Gambling with Lives – Written evidence (GAM0098)


Gambling with Lives (GwL) is a charity set up by families bereaved by gambling related suicides.  All lost young people aged 18 – 34 who had been addicted to gambling when they were children or adolescents, on machines and in environments that they and their families thought were safe.  Apart from this addiction all were happy normal children from loving families.

This submission is based on the intensive engagement of this group of experts by experience (EbEs) with legislators, regulators, treatment commissioners and providers, recovering gambling addicts, campaigners, researchers and industry representatives. The trauma of losing their children has motivated families to investigate the subject widely and thoroughly. It has been our experience that other stakeholders tend to assume that families can only express trauma and grief.  However, we have not lost our capacity to learn and think along with our children.  We are still capable of self-determination and we have refused to be siloed and patronised. Many families report the experience of a growing knowledge providing a growing understanding about what happened to their children – a clarity about the addictive products and predatory practices that their children were exposed to and the lack of information, treatment and failures of regulation that condemned these young people to the ultimate conclusion of this illness.

Comments are provided under the broad headings requested.  We also ask that the Members of the Committee view the 2 short films on the GwL website ( The films feature some of the GwL families speaking about their own experiences and commenting on what they believe needs to be done to reduce the major harms which are caused by gambling. Many of the comments directly address questions in the Call for Evidence.

The Gambling Act 2005

There is a clear need for a new Gambling Act to bring legislation up to date with the rapid developments in technology over the past 15 years. The Act did not anticipate the huge growth in online gambling, in particular the rapid spread of the mobile phone, or the amount of activity which would be conducted off-shore. The fact that the maximum £2 stake which was applied to land based Fixed Odds Betting Terminals could not be extended to cover the same products offered online is evidence of the inadequacy of current legislation. We know that normalisation and availability increase prevalence of gambling disorder so a new Act needs to recognise that the advent and spread of the mobile phone has increased the likelihood and intensity of harm.

A new Act should introduce a mandatory levy (see below) to pay for independent research, education and treatment. This will need to be set at around 1% of Gross Gambling Yield, raising around £140m pa. The disbursement of this level of funding requires the reorganisation of existing structures to provide complete independence from the influence currently exerted by the industry due to the discretionary voluntary arrangements and the conflation of collection and disbursement in the same organisations.

The new Act should also establish an independent ombudsman with responsibility for protecting the individual consumer and wider public. The current remit of the Gambling Commission to investigate the activities of individual companies in respect of their licensing conditions does not provide adequate protection or redress for individuals whose rights have been violated by a gambling company. It should not be necessary for an individual to have to take legal action, potentially costing thousands of pounds, to seek redress from an individual company.

A new Act should include recognition the wider harms that gambling causes to individuals and society – which go beyond “crime and disorder”, “fairness” or “protecting the vulnerable”. It needs to recognise that gambling should be treated as a public health issue, with all the implications that has on product safety, availability, advertising and marketing.

Finally, a new Act must curtail advertising and marketing which normalises gambling, addicts while providing false information about fairness and safety, and ramps up addiction by targeting addicts directly.  The current massive spend on traditional advertising visible to the public is dwarfed by the spend on direct marketing and targeting.  In 2018, GambleAware estimated that the industry spent £1.5bn on marketing, almost half of which was direct marketing, with a further fifth through ‘affiliates’ and 10% on social media. Therefore, the remit of the Advertising Standards Authority does not extend across the vast bulk of gambling marketing. The new Act needs to include authority for all forms of gambling marketing to be regulated.

Social and economic impact

Current research on the social and economic costs of gambling is basic and inadequate. Harms measured are limited to those which are easily monetised and involve additional measurable costs to the public purse. Therefore, all social and emotional impacts on families, friends and in the workplace are not included.  As has been stated directly by one GwL family to the Minister for DCMS, official summaries of harms do not even include the deaths of our families members.  Despite our work on summarising the considerable body of research from around the world that links gambling with suicide there are still no official estimates of the numbers of deaths.

The authors of the 2016 IPPR report Cards on the Table estimated that the cost to the public purse of gambling was between £260m and £1.2bn but noted that their work was a first step and covered a limited set of costs and suggested some of the actions that would be required to improve and extend these estimates:

Due to limitations in the available data, these findings should not be taken as the excess fiscal cost caused by problem gambling. Instead, they should be taken as an illustrative estimate for the excess fiscal costs incurred by people who are problem gamblers, beyond those that are incurred by otherwise similar members of the population. 

The Gambling Commission’s 2018 report Measuring Gambling Related Harms identifies over 50 potential ‘metrics of harm’ but actually used only 9 as a starting point of quantification.

While GwL accepts that the quantification of harm is an inevitable part of the public decision making process, we contend that the numbers produced represent only a small fraction of the true impact and that that monetised harms should be only one aspect of decision making on regulating gambling and reducing gambling harms. To focus only on monetised impacts is to render the decision more vulnerable to industry lobbying and treasury interests, as we saw in Philip Hammond’s statement to the Treasury Select Committee in November 2018 over the reduction in FOBT stakes.

There is a tendency for quantified (monetised) costs to be accorded a status which cannot be justified by the approaches and assumptions used to achieve them.  They inevitably end up being an underestimate of just some of the impacts and totally ignore others. For instance, gambling researchers have identified that 4-10 others are affected by a ‘problem gambler’. However, what this means is that there is an identifiable public monetary cost associated with 4-10 other people, through, for example, increased use of services. The EbE evidence of GwL families and others shows that the impact of one individual’s gambling problem extends to family members, friends, employers and the wider community. Some of these costs may be directly monetised while other impacts may be more hidden (for example loss in productivity).

Of course probably the greatest unquantified impact is the harm caused to us all as we live with the pain and distress of seeing much loved family members suffering, their lives permanently ruined or violently endedCurrently they are private costs which should be considered alongside the monetised costs to public services.  Together as families we are working to make that private suffering public.

We consider further the issue of suicide and gambling under Treatment, below. However, we must note in this section that the UK government still has no official figures or even estimates of the number of gambling related suicides each year in the UK, despite our demands over the past 18 months. While we would not condone putting a “cost per life” figure on an individual death, our own estimates, which are based on international research (see, indicate that there are 250 – 650 gambling related suicides each year in the UK. By any measure this represents a huge cost to the country, both monetary and more widely. It is intolerable that the government has no estimate of suicide numbers and must be rectified immediately, through the commissioning of a dedicated research programme and changes to medical recording and the coronial process.


The voluntary levy system does not work in 3 respects:

  1. Inadequate levels of funding for research, education and treatment (RET):


The industry has consistently failed to meet the ‘target’ levels which GambleAware have requested. These levels have been totally inadequate – reported as either 0.1% of Gross Gambling Yield (GGY) or £10m. This is reflected in the lack of development of a vibrant and high status research community, the very limited provision of education work, and the staggeringly low quantity and quality of treatment.  Less than 3% of those with severe gambling problems receive any treatment compared to 15 – 20% of those with drug or alcohol problems and virtually all are self-referrals.


We estimate that a statutory levy of a minimum of 1% of Gross Gambling Yield, which would currently generate around £140m pa, is required.  This would see world class research and education services established and NHS commissioned treatment for approximately 20% of those with gambling problems and addiction. A much larger levy would be required for gambling to cover even the lowest estimate of harms calculated in the IPPR report, noted above.


In Feb 2018 the Gambling Commission’s Reviewing RET Arrangements put a high-end estimate of £62m pa. We believe that this is far too low. In particular, it assumed that only 10% of those requiring treatment would receive it and that the current mix of provision would continue. It is clear (see Treatment, below) that not only should a higher proportion be seen, but a much higher proportion of treatment must be delivered by NHS staff trained to a much higher level. Further, the Commission’s estimate does not appear to include links with the rest of the NHS and other support services that gamblers, their families and those bereaved by gambling suicide need.  Spend at the level of £140m pa would still only bring the UK into line with the levels of spending on RET “per problem gambler” in most provinces in Canada, Australia and New Zealand.


  1. Lack of consistency and security of funds


Organisations must have security of funding to be able to develop the expertise and resources to achieve world class research, education and treatment services. Realistically only the NHS can commission and deliver nationwide specialist treatment for gambling disorder (see below). This will require substantial investment over a number of years to attract and train specialist staff but also to ensure that there is the necessary training of GPs and other frontline staff (in the NHS and other agencies) to diagnose gambling disorder, make appropriate referrals to specialist services and provide low intensity treatment at primary care level.


The gambling research community in the UK is relatively small with very few university departments having a dedicated gambling research team. Currently it is difficult for a new researcher to envisage that they could have an exciting or stable career in gambling research. Further, the field of gambling has attracted few researchers working in related disciplines such as mental health or suicide. To our knowledge, there has been only one independently funded research conference in the UK. This is an extraordinary position given the scale of gambling activity and harms in the UK. To achieve the growth required in the UK research community, it is necessary to provide not only a substantial boost to research spending but a good level of stability in the availability of research funding in order to attract leading gambling researchers to work in the UK and to attract the brightest young researchers into this field.


  1. Industry influence over organisations, the research agenda and institutions, education specialists and treatment providers


The discretionary nature of the funding enables the gambling industry to exercise a substantial and censoring influence across the research community, education and treatment providers which prevents discussion on addictive products, predatory practices and political lobbying. This influence seems to have silenced even treatment providers from highlighting the scale of the problem, demanding substantial increase in resources and changes of culture.


This influence is also evident in the perpetuation of the “responsibilisation agenda” in which all responsibility for curbing gambling is located in the individual with little or no attention to the responsibility of the state or operators.  Individuals have usually been addicted to known addictive products while children or adolescents in environments which they and their families were told were safe.  They have been enticed into further addiction by predatory and deceptive practices and are then told by the collective culture that they are responsible for their own addiction and are morally and psychologically deficient individuals.  We believe that this agenda contributes to the move to completed suicides – this is evident in the suicide notes of our family members. And yet much of the research agenda continues to focus on individuals, whether it is their “genetic predisposition” or identifying patterns of play rather than examining the contribution of environment, products, practices, availability, advertising and marketing and normalisation. 


As noted above, one of the major concerns about research in this country is the direct and indirect influence that industry has through the voluntary funding regime. These major concerns are summarised in Fair Game (R. Cassidy et. al, Goldsmiths, 2013). We believe that this situation can only be addressed through the introduction of a statutory levy which would be disbursed across research, education and treatment entirely independently of the industry. This will require the establishment of new independent structures and organisations.

The GwL families believe that the failure of GambleAware to commission research on the links between gambling and suicide results directly from their reliance on industry funding and the resulting influence on the identification of research topics and overall research agenda. This was never an area that the industry would wish to be highlighted or investigated. Similarly the paucity of research around the addictiveness and dangers of different gambling products or the impact of the marketing and targeting (eg. VIP schemes) of the industry reflect the influence of funding in directing the research agenda.

We believe that a national research programme should be developed through joint consultations with government, regulators, treatment providers, EbEs and the research community. This may involve consultation with the industry, but they should have no influence over the final programme. The development of the research programme must also include an emphasis on greater collaboration between researchers from different disciplines, including psychology, economics and the wider social sciences, medicine and neuroscience. Given the historically low level of research funding and lack of wide knowledge about gambling across disciplines, it may be necessary to run a substantial consultative exercise to establish some the parameters of an initial research programme.

However, we also believe that significant finance should also be available for individual research organisations to be able to bid to ensure that appropriate innovation remains.

As a condition of their licensing, gambling operators should be required to make available complete anonymised play and other data, which should be held in national repositories which are accessible to all bona fide researchers. Further, operators should be required to cooperate in any way that is required within any approved research projects.

Reporting of all projects which receive industry funding, directly or through organisations such as GambleAware, or are undertaken by organisations which receive direct or indirect funding from the industry should include a clear statement making clear this association.


First, it is worth noting that education activities are generally amongst the least effective interventions in terms of preventing the development of problem gambling. Further, some researchers have argued that gambling education might be counterproductive and that it might actually increase the normalisation of gambling. So while education does have a place, it should not be considered as the major preventative measure and should only be considered alongside other initiatives.

Currently there are no national standards for the content or delivery of education. This needs to be addressed immediately, ensuring that content is not just about understanding probability, odds and risk, but including clear information on mental health risks, dangers of particular products and awareness of the practices of the industry. Gambling needs to be placed in a social and public health context, alongside drugs and alcohol awareness teaching in PSHE.

We are concerned that industry funding for existing education activities mean that an incomplete picture is being delivered. The focus tends to be on understanding the financial and statistical risks of gambling rather than addressing mental health issues, the addictive nature of some products and a realistic view of the practices of the industry. Current education just reinforces the “individual responsibilisation” message which is favoured by the industry.


The experience of the families who have made contact with GwL is that current treatment is both inadequate and ineffective.  All the young people who have died attempted to access treatment and were either misdiagnosed or offered inadequate or inappropriate treatment. Gambling disorder is not routinely diagnosed by GPs due to lack of training and there are no NHS treatment pathways or public health strategyCoronial recording of suicides cannot take account of medical recording of gambling disorder on as would follow suicides with a GP note of drug or alcohol addiction.  Deaths after treatment are not investigated and therefore there is no learning from deaths correlated with gambling disorder and no recording of numbers.

NHS treatment

Gambling disorder was classified as a psychiatric condition in 1995 and further classified as equivalent to drug and alcohol addiction in 2013 (DSM IV 1995 & DSM V 2013).  The families of GwL believe that until now there has been a systemic state failure to follow that classification with commissioning and provision of evidence based services delivered to an NHS standard.  This failure to provide public health information and effective treatment has resulted in the deaths of our family members. 

GwL welcomes the first instruction to Public Health England to support DCMS with public health information in March 2018.  However, we note that this instruction was not given priority during 2018 and there seems to have been little progress.  GwL welcomes the inclusion of clinics in the NHS long term plan of 2019 and the introduction of NHS standards to commissioning of NHS provided clinics.  It is now essential to ensure that any partner providers adhere to the same standards of treatment effectiveness, training and service metrics. 

There is now the potential to introduce NHS standards of efficacy and on the ground service effectiveness to tendering and commissioning decisions. However, the plan currently lacks coordination with other structures in the health service. Primary care is both a key referral point and a potential delivery point for low intensity provision and preventive measures and would have been key to saving the lives of our family members.  GP training in gambling disorder is minimal and has no equivalence to drug and alcohol training.  There is no routine screening for gambling disorder equivalent to screening for high alcohol intake and there seems to be no plans to introduce this.

Current treatment outside the NHS

There is a lack of accountability and normal governance scrutiny of the current non-NHS commissioners and providers.  The GwL Board includes people with long, senior clinical and commissioning experience in the NHS and we see no evidence of commissioning and provision comparable to NHS best practice as is currently routinely asserted. The lack of appropriate procurement and service improvement at the point of recommissioning is evidenced by the recent decision by GambleAware to award a further £3.9million to GamCare without a procurement commissioning process or collaboration with the NHS.

It is essential that EbEs are now included routinely in procurement and commissioning decisions as is now common practice in the NHS and we understand that the Gambling Commission and the NHS providers are beginning to set this in place.  Until now our concerns have been systematically ignored.

Concerns include:


Perhaps most worrying is the 6 month time limit on serious incident reviews on people who have taken their lives after treatment from a GamCare provider.  As senior NHS staff we find this refusal to learn from failed care that has led to deaths unconscionable.

Gambling and Suicide

Until Gambling with Lives was established, the link between gambling and suicide was barely publicly acknowledged by government, regulators, treatment providers or the industry – despite a research literature stretching back decades which showed a clear and consistent link. In our early meetings with stakeholders we were met with blank looks when we talked about the potential scale of the issue. As noted above, it fell to GwL to compile the international research which indicates 250 – 650 gambling related suicides each year in the UK. Research published since we produced those estimates have confirmed the scale of deaths.

We recognise that progress has been made in accepting this link – as demonstrated by the fact that the Committee has included an explicit question on gambling and suicide.

However, the reality is that GambleAware have commissioned only 2 small scale projects analysing old data sets. These projects confirmed a substantial relationship between gambling and suicide which could not be explained by any other factors. There is the need for a substantial research programme to develop the understanding of the scale and pathways of gambling related suicides.

Initially we are calling for a substantial project based on “psychological autopsies” of recent suicides in the UK, similar to the study by Wong et al (2010) in Hong Kong. This should be accompanied by other qualitative work to understand more about the development of addiction and path to suicide. This should include the impact of the “individual responsibilisation” agenda in increasing the suicide risk of individuals. Finally, further work is required to understand the influence of particular gambling products on moving people towards suicidal action.

GwL families are available to be involved in these different strands of research. Further, the majority of recovering gambling addicts have acknowledged suicidal thought and attempts. There should be no major barriers to getting a substantial research programme underway.


11 October 2019