Dr Carolyn Downs – Written evidence (GAM0049)


Dr Carolyn Downs is a senior lecturer at Lancaster University. Dr Downs has been researching gambling since 2001 and is a respected media commentator on issues around gambling. She served on the Gambling Commission advisory body on the structure of the UK Prevalence study (2007-2008). Dr Downs led the first UK study solely focussing on gambling related debt (2009-10) and conducted the first UK research into virtual gambling among children. She conducts research into bingo and social lotteries and was a member of the Expert Steering Group for the SRC Study on Socio-legal status of Bingo (University of Kent, 2014-2016). She is currently researching and is currently writing a book on the development of the UK gambling Industry. The ESRC, Gamcare, Money Advice Trust and People’s Postcode Lottery have funded Dr Downs’ gambling-related research. This evidence is given as an individual.


Question 1: Are the three primary aims of the Gambling Act 2005 (to prevent gambling from being a source of crime or disorder, to ensure that gambling is conducted in a fair and open way, and to protect children and other vulnerable persons from being harmed or exploited by gambling) being upheld?


Response: The aim of protecting children and vulnerable persons from being harmed is not being upheld effectively. There have been some high-profile fines issued by the gambling commission over the last 30 months but in general this hides ongoing problems. Firstly, there is no definition of who might be considered a vulnerable person. It is important that this be addressed. Secondly, there needs to be specific regulation about the duty to identify potentially vulnerable people and ensure they are offered suitable support, thirdly, it is undoubtedly the case that smaller-scale money laundering is taking place across the UK via cash gambling in particular. As to the protection of children and young people, until virtual gambling, video gaming and gambling advertising and promotions are properly regulated children will continue to be at significant risk. There is a body of academic evidence that the younger a person becomes habituated to gambling the more likely it is they will progress into a person with a gambling problem.


Question 4: Should gambling operators have a legal duty of care to their customers?


Response: Undoubtedly. Gambling is great fun for many people, but for a significant number it is highly risky. Social responsibility policies are only as good as the enforcement mechanism. There have been no investigations in the UK into what robust social responsibility in the gambling industry looks like or how it could best be implemented. This is a neglected area of work which academics and the gambling industry should be developing in partnership.


Question 5: What are the social and economic costs of gambling?

Response: As principal investigator of the first UK study exploring the relationship between gambling and debt (funded by Gamcare and the Money Advice Trust) the stark conclusion was that for each individual with a gambling problem between four and eleven other people or organizations were directly socially and economically adversely affected. The impacts of problem gambling go beyond the individual, rippling out to the family, employer and local community of the affected individual. The UK Gambling and Debt study identified the following social and economic impacts, although other impacts have been found in work by many leading academics:

Economic Impacts

Social Impacts

Question 6: What are the social and economic benefits of gambling? How can they be measured and assessed?

Response: Gambling has economic benefits to the tune of almost £14bn annually to the UK gambling industry, and to the Exchequer from various gambling taxes. Employment within the gambling industry is significant because of the size of the sector, although individual outlets (betting shops, arcades) usually employ fewer people than a comparable sized retail outlet. As the industry is investing heavily in AI and machine learning it is likely that numbers of workers in terrestrial outlets will decline over the next 10 years, while all UK gambling companies are growing their online business.

Lotteries provide funds for various good causes, and the traditional draw-based game, especially the smaller, social lotteries, are much less likely to lead to the development of problem gambling, although scratch cards are problematic.  Many modest gamblers enjoy participating occasionally in a range of gambling activities as part of their leisure. This has been shown to give people hope and pleasure as they speculate about what they might win, and is an important underpinning of the motivation to gamble, particularly on lotteries.

Measurement of the social and economic benefits of gambling should move beyond financial metrics and should include a cost-benefit analysis that takes into account levels of harm. For example, a society lottery, with direct-debit payments, limited draws and no opportunity for online or scratch-card gaming by participants will produce more benefits (in terms of donations to charity, prizes to winners, enjoyment of participants) and a lower risk of participants developing problem gambling than some other types of gambling. The current means of measuring the social and economic benefits of gambling do not take into account differing levels of risk, types of social responsibility measures or the wider social and economic costs (some of which are detailed in the response to question 5)

Question 7: Is the money raised by the levy adequate to meet the current needs for research, education and treatment? How effective is the voluntary levy? Would a mandatory levy or other alternative arrangement be more productive and effective? How should income raised by a levy be spent, and how should the outcome be monitored? What might be learned from international comparisons?


Response: The levy is wholly inadequate to fund research education and the treatment of around 450, 000 problem gamblers. Robust estimates suggest the cost of treating alcohol dependent people to the NHS is £3.5bn per year (Roberts et al, 2019), in the UK there are around 590,000 dependent drinkers, equating to around £5900 per year per person spent on treatment alone. This figure is for NHS treatments (periods spent as in-patients, visits to GPs etc) and does not include drug and alcohol addiction services as these are funded through local authorities rather than the NHS. If we were spending this much on problem gamblers, we would need a budget of £2.6bn per year. In fact, the UK is likely to be spending significant amounts on the consequences of problem gambling, but it will be coming out of general NHS, criminal justice and other budgets, undermining the ‘polluter pays’ principle of the Gambling Act (2005). It should be noted here that the 2.6bn a year would be solely for treatment, without any money set aside for research into the social, psychological, economic or other aspects of gambling nor for education programmes about responsible gambling. The maximum currently contributed by the gambling industry is £10m annually, and this is often a very reluctant donation. Numbers of gambling operators donate tiny amounts (£10 for example) so as to get on the list of donors. While I acknowledge that a group of larger operators plan to increase their donations towards the levy to 1% of profits over the next five years, that will only result in £100m of funding. This falls far short of what is realistically needed for a comprehensive treatment service, for example in 2013-14 £877m was spent on drug and alcohol addiction treatment in the UK. Establishing the true cost of gambling addictions to various services is critically important as it is only through knowing the costs that a judgement can be made as to the level of contribution the industry should make. There may also be a case for conducting research into the levels of harm caused by particular types of gambling so that those more likely to lead to addiction have to contribute more to the levy than those causing less harm.


Question 9: If, as the Responsible Gambling Strategy Board (RGSB) has suggested, there is limited evidence on which to base sound decisions about gambling by children and young people, what steps should be taken to rectify this situation?


Response: There is certainly very limited evidence on which to base sound decisions about gambling by children and young people. I produced the first research on children and virtual gambling in 2009. Virtual gambling is unregulated as it does not involve gambling for money but with tokens provided by the app developer. However, when the free tokens run out players can make an in-app purchase of more tokens. Children can use payment cards they can buy at many high street retailers to make in-app purchases. These sorts of games have spread exponentially since 2009 and the types of gambling are very varied and often concealed when simply viewing the front-end of an app. For example, along with games that are purely gambling (Zynga Poker on Facebook) there are gambling elements included in many games that at first sight are suitable for children. We have no research into the impacts of loot boxes in video games on children or young people’s understanding of gambling. Anecdotally a large number of X-box live and Play Station Plus gamers bet with each other while playing FIFA, Forza and so on, for virtual goods. We have no prevalence data, no age breakdowns for this type of gambling but we do know that hundreds of thousands of teenage boys in particular play these video games. Many very young children are able to download apps by themselves, and certainly would not be barred from accessing apps with gambling elements. There should also be concern about the popular video game Grand Theft Auto, which has now activated a casino as part of it’s game. Players need to buy tokens to use in the casino but cannot cash out winnings, which enables the game developers to avoid regulation. However, although the game is certified as an 18, many younger teenagers have access to Grand Theft Auto, and therefore to the the casino that is part of the game. It is well established that the earlier people become habituated to gambling the more likely it is they will develop problem gambling. We also lack research into the ways in which children understand risk and odds, how they conceptualize gambling, how advertising and marketing affect their decisions regarding gambling.


Question 13: The RGSB has said that by not taking action to limit the exposure of young people to gambling advertising “we are in danger of inadvertently conducting an uncontrolled social experiment on today’s youth, the outcome of which is uncertain but could be significant.

Response: I would certainly agree that there are significant risks with uncontrolled gambling advertising. I was supervising a small child using an educational app on an iPad only to be horrified when an advertisement for a gambling app (cartoon based) appeared. There should be significant restrictions on gambling advertising. Prior to the Gambling Act (2005) the general principle was that although gambling was legal it should only be provided where operators could show there was ‘unstimulated demand’. Restrictions on advertising were eased with the arrival of the National Lottery but are now completely absent. Some operators have decided to voluntarily limit their advertising with a ‘whistle to whistle’ ban on adverts during live sporting event, but many children and young people do not watch much live TV, preferring social media, You Tube, Netflix, Amazon and so on. Via personalized marketing children and young people are exposed to adverts and offers related to gambling. Again, I have personal experience with my 16 year old son getting gambling adverts appear on his Instagram feed. Many children lie about their age on their social media accounts and thus are vulnerable to seeing adverts or receiving marketing that are not age appropriate. Research by Ofcom found that a significant proportion of young people (between 27-34%) believe online adverts are ‘telling the truth’ (Ofcom, 2017b) and that almost 50% of children did not identify sponsored links or content online (Ofcom, 2017b)

Question 15: How are new forms of technology, including social media, affecting children’s experiences of gambling? How are these experiences affecting gambling behaviour now, and how might they affect behaviour in the future?


Response: Most children over the age of 11 now have access to 4G enabled mobile phones (Ofcom, 2017a) which means they can access the internet 24/7, with parents rarely aware of the ways in which their children are using these devices. Children are using social media, (often lying about their age to access accounts), children have bedrooms equipped with internet access via video games machines and laptop computers. All of these changes mean children can easily access a wide variety of leisure activity. However, there are many gambling adverts and marketing promotions running through social media – children can access these. Where a gambling promotion offers free play there may not be a requirement to sign up with a credit or debit card. There have been cases of children using relatives credit or debit cards or relatives online accounts to access gambling or to make in-app purchases for loot boxes (akin to gambling). Children can also easily use their own money to buy a voucher that enables in-app purchases, these are available at outlets like Game, Argos and major supermarkets. There has been in sufficient research into this topic so we do not understand how these experiences are affecting children’s understanding of or access to gambling or gambling like games. A large-scale, longitudinal study is urgently needed to assess children’s use of technology and access to gambling or gambling-like activities and to explore whether there is a relationship between early access and development of problem or habitual gambling.


Closing remarks: This document is unable to address all of the questions posed by the committee due to space restrictions, and the questions addressed have answers that are summaries of complex matters. I would be happy to speak to the committee in person so that you had a more detailed picture.



Downs, C (2011)‘Playing in a Virtual Bedroom: youth leisure in the Facebook generation’ pp 15-31 in Children, Youth and Leisure, Editors Ruth Jeanes and Jonathan Magee (LSA No 113) ISBN 978 1 905369 24 9

Downs, C and Woolrych, R (2010) ‘Gambling and Debt: The wider impact’ Community, Work and Families Vol. 13, No. 3, August 2010, 309-326

Downs, C (2010) ‘Young People Playing with Risk: Social networking and the normalisation of gambling behaviours’ in Leisure Experiences:  Space, Place and Performance ed: Marion Stuart-Hoyle and Jane Lovell LSA 109 ISBN 978 1 905369 20 1 pp25-47

Downs, C and Woolrych, R (2009) Gambling and Debt: Pathfinder Report (2009), Manchester: MMU RIHSC Occasional Publications Series ISSN 1750-1571 ISBN 978-1-900139-39-7 (Anonymously Peer reviewed before publication)

May-Chahal, C., Humphreys, L., Clifton, A., Francis, B. and Reith, G., 2017. Gambling harm and crime careers. Journal of gambling studies, 33(1), pp.65-84.


Ofcom. (2017a). Share of children who regularly used mobile phones in the United Kingdom (UK) from 2014 to 2017, by age. Statista. Statista Inc.. Accessed: September 06, 2019. https://www.statista.com/statistics/398283/children-regular-use-of-mobile-phones-by-age-uk/



Ofcom (2017b) Children and Parents: Media Use and Attitudes Report accessed: September 06, 2019.  https://www.ofcom.org.uk/research-and-data/media-literacy-research/childrens/children-and-parents-media-use-and-attitudes-report-2018


6 September 2019