Bournemouth University – Written evidence (GAM0001)


Professor Raian Ali (Professor in Computing) and Associate Professor John McAlaney (Associate Professor in Psychology)

  1. Written evidence submitted on Wednesday 17 July 2019 by Professor Raian Ali and Associate Professor John McAlaney, on behalf of Bournemouth University, to the House of Lords Select Committee on Social and Economic Impact of the Gambling Industry.
  2. Professor Ali is a Professor in Computing and leads the EROGamb, GamInnovate and Responsibility by Design projects. His research is focused on the engineering of social informatics – the social aspects of computerisation – and specifically includes the design of systems which are receptive and responsive to the feedback of users.
  3. Associate Professor McAlaney is a Chartered Psychologist and Chartered Scientist in the Department of Psychology. His research focuses on social-psychological determinants of risky behaviours, with an emphasis on addiction. His involvement in EROGamb[1] centres on the role of perceived social norms, and how challenging misperceptions of gambling behaviour can be used for prevention and intervention. He is also a trustee board member at the Gordon Moody Association.
  4. John and Raian would be pleased to provide further information or give oral evidence if it would support the Committee’s inquiry.

The Gambling Act 2005

Question 2: What changes, if any, are required to bring the Act up to date with new technology and the latest knowledge about how gambling harm is distributed?

  1. The scope and richness of data that flows between the gambler and the operator in online gambling has increased substantially since the publication of the Act, as has the ability of the operators to use data analytics predictive modelling to identify current and future problem gamblers. Gambling operators could allow gamblers easy access to the data they hold so the gamblers themselves can monitor and modify their behaviour.  Our research shows that it is possible to use API (Application Programme Interface) technology to provide personalised real-time data to a gambler[2]. Currently, GDPR rules allow players to ask for data held about them by others but does not mandate the sharing of such data in real time, e.g. via automated tools. If the data could be provided in an automated, real-time manner to players, it would enable them to visualise and understand their gambling behaviour, support them with budgeting and to identify potentially harmful behaviour.
  2. The real-time data could also be harnessed to support players in managing time and money limits. Personalised limits could be set by the gamblers themselves, potentially with third-party verification for problem gamblers (e.g. bank, therapist, family member). This use of personalised messages delivered through devices such as smartphones has been used to reduce risk behaviours in other domains, such as alcohol use. This type of feedback is much more salient and persuasive to an individual than a mass media campaign aimed at the public in general. This may be of particular importance in relation to online gambling.
  3. Gamblers who have taken part in our research talk about the fact that money does not seem real in online gambling; they feel that time limits which restrict the total amount of time spent gambling and increase the time between bets would help them maintain control of their gambling. Any such limits would need to apply across operators - and the technology exists to prevent users simply switching to other sites and apps once they have exceeded their limit on one.
  4. Our research participants told us that enforced cooling-off periods (time gaps between bets) could help them regain some control as the gaps between bets in online betting can be very short and players are driven by emotion rather than rational thought. The combination of understanding the role of the emotions with the real-time, personalised data may support gamblers to identify and track their personal triggers and consequences. There is also the potential to harness physical device actions (e.g. movements and gestures whilst using smartphones) to provide feedback on a player’s state of mind and prompt appropriate messages.
  5. Greater transparency and access to this data (anonymised if appropriate) by researchers, public health bodies and regulators can substantially improve our understanding of how gambling harm is distributed. Online gambling data in particular can be used to map the demographics of gamblers, often also including an approximation of their physical location. This in turn can be used to make an estimation of factors such as socio-economic status.
  6.        Updating the Act to ensure the legal and regulatory framework facilitates and supports the above technological advances, rather than inadvertently stalling them, would provide tools for gamblers to maintain control and manage their spending and emotions.

Question 3: Is gambling well regulated, including the licensing regime for both on- and off-shore operations?

How successfully do the Gambling Commission, local authorities and others enforce licensing conditions including age verification?

What might be learned from comparisons with other regulators and jurisdictions?

  1. Many aspects of gambling are well-regulated. However, new and emergent technologies have made the enforcement of these regulations challenging, e.g. loot boxes in online gaming do not currently come under the regulations. In addition, children and young people have the means (shared via online forums and other spaces) to circumvent age verification systems. There is the potential for financial services providers to contribute towards age verification; for example, some banks already provide services in which accounts can be blocked from being used for any gambling-related transactions. By utilising such systems, it may be possible to make it harder for age verification systems to be bypassed.

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

  1.        Yes, gambling operators should have a legal duty of care to their customers. As part of our research[3], the EROGamb (Enabling Responsible Online Gambling) project explored the gambling industry’s perspective on its corporate social responsibility[4]. As part of this work, we discussed sustainability with operators, and how it is a better business model for them to retain a customer database which gambles safely and responsibly over an extended period of time rather than having customers who develop gambling problems and quickly escalate to a situation where they are no longer willing or able to gamble. Making these responsibilities by the operators a legal care of duty would reinforce the expectation that the onus is on the gambling operators.
  2.        Currently, gambling operators do not have the capability to design a site that embeds responsible gambling within it; our new Responsibility by Design project is looking at establishing a data set that would achieve that aim. The infrastructure of most gambling interfaces is not designed with this type of function in mind and if the gambling operators want to facilitate responsible gambling, their websites require certain functionality to be built in from the start. If this can be done, then the gambling sites and apps themselves could be prepared to inherently host, facilitate and deliver responsible gambling solutions to the players, saving the operators time and investment and reducing harm for the players and their dependents.


The Levy

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?

  1.        The levy and donations are not enough as they are not the only resource needed. The main issue from our experience is the lack of meaningful and substantial collaboration between operators and researchers. The gambling industry is still reluctant to engage fully with research and this is due to the way funds are allocated, whereby operators are support partners in projects, but without any legally binding commitments.
  2.        Currently, most funding for gambling research comes from GambleAware and the industry, with other smaller pots of money coming from a range of charities. There is no obvious source of funding from the UK Research Councils, although it is not clear if this is because they do not see the topic as part of their remit. Public Health England recently referred to gambling problems as a public health issue and this has somewhat changed the narrative around gambling as an addiction. NIHR (National Institute for Health Research) subsequently launched a call for research into interventions and harm prevention.
  3.        A mandatory levy and objectives would support and develop the seniority and prominence of the harm reduction agenda within companies – at the moment corporate social responsibility holds a minor position in the gambling operators’ priorities and wields little real power.
  4.        We propose a better way of achieving meaningful engagement with the gambling operators would be to consider such engagement as part of the financial donation/levy they give. For example, they could contribute staff time and access to IT infrastructure and marketing material, as well as provide technical assistance to researchers who wish to develop prevention and intervention tools that would interface with the operator’s API.



Question 8: How might we improve the quality and timeliness of research in the UK?

What changes, if any, should be made to the current arrangements for funding, commissioning and evaluating research in the UK?

What might be learned from international comparisons?

  1.        There is, of course, a possibility that gambling operators might avoid commissioning research where the outcomes might be unfavourable. Siting funding for gambling research within the UKRI (the UK research councils) would be a positive move, although it is important that this does not undermine the efforts of GambleAware, who are keen to build up and diversify research capacity in the UK.
  2.        If gambling operators are directly involved in the funding of gambling research, then it is important that this is done publicly and transparently. This could be aided by actions such as researchers publicly posting their study protocol before the research project starts. As in the principle of open data, the results of the study could also be made publicly available, allowing other, independent, researchers to conduct their own analysis.
  3.        In addition, furthering the opportunities for national funding makes it more likely that research will be undertaken that relates to gambling harm, but is beyond the remit or business interests of gambling operators. Examples of this include research into potential links between gambling and poverty, or gambling in specific geographic settings such as coastal towns.

If, as the Responsible Gambling Strategy Board (RGSB)1 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?

1 Now called the Advisory Board for Safer Gambling.

  1.        The increasing blurring of the boundaries between gaming and gambling is of particular concern for young people and there is debate over whether gaming can be regarded as a gateway to gambling. We are currently analysing data from a study which explored the conceptualisation of loot boxes, which includes people’s perceptions and expectations when accessing them and the potential gaming/gambling overlap. We would be happy to share the outcomes of this work with the Committee when it concludes in early autumn 2019.
  2.        Furthermore, we intend to extend this work as it is increasingly vital to understand more about the impact of loot boxes, the effect of embedded marketing promoting gambling within non-gambling apps (included those accessed by children despite parental controls), and whether educational resources for school-age children can help increase awareness of the distinction between gambling and gaming and how children and young people can safeguard themselves.
  3.        The Belgian government has banned loot boxes with games, and suggestions have been made in several other countries, including the US and Sweden that similar legislation is passed. There is, though, a lack of research evidence on which to base these decisions. As researchers within the gambling field, we are keen to investigate the involvement of children within gambling and are actively seeking funding and collaboration to take this forward.



Question 10: Is enough being done to provide effective public education about gambling?

If not, what more should be done?

  1.        Public education about gambling is not highly visible; more broadly, there is a lack of public education about online systems and the algorithmic manipulation of behaviour. There is a need for increased education in schools on the risks of online behaviour, including not only online gambling, but other areas such as involvement in hacking or the modification of video games. As has been achieved in areas such as substance use and sexual health, the aim is to help children and young people become informed decision makers who are able to navigate safely a fluid and changing world. Educational resources of this type are currently being developed by the researchers at BU, which will be made freely available and shared with the Department of Education and the Committee.



Question 11: Are the services available for the treatment and support of people at risk of being harmed by gambling sufficient and effective? How might they be improved?

What steps might be taken to improve the uptake of treatment, particularly among groups who are most likely to experience harm from gambling and least likely to seek help?

  1. The extent and prevalence of gambling-related harm among young people is still not completely known. Young people are a risk group and bringing a focus to understanding their involvement and treatment for addictive gambling is important.

Question 12: What steps should be taken better to understand any link between suicide and gambling?

  1.        Family members, therapists, banks and employers should be included in the responsible gambling process – with the proper consent of the players. With such access, they could report any mental health issues which may not otherwise be properly identified if the onus remains purely on online gambling data and self-report by the gamblers themselves.
  2.        It is difficult to establish reliable statistics about the link between suicide and gambling as it is not a requirement for the coroner to record the factors relating to a verdict of suicide. Josephine Holloway, whose son Daniel committed suicide after 18 years of gambling addiction, and who is one of the supporters of our research, is campaigning to have the law changed in order for her son’s death to be registered as gambling related. Only once coroners are able to state the factors in a death by suicide will there be any meaningful statistics on the link.


Gambling by young people and children

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?

  1.        As mentioned in the response to Question 8, new forms of technology are blurring the lines between gambling behaviour and gaming. It is unclear if there is a relationship between gaming and gambling, for example, with regard to loot boxes in video games. It is again unclear if this overlap will be problematic for young people who play video games, and in particular for those who play games with more gambling elements and/or for extended periods of time.
  2.        The interrelation between game elements and gambling can be subtle and requires extensive research. We suggest that mechanisms, such as loot boxes, which deal in real money are suspended until the gaming industry can clarify - with evidence from impartial research - whether or not it is a form of gambling. At Bournemouth University we have conducted an interview study with 20 game players who are familiar with loot boxes, and we expect to publish the results in August 2019. We would be pleased to share the results with the Committee if it can assist this inquiry.


17 July 2019



[3] The BU Gambling Group’s research is available through the below website, scroll down to Publications section:

[4] Elvira Bolat, Emily Arden-Close, Raian Ali. Building a responsible ecosystem: examining trust and responsibility in the gambling industry. Bournemouth University, Technical Report. Dec 2018. This paper is currently under peer review with International Gambling Studies:

Bolat, E., Arden-Close, E., Ali., R. , and Renshaw-Vuillier, L. 'Towards building a trustworthy and responsible online gambling -  an insiders’ view. International Gambling Studies (under review).