work in implementing the Government’s White Paper on gambling.
Professor Bowden-Jones: I am a national adviser to NHS England, I am a psychiatrist with a clinical background, and I set up the first NHS gambling clinic in this country, in 2008, following my doctorate at Imperial College in neuroscience, in addiction, which led me to think it was required.
Andrew Vereker: I am Andrew Vereker. I am a deputy director at OHID in the Department of Health.
Q46 Danny Beales: We heard compellingly from the previous panel, which I know you sat in on, about the need for shifting awareness about the realities of gambling, the harms, and for breaking down stigma related to approaching services for support if people are struggling with gambling addiction. The Government have also talked previously about this cultural shift. Do you agree that cultural shift is needed? If so, how do you plan to support it in your work?
Professor Bowden-Jones: Thank you for that great first question. I started looking after people with a gambling addiction at a time that coincided with the liberalisation of gambling through the 2007 implementation of the 2005 Act, so I have been living it for almost 20 years, witnessing the changes in people’s behaviour and the harm. Early on, in 2009, I realised that things were not looking great. Queues and queues of people in Soho wanted to spend their lunchtimes betting on fixed-odds betting terminals. Since then, really, I have been campaigning for a change.
The work that led to the White Paper—the collaboration between clinicians, lived experiences and researchers—is a momentous moment for us, a new era. I believe it is time to change things. It is time for a more transparent era. You have been hearing a lot about conflicts of interest and the importance of having transparency, but from my perspective as national adviser, it is perhaps also an opportunity for the country to unite in providing the help that is needed.
Someone mentioned the voluntary sector, and I believe that now is an opportunity for NHS England to commission the whole of the national treatment services in absolute collaboration with the voluntary sector, within which thousands of people have been doing great work in gambling and want to continue doing it. This is an opportunity to share data and finally have a snapshot of the country at any one time—who is presenting for help, and in which areas? Also, as Paulette mentioned, how do we know what is happening here or what we are doing to tackle inequalities?
To me, the dream has come true, because by the time our systems are able to collect data in the same way from every single treatment provider across the nation, we will have a very good idea of where the money should go and where there is enough money for the moment, so we just expand at the usual rate. The dream is to identify pockets of harm, populations in which harm is rife, and to understand the causes by using the money invested in research in that independent way to address properly the questions that will arise and to make people’s lives easier. It is a horrible addiction. As I said, I have treated thousands and thousands of people, and not enough has been said about suicide and suicidal ideation.
Q47 Chair: What are the rates in this country compared with others?
Professor Bowden-Jones: In this country, we know there are anything from 300 to 500 suicides a year.
Q48 Chair: Is that higher or lower than other places? Do we know?
Professor Bowden-Jones: I have no idea. It is difficult for me to say. I would like to talk about this country, where I have an understanding of the fact that we have not conducted or sponsored enough research into this area. We have a need to understand fully, and there are ways of doing it through data sharing, if we do not allow industry to control all its data without sharing it with researchers. If you allow transparency, you allow us to identify vulnerabilities. You may prevent many lives being lost if you understand patterns of high-risk play, the inability to afford gambling and what it means to lose your home.
Q49 Danny Beales: That is really helpful. Thank you. Andrew and Tim, do you have anything to add? That was quite a comprehensive response about the things needed to support that cultural shift. Is there anything further that you think is needed to enable it?
Tim Miller: Yes. On the need for change, it is worth reflecting that we are probably slap-bang in the middle of arguably one of the biggest periods of regulatory change and reform since the Gambling Act was passed. A rare moment of cross-party consensus fell in behind the gambling White Paper. From our perspective as the regulator, we are now two years into delivering a lot of that change. A huge amount of change is already in place. We have implemented financial vulnerability checks to identify risk at an early stage. We have made changes to direct marketing to prohibit cross-selling from lower-risk products to some of those—
Q50 Danny Beales: You are telling us what you are already doing. Do you think that what you are already doing is enough to enable the cultural shift, or do you think more is needed? You are telling us what has happened.
Tim Miller: Absolutely, more is needed, because we are only partway through delivering this programme of reform. As earlier witnesses have said, this is a landscape that has been rapidly changing over the last few years and will continue to change. From our perspective as a regulator, we are constantly shifting and adapting to those changing risks.
A good example of that, which has been a huge change in how we operate as a regulator, is the risk that comes from illegal overseas websites particularly targeting the most vulnerable consumers here. We have seen a trend of people who have often taken the very difficult step to self-exclude from gambling, because of the challenges they face, actually being targeted by illegal websites based overseas. What that has meant for us as a regulator is shifting from some of the traditional ways of regulating the industry here at home to having to work, for example, more closely with the likes of Google. Over the last year, for example, we have had about 80,000 URLs of illegal websites taken down by Google, where we have found examples of overseas sites targeting particularly vulnerable consumers. That illustrates the need for us to be constantly adapting and changing to the risks that people might face.
Andrew Vereker: We heard compelling evidence from the first panel about the wide-ranging negative effects that gambling can have. You asked whether we should do more. The Government’s manifesto had a commitment to strengthen protections from a Department of Health/OHID perspective. Through our health mission, we are committed to shortening the time spent in ill health by preventing harms before they occur.
In that context, I think the levy is a real opportunity, as the previous panel said, to improve treatment, to enable high-quality research and to support effective prevention activity. There is definitely more we can do through the levy. It is not all about spending. I would also draw the Committee’s attention to the clinical guidelines published by NICE earlier this year, recommending that health professionals ask questions about gambling at health checks when people come into contact with the health profession. That is a really welcome step to make sure that people have support and access where they need it.
Q51 Danny Beales: We heard quite compellingly from the previous panel about the role of advertising and marketing. Do you think the fact that 55% of Premier League clubs are now sponsored by gambling companies, and the proliferation of online advertising in all the forms we heard about, is aiding cultural change, improving understanding and breaking down stigma around gambling addiction? Or do you think it is likely to worsen the situation?
Chair: Are you asking Andrew?
Danny Beales: It’s an open question, really, to whoever feels most expert to answer.
Andrew Vereker: I would emphasise again that the Government have a manifesto commitment to strengthen protections generally. I recognise those concerns about advertising, which is slightly out of scope of the levy. OHID has just been appointed as the prevention commissioner, and we are working with DCMS, which is the lead on regulation, to consider how we can best deliver against the Government’s manifesto commitment and our health mission.
Tim Miller: From our perspective as a regulator, we gave formal advice to the Government on advertising around the time of the White Paper—we are not the regulator for advertising, but the ASA is clearly a close partner. We said that there needs to be a focus on ensuring that gambling advertising is much less visible and accessible, particularly to children, but also to other people who might be vulnerable. Some of our specific recommendations, particularly around sport, include a ban on front-of-shirt sponsorship, which I think is being taken forward on a voluntary basis.
Danny Beales: I understand that 55% of Premier League clubs are now sponsored by gambling companies. It does not seem like many are volunteering at the moment.
Tim Miller: The voluntary ban is due to come into effect in 2026-27. We also said that, in addition, you should look at restricting the amount of advertising in stadia themselves—the electronic hoardings.
Q52 Danny Beales: Have you any sense that there has been a step down towards that deadline? It feels to me like they are stepping up, rather than stepping down.
Tim Miller: Like with everything in the White Paper, we will need to properly evaluate the impact of any of those changes. If you look overseas, where some of these sponsorship bans are already in place, Italy and Belgium being two examples, we have seen that football clubs are finding any opportunity to try to circumvent those bans. For example, they no longer have a formal betting sponsor on their shirt, but they take one of those companies’ other brands—a lot of them have a sports news website that channels customers to the betting website—and use it for sponsorship instead. If you are going to put these things in place, you need proper evaluation to make sure you actually deliver the outcome you are expecting. We will have to see how effective a voluntary ban shows itself to be.
Q53 Danny Beales: We have heard that the level of harm is comparable to alcohol—that was the previous panel’s summation. Professor Bowden-Jones, you have talked compellingly about the level of suicides related to gambling. Do you think we should be looking at similar restrictions on the advertising and marketing of gambling, particularly to children?
Professor Bowden-Jones: I am glad to have a moment to contribute my bit. From a lifelong clinical perspective, I believe that, with the normalisation of gambling in sport, we are in a position that feels wrong. I run young people’s gambling services, as well as a national clinic and the National Centre for Gaming Disorders, which I started in 2019 for the NHS. It is the only centre. I have constant reminders every day that people in this country are nowadays pretty much unable to differentiate between true sport and gambling.
Q54 Chair: Does that explain the difference? We heard from the earlier panel about the 0.3% problem-gambling response to the NHS health survey.
Professor Bowden-Jones: I was talking about the perception in this country, and not just among young people. I see a lot of old people.
Chair: That is what I am asking.
Professor Bowden-Jones: This is not about explaining the prevalence and the reason. There are many other reasons why we have the prevalence that we have, but I think that banning front-of-shirt advertising, and not having advertising in sport generally, would do us a lot of good. I feel very strongly about that, as will most of my colleagues you will be speaking to. Sorry to have interrupted, but I wanted to make that point.
Q55 Chair: It is linked, because 0.3% does not feel like a big problem, but it is a big problem. That survey comes from NHSE, and you work with NHSE. Should we be revisiting that figure, or do you stand by it?
Professor Bowden-Jones: I am the clinical adviser to NHS England, and I had no involvement in that 0.3% figure. What I know is that Professor Wardle, who is a research specialist, has stated that other prevalence studies show 2.5%, which I think is much more realistic.
Q56 Chair: So you would agree with that?
Professor Bowden-Jones: I absolutely do.
Chair: I just wanted to get under the skin of that.
Q57 Danny Beales: Tim, would you like to come in on that?
Tim Miller: I would, because we collect the official statistics on this issue. Last year, we launched the Gambling Survey for Great Britain, which is the largest survey of its kind anywhere in the world. It gave us, in terms of people scoring 8+ on the Problem Gambling Severity Index, a rate of 2.5%.
What is important to say is that it is a new methodology, so it is bedding in. However, what we felt as a regulator was that relying simply on the health survey did not give us a good enough or contemporaneous enough picture. What we were finding was that it was taking a long time for that data to come through. It was being done piecemeal in different parts of Britain. I recognise that health is a devolved matter, but we are a Britain-wide regulator, so we are now building a much more comprehensive picture of harm and prevalence across Britain.
Q58 Andrew George: In view of the time, I will direct this question to Henrietta. There has already been a reference to the NICE guidelines, which were published only a couple of months ago. Are they sufficient? Are they welcomed? And if there are issues about the implementation of those guidelines, what are those challenges and how can they be overcome?
Professor Bowden-Jones: Thank you for asking about such an important topic. Just to give you some context, I had no guidelines when I started the first NHS clinic; I had to rely on American research data to understand what treatments might be helpful. I then based my work on the Monash guidelines, which were very basic compared with what happened later in England—
Q59 Andrew George: Sorry, which guidelines?
Professor Bowden-Jones: They are Australian guidelines from many years ago.
There was a real need, and I am very grateful to the people who campaigned—including Gambling with Lives, which led the campaign—to get the NICE guidelines. I was the psychiatrist on those guidelines.
The reason why these guidelines are so important is because the levy is a lot of money. Every year, an enormous amount of money will be allocated to this disease and to fighting the harms, so we need to ensure that as treatment providers—I am talking about treatment now, but this also applies to prevention and research—we are accountable for how we spend the money. We are also accountable to our patients. We treat them with evidence-based treatments that we know have been deemed to be working.
As always when you have an area that is so understudied—the hidden addiction; the addiction that no one really has cared about for a long time—not enough research really existed for the NICE guidelines to be inundated with great research. The NICE guidelines have done their best to identify gaps.
Professor Chamberlain mentioned the need for randomised control trials, which is urgent. If I give someone with a gambling disorder only CBT, or CBT plus naltrexone, I want to know, first, how quickly they will get better. Secondly, I want to know for how long they will stay gambling-free. Is it six months? Is it three years? Is it lifelong? All of this information is needed for me to sit here as a national adviser and say, “We are doing a good job, and the job that you have paid for will continue to exert a positive influence on the population in the long term.” NICE guidelines were needed. I am grateful that NICE took us on, because there is a long queue for NICE guidelines. I think they understood enough about the harms to dedicate time to this.
I believe that from the NICE guidelines, as my colleague Andrew Vereker mentioned, there will be an implementation of other activities, such as making sure that people in primary care ask about gambling and making sure that we train people to do the job they are being paid for with gamblers.
Therefore, if you are a patient, at whatever end of the spectrum you arrive—whether you are arriving with a bit of a worry about your gambling because you have not paid your tax, or whether you have a raging gambling disorder and you have lost your family home—you will get the right help.
Q60 Andrew George: Is the 50% split, in terms of the resource going into treatment, the right level? I ask because it sounds to me like there is a lot of experimentation going on within the treatment itself.
Professor Bowden-Jones: Not experimentation, no. We know our treatment works—
Andrew George: Or randomised trials?
Professor Bowden-Jones: Sorry, a randomised control trial means we are not sitting on what we are doing, feeling that we are doing the best we can. It is a constantly dynamic system that allows new interventions to be evaluated and allows you to know whether it works the same way if you treat people individually or in a group. That is not experimentation.
Q61 Andrew George: I understand that, but there is still a lot of uncertainty as to which is most effective in terms of treatment.
Professor Bowden-Jones: No, we know that cognitive behavioural therapy and some pharmacological therapy is helpful. I would not call it uncertainty; I would say that we are going to build on what we have. I sit on the WHO expert group, and in England we are doing a fantastic job. We should be thankful, really, to this Government and to all the bodies involved for allowing us to be doing this great job. We have 15 clinics across the country, which is a very good position to be in.
Q62 Andrew George: Finally, you mentioned the wealth of money coming in through the levy; are you saying that the resource is sufficient for this? Is there sufficient resource for those people who need to access treatment and support?
Professor Bowden-Jones: That is an important question. I believe that today that money is an extremely good starting point. I know that every five years things will be reviewed. I think there is enough money for us to properly implement what we need to in research, prevention and treatment, and for us to understand whether we are meeting all needs. Remember that we still think that under 5% of people who need treatment are accessing it. Let’s say that in two years’ time everyone decides to access treatment; then I might change my answer if you interview me again. But for this year, yes.
Q63 Andrew George: In terms of the population of people who are suffering from this addiction, what proportion overall are seeking to access treatment at the moment?
Professor Bowden-Jones: Relatively recent research states that it is still about 5%. Say that it was 10%, we would still have a long way to go. That brings me back to the earlier question: how do we reach the people who are hard to reach?
Chair: We are coming to that.
Q64 Ben Coleman: We have had some interesting responses. I would like to ask this to Professor Bowden-Jones, and perhaps bring in the other two panellists. NHS England has been appointed the commissioner of treatment services, but it is being abolished. There is also a huge role for public health at a local authority level with gambling as well as alcohol and drug misuse. Where should commissioning sit in the future? Should it be more localised, and what would the risks and opportunities be of doing that? I will ask you first, Mr Vereker.
Andrew Vereker: Ministers have made their statements on the future of NHS England, and the Department, NHS colleagues, NHSE colleagues and DCMS are all working through what that means. I don’t have definite answers.
Q65 Ben Coleman: What do you think would be best for people suffering from problem gambling?
Andrew Vereker: Right now, I would say that I am fully focused on delivering the prevention commissioning role from within OHID. That is immediately in front of me. There is a real opportunity from this year, with the levy, to do something genuinely different and to put funding on a more stable footing. What the centre looks like in the future is something that will have to wait to be determined. If you are asking about the role of place, and national versus local, it is an incredibly important question to raise. With prevention, we will need to consider not only population-level interventions and initiatives—as the panel raised earlier—but regional and local initiatives, supporting all of the good and best practice that is out there in the system.
Professor Bowden-Jones: Thank you for giving the overview. We have got a couple of years, as you know, to fully implement how it will look, and the work has just started. But we have already been working extremely closely with DHSC, and their knowledge and expertise in the world of gambling harms is fantastic. Having lived through it myself, in terms of working with them for so long, I have no anxieties at all in relation to the delivery of the treatment that we have pledged to deliver, despite NHSE needing to hand over to a differently shaped body.
Q66 Ben Coleman: When you say that you have no difficulties, one understands that GPs are relatively uninformed about this, although some GPs are excellent.
Professor Bowden-Jones: You were just asking me about the ending of NHS England. I can talk to you about primary care, if you want to change and move on to that.
Ben Coleman: Yes, let’s do that.
Professor Bowden-Jones: Okay. Just going back to the original question, you asked about national oversight. It is very important to have very clear oversight of who needs the money urgently, who is doing great work but has enough, and where the pockets of populations are that require extra. If you have national oversight, you are able to do that in a way that I don’t think you can if you work in silos, as we have done a little bit in the past. Primary care has an enormous role to play, and we are planning to work very closely with primary care. We have advisory committees that will feed into all sorts of different levels of boards, importantly including the advisory board to DCMS; primary care will have a big seat at the table.
Q67 Ben Coleman: When you talk about the advisory board, it is very interesting. We have the gambling levy programme board, on which the Department of Health and Social Care will sit, and you will also have the advisory group to the board. Presumably, you think that the Department of Health and Social Care should sit on that, but should we also have separate public health representation on the advisory board? There is a distinction in my mind between the NHS, public health and local authorities.
Professor Bowden-Jones: I agree. I would always say that you can do no harm by bringing public health to the table in any committee.
Q68 Ben Coleman: When you say “no harm”, would you actively advocate for it?
Professor Bowden-Jones: Yes, absolutely. We would not be here without the public health approach. We advocated for that in the Lords at their initial review, which really changed things.
Q69 Ben Coleman: Andrew, would you also expect to see yourselves or public health directors represented directly in the gambling levy advisory group?
Andrew Vereker: The first thing to say, as you alluded to, is that the formal governance that will oversee the levy will include the Department of Health and Social Care, so we will have a seat at the table there. Both Ministers and officials will have oversight of the levy and sign off the allocations. I don’t think the advisory group, which DCMS is setting up, is being defined, but I would expect it to have a range of voices that is sensible.
Q70 Ben Coleman: My question to you is not perhaps asking for such a broad, political answer. Do you think it would be helpful for the advisory group to have clear, direct representation from public health professionals, such as your organisation or the Association of Directors of Public Health?
Andrew Vereker: OHID is part of the Department of Health and Social Care, so we will get a seat at the table there. I definitely think it would be sensible to have a public health voice in the advisory group.
Ben Coleman: Directors of public health, for example.
Andrew Vereker: But that is still to be worked through with DCMS.
Q71 Ben Coleman: I will ask, if I may, about the third sector. Most of the support and treatment happens outside the NHS. What do you think the third sector’s role will be in the new commissioning system, Professor?
Professor Bowden-Jones: Very, very important. As you say, it has been treating far more people than the NHS, and it has been doing so for many years. When I set up the first NHS clinic, I was fully reliant on very wonderful and helpful colleagues in the voluntary sector to teach me all they know about the system here. I also learned from international colleagues, but it really was the passion and commitment of the voluntary sector here. The plan is to collaborate fully, and the majority of people will continue to be seen by the voluntary sector. The thing that we are going to focus on, which I am very excited about, is my vision of the training being shared by all, so that the training of clinical governance and suicide prevention—all the things that are so vitally important—is shared by the voluntary sector and the NHS.
Q72 Ben Coleman: In terms of sharing, all that will require funding. I think we have touched on ringfencing, but how can we ensure that funding, whether it is through the public health grant or whatever the NHS does, is ringfenced to tackle problem gambling?
Professor Bowden-Jones: Until this morning I had no anxiety about ringfencing. This is what we were promised, and we worked hard to get the White Paper. This has come through, and we are delighted with the fact that it is ringfenced. I would like to alleviate your anxieties, as I don’t think there is any way that it is not ringfenced.
Tim Miller: The Gambling Act is clear that levy funding has to be used for purposes in connection with the licensing objectives in the Act.
Q73 Ben Coleman: When it comes down to directors of public health in the local authorities, how can we be sure that they will be implementing measures to support problem gamblers, using money from that?
Professor Bowden-Jones: I am sorry for talking too much. I will hand over shortly, but I think it is about transparency and accountability. That comes down to sums, as well as outcomes.
Andrew Vereker: I don’t have much more to add.
Chair: Fear not; we have plenty of questions for everyone.
Q74 Ben Coleman: When you say “accountability”, who will be holding the commissioning services accountable? Will they be reporting regularly? What happens with the 150-odd local authorities across the country when it comes to public health interventions for gambling problems?
Professor Bowden-Jones: It depends on how the money is being spent. OHID will be in charge of overseeing accountability for the delivery of services in commissioning prevention. Equally, I cannot tell you exactly what the body will look like, but the new incarnation of NHS England will do that for treatment. Research is highly relevant, too. We need to really understand how the different commissioners of different types of research—genetics, neurobiology, randomised control trials and all sorts of other stuff—end up being overseen. Is UKRI going to oversee it all? That is one of the things that we will be reassuring the nation about.
Q75 Ben Coleman: I was struck earlier by the fact that GambleAware was effectively vetoing certain questions, or not allowing them to be asked, in research that was being undertaken. Who will be ensuring that the research is wholly independent? There is a bit of tension between the industry representative and the health representative in Government. How much are we going to be involved in ensuring that the DCMS makes sure that the questions are neutral and the research is independent?
Professor Bowden-Jones: In relation to research, I 100% guarantee that there is not going to be any industry influence on the £20 million a year—
Q76 Ben Coleman: Do you see a tension in Government between DCMS, as the representative of the industry, which contributes a great deal in taxation, and the Department of Health and Social Care, which is trying to help people with problem gambling? Is there a tension there when it comes to supporting research through, for example, the programme board and the advisory group?
Professor Bowden-Jones: I will leave Tim to answer in relation to his area, because that is a separate pot. However, in terms of research that is independent and free from industry influence, in order for us to fully understand and allow researchers to deliver their message, there will not be any problems with industry interference in relation to that £20 million. However, there is also a different type of research happening, which is Tim’s area.
Tim Miller: As someone who has worked closely with Government on these issues for a number of years, that has not been my experience. The reality is that I have found a tremendous amount of overlap between what DCMS, the Health Department and the Home Office are looking for. It is worth remembering that although we are the statutory regulator and are subject to the licensing objectives, the Secretary of State for Culture is also subject to those licensing objectives, which include protecting children and vulnerable people from harm. There is absolutely a coming together of interests. Clearly, Government have to be mindful of the totality of the public policy agenda, but it would be wrong to say that DCMS does not focus on harm; that has not been my experience as the regulator.
Chair: Thank you. That is very clear.
Q77 Alex McIntyre: I am conscious of time, so I shall direct my questions to Andrew. We have heard from the previous panel about areas in which we are seeing some good work; and from Henrietta just now we heard about areas that have perhaps not got the resources that others have. When OHID is pulling together a national strategy on prevention, how will it work with local public health professionals across the country to develop that national strategy?
Andrew Vereker: That is a really good question. It is essential that we understand all the good works out there. I think the first panel referred to the strategies in Yorkshire and the Humber, and the Greater Manchester metropolitan area, and I recognise those examples. We will take every effort to engage widely with the third sector and local authorities. We are doing a few specific things in the Department. We are undertaking a stocktake of all the activities that are out there. We have surveyed every organisation we are aware of that is active in the prevention space, and all local authorities. We are synthesising the evidence from that stocktake. We are also setting up our own governance and a task and finish group that will have external voices to help provide some external expertise into our thinking. But it is critical to your point that we don’t sit apart from the system and take decisions; we understand what is out there, and we listen to everything that the system has to tell us about what is and is not working. That is particularly the case because as we heard in the first panel, the evidence base here is somewhat limited, and we need to leverage on what is already happening.
Q78 Alex McIntyre: My colleague touched on this earlier with some of the questions around the inequalities in different local communities. Is that another work strand that you are looking at, in terms of how we can tackle some of those and get into communities that are perhaps more difficult to reach with prevention programmes?
Andrew Vereker: That is a really complex area. OHID is at the start of this journey, having just been appointed prevention commissioner. So, we are going to have to test and learn. I imagine that the spending decisions we make in year one will be different from year two and so on. We need to learn how we can reach those sorts of groups. We need to think as well about population-wide interventions, and how we target our approach, particularly for those people who are at risk because they live in deprived areas, or have existing mental health issues, or are unemployed, or male, or relatively young. As the first panel said, there are many at-risk indicators that we will need to think about as we work through a prevention approach.
Q79 Alex McIntyre: When can we expect to see a national strategy from OHID?
Andrew Vereker: We are working at pace to put in place our plan. I am not able right now to commit to a specific date or specific spending decisions.
Alex McIntyre: A rough date? A quarter? A year?
Andrew Vereker: As quickly as possible in this financial year, because we want to ensure as smooth and stable a transition as possible between the voluntary system and the statutory system. We were only publicly appointed in February, but we recognise the urgency. I am not going to commit to a specific date, but I want to reassure you that that is front of mind, that we need to work at pace.
Q80 Alex McIntyre: Will it be sometime between now and 5 April 2026?
Andrew Vereker: As soon as possible in this financial year.
Q81 Alex McIntyre: In terms of working with others, we talked about local public health professionals, but on working with the NHS and the Gambling Commission, how do you see working with them to make sure that we embed this prevention-based approach in everything that we do?
Andrew Vereker: That is a good question. We of course need to work really closely together. I think my colleague made the point that we already have really good relationships, and those are now set to continue. DCMS are putting in place formal governance arrangements, but underneath that we will have to be in regular close contact throughout this period.
Q82 Alex McIntyre: I am struck by your comment that there are a lot of things we don’t know in this space. How will you be working to test the effectiveness of the interventions, and do you have an idea of how you might evaluate the effectiveness and report back on that?
Andrew Vereker: You are right that the evidence base is somewhat limited. We don’t have a pre-existing framework of interventions that we know work, like in other areas. We will have to do a bit of learning as we go. We will have to look at effectiveness of impact in different ways, and we will have to work with DCMS, NHS and Gambling Commission colleagues to take views on what is value for money and what is impactful. We will continue to have that regular feedback loop with external experts. This will be difficult in the early stages, but I hope that as UK Research and Innovation takes forward its research programme, more of those evidence gaps will be filled.
Q83 Jo Platt: My questions are directed to you, Tim. The 2020 Public Accounts Committee report was pretty damning about the commission. What has the commission done since that report to improve the data and the intelligence that it uses to identify what is going wrong for consumers and for you to be able to intervene quickly? Are you still doing enough?
Tim Miller: It is worth saying that every recommendation in that 2020 report has been completed, and the NAO has confirmed that to be the case. Specifically on data, the biggest development was the launch last year of the Gambling Survey for Great Britain, which I touched on earlier. It surveys around 20,000 people a year, which makes it the biggest of its kind anywhere in the world. It is starting to give us a really comprehensive picture; not only does it show the headline rates of problem gambling and so on, which are only part of the picture, but it allows us to drill down in much more detail.
As a result, we have now started publishing some more in-depth reports. In a couple of months’ time, we will be publishing the next annual report. We are now getting a much more detailed picture. It is important to have that at the same time as delivering on the White Paper commitment. Evaluating whether those regulatory changes are delivering the benefits that we expect will be important, so that data forms an important part.
Alongside that, there are two other developments that I wish to highlight. We have fully established a number of advisory panels within the commission, including a lived experience advisory panel, so that we can draw upon the experiences of those who have experienced gambling harm as well as those of their loved ones. We have also commissioned quite extensive programmes of research into understanding consumer experiences, by which I mean people’s journey into and through gambling, to give us that much richer understanding.
Q84 Jo Platt: I am really interested in that bit. The 2020 report stated that the commission did not know what impact it was having on problem gambling, or what measures would demonstrate that the regulation was working. Then the previous panel informed us that new, updated studies were desperately needed. When will you meet the demand for those new updated studies, so that we understand that a little bit more? Or is the same true now as it was back in 2020?
Tim Miller: No, absolutely not. We are already seeing those studies coming out. You can go on to our website and find a huge amount of research and data that we are publishing. We make it all available for people to see and to challenge for themselves.
An example of the specific impacts that I would draw on is the fact that the egregious breaches that we were seeing back then—often from some of the biggest operators—are just not coming through in our casework any more. We are still seeing issues that we need to tackle, but those big breaches that go way beyond what is acceptable are just not there. Therefore, we are seeing much better levels of compliance from the industry.
We have introduced a ban on gambling on credit cards. The evaluation of that has shown that we were able to implement that in a way that did not drive people to other, illegal forms of lending. There is a whole range of measures that we put in place are really having an impact for people in the real world.
Q85 Jo Platt: I understand that you cannot look at cases older than two years old—is that right?
Tim Miller: No, that is not correct. There are some time limits on when we bring particular regulatory action, so we have to have completed our work within that time period, but we can look further back. What we are conscious of, though, is that there has been such a huge amount of regulatory change—particularly over the past couple of years—that the rules that exist now will often not be the same ones that were in place two years ago. Our focus is on ensuring that operators are compliant with our rules as they stand.
Q86 Ben Coleman: I recently wrote to the Gambling Commission on behalf of a constituent. The response, which was from the deputy chief executive, said: “The commission cannot consider historical complaints—events that occurred more than two years ago.” There seems to be some dispute between what you are saying and what was said there.
Tim Miller: It hinges on the particular facts.
Ben Coleman: That is not what the deputy chief executive said. She said that it cannot consider historical complaints. She was not contextualising it; it was a straightforward statement. Why would she make that statement, when you are contextualising it?
Tim Miller: It does depend on the issue. If, for example, something from a couple of years ago points to a potential existing breach of our rules—existing non-compliance—we can take that forward and look at whether they are currently compliant. In most cases where we are referred historical things, it is something we have probably already looked at through a wider review of licences.
Q87 Ben Coleman: If a company has not behaved properly, you cannot look back more than two years: is that what you are saying?
Tim Miller: No—if the regulatory action we were going to take was in relation to those specific events and two years had passed, there would be significant limitations on us being able to do that.
Q88 Chair: What limitations?
Tim Miller: The legislation imposes certain time limits on when we can take forward—
Chair: That is the answer we were looking for. Thank you.
Q89 Jo Platt: How can you encourage operators to go beyond the minimum required to prevent gambling-related harms? Do you have any examples of where that has happened?
Tim Miller: A good example at the moment is the development of something that was originally called the single customer view and is now called GamProtect. That is a system where operators can share with each other where they have identified a flag that a consumer might be experiencing severe levels of harm. The idea is that, in some cases, when an individual operator looks at a customer, they might be able to see the totality of the harm. We know that most people that are scoring eight-plus on the PGSI are gambling with multiple operators.
Seven operators have voluntarily come together to develop and build that. We are now looking at the evaluation of that. If it is shown to be really effective, we will look at whether we mandate it within our rules. That is a good example of operators voluntarily going beyond what the rules currently say following pressure from us and potentially helping to shape what we might require of other operators in the future.
Professor Bowden-Jones: I want to add that, from my 20-year perspective of dealing with the industry and with gambling disorder, I do not think industry can self-regulate on any level because the financial interest is too great for them to do the right thing at every opportunity.
Q90 Chair: What makes you say that?
Professor Bowden-Jones: Just the hundreds of people I have come across who have received all sorts of messages and have not been self-excluded. I had two people last week who kept on returning to the same bookmaker day after day, despite self-excluding. I will not bore you with all the details, but the reason I am bringing it up now is that you asked the previous panel what major changes they would like to see.
Chair: I am going to come to that question for you—please do not pre-empt my questions.
Professor Bowden-Jones: Okay—I hope I will remember then, but it is linked to this. It is about data sharing.
Tim Miller: Do you mind if I respond very quickly? It is important to say that, where things are done on a voluntary basis, I do not see that as being self-regulation. This is not an industry that is self-regulating. It is worth remembering that, although we are the statutory regulator for Britain, every local authority in the country is a gambling regulator. The Secretary of State is a regulator of gambling. It would be wrong to suggest that this is a self-regulated industry, but there are absolutely opportunities where industry can go beyond the set standards.
Q91 Chair: We heard from the last panel that, yes, they are regulators, but the issue may well be the legislation. The issue is that this industry is moving so fast that the legislation just has not caught up. Previous Committees made recommendations that, for example, loot boxes and other things should be regulated; maybe that is being kept under review now. My question to all of you is: what more powers would you like? Let us imagine that the King’s Speech is coming and in it will be a new gambling Bill. This is a hypothetical, and I urge you to answer it. What would you like in that Bill? You can have two things, and two things alone. I will start with Tim Miller.
Tim Miller: Helpfully, the Government have already committed in the White Paper to the two things that we want. One is for us to have the power to require internet service providers to take down illegal websites. That is in the Criminal Justice Bill, which is going through Parliament at the moment. The other is for us to have the power to set our own licensing fees so that we can flex our resources to meet changing challenges. I have highlighted the illegal market, for example—that is going to become more and more costly for us to address. We need the freedom to flex our licensing fees to meet those challenges.
Professor Bowden-Jones: I will give you one, because it is a lengthy one.
Chair: One good thing is fine, too.
Professor Bowden-Jones: I feel strongly that, if we are moving into a new era and industry is absolutely keen to collaborate, because we have got this money and we are very transparent about how we are going to spend it and everyone is working together, then the next phase needs to be making data available. By data, I mean all the things that the industry knows about each and every player. I am speaking on behalf of all the people who have lost their relatives from suicide to gambling and all the families who have lost their family homes because of gambling debts.
Q92 Chair: So forcing open data on the gambling companies?
Professor Bowden-Jones: Yes, because that way we would be able to detect harm way before someone ends up losing their life or their home just by looking at data: do they have the money? No, they do not. Where are they getting the money?
Q93 Chair: There is a power disparity here—the companies have more data than the regulators or the Government ever do.
Professor Bowden-Jones: Only the industry has the data that we are interested in, which is the data that drives people to end their lives. It is too late once someone has ended their life. Even then, we do not know who kills themselves because we do not have access to the data on whether they were gambling or not, and the families often are estranged or have no contact. I think the best thing this country could do is to move to an open data source—one that is anonymized, so that you end up only requesting it if you feel that it is important for the harm of an individual. I do believe that would make a big change.
Andrew Vereker: Fundamentally, what we want to see on prevention is a switch from treatment to upstream interventions to reduce the risk of harm occurring. Right now, the way we are delivering on that is through the levy, not through regulation, which is ultimately a matter for DCMS. My answer, which I accept is not a perfect answer, is that I want to see the levy come into effect. It is new; it is a step change; it could be a watershed moment, and we should look at the impacts of that before thinking about other regulations.
Q94 Chair: On that note, I come to my final question, which is again to you all. Imagine we are in a new era and this is coming in. We are at the next election, so the end of this Parliament. What will be different? What will be better by that point? What do you know will happen that will be better, and what do you hope might happen?
Andrew Vereker: I think we should seize the opportunity through the levy to reduce gambling harm and to ensure that people who are gambling do so at lower risk levels. That means that we want to see people not spending too much time gambling and spending too much money. Through awareness raising and through the prevention strand of the levy, I would like to see a measurable difference over the next few years on levels of gambling.
Q95 Chair: Is that a hope or a “know”? I am trying to get a sense of the levels here. I want to know what you think will happen as a minimum as a result of where we are now, and then the potential for where we could get to if this is implemented very well.
Andrew Vereker: The levy represents a step change in so far as we are putting things on a stable, transparent footing. We will see an effect; how big an effect I do not yet know, but I would like to see it be as big as possible.
Professor Bowden-Jones: The “know” is that we are now in a position to deliver evidence-based treatment to everyone who needs it—no postcode lottery—with a focus on those groups who will need it more, in order to break down the barriers to treatment for them. That feels like a “know”.
The hope is that the research agenda is taken seriously and that all things that need to be researched are researched—not just a little bit here and a little bit there because it is interesting to some people. I believe that neuroscience, neurobiology, genetics and randomised control trials need to be clearly outlined in this agenda this year to invest properly in things that we have never done before.
Tim Miller: The “know” is that we would have completed the delivery of the biggest reform of gambling regulations since 2005. I can be certain that the Gambling Commission will have done everything that we were meant to under the White Paper. The hope is that those changes—the introduction of the levy and so on—will allow us to have the comprehensive evidence base we need to demonstrate properly that those changes have had the beneficial impact for consumers that we all want them to have.
Chair: On that, I end the session.