UK LEGAL COMMENT
similar results to the experimental data. The overall participation rate in gambling during the previous four weeks in the telephone survey of 43.5%, compared to 49.5% in the new survey. Whilst some variation might be expected using different
survey methodology (and we can see that a slightly higher proportion of respondents to the new survey were gamblers), the difference between the latest telephone survey’s estimate of 1 in 500 people being a problem gambler and the new survey’s 1 in 40 is huge. It is tempting to conclude that the telephone and mini screen methodology is inadequate, which certainly justifies the development of a new survey format by the Commission, however the Government’s Health Survey should also be considered.
Differences from the Government’s Health Survey Like the Commission’s new survey, the Government’s Health Survey for England used the full 9 question PGSI screen to assess problem gambling rates (it also assessed rates using the slightly different DSM-IV screen), so it might be expected to yield more accurate results than the telephone survey. The Health Survey found that 0.3% of respondents scored 8+ points on the full PGSI screen. The methodology was again different, in this case the survey was conducted entirely through a self-completion booklet rather than the mix of online and paper used in the Commission’s new survey, but both surveys were self-completed and confidential. As with the telephone survey, the Health Survey showed a
somewhat lower overall gambling participation rate. The Health Survey asked whether the respondent had gambled in the past 12 months and found that 50% responded positively, compared to 61.3% in the Commission’s new survey. This is likely explained by the fact that the Health Survey took place in a different context, including gambling questions amongst other health questions. This appears to have resulted in a wider range of people completing the survey, rather than it having a particular appeal to gamblers. But, again, the fact that a higher proportion of gamblers
completed the Commission’s new survey compared to the Health Survey cannot fully explain the difference in problem gambling rates found. Even if 100% of respondents to the Commission’s new survey had been gamblers, we would expect a problem gambling rate of just 0.5%, if results accorded with the rate of problem gambling amongst gamblers found by the Health Survey. The differing data for the number of respondents who scored
0 on the PGSI (no risk of gambling harm) is also noteworthy. The Health Survey estimated that 94.2% of gamblers fall into this category, whereas the Commission’s experimental survey indicates this is just 77.1% of gamblers. To put this into context, scaled up to the adult gambling population the difference is in the region of 5 million people.
Differences from the new survey’s own pilot The Commission’s new Gambling Survey project started with a consultation in 2020, then proceeded through three stages, including a pilot of the new survey methodology with results published in May 2022. This pilot found a problem gambling rate of 1.3% - again higher than the Health Survey and telephone surveys, but lower than the more recent result. The 1.3% result was somewhat explained by the fact
that 63% of respondents to the pilot survey were those who had gambled in the past 12 months. The review report on the pilot survey concluded that the
finding of a higher problem gambling rate compared to the telephone survey may also have been “because people provide more honest answers when reporting behaviours online than when filling in self-completion questionnaires when an interviewer or other family members are present.” This explanation doesn’t provide any further insight into why the newest iteration of the pilot survey produced even higher results, however, with the latest survey able to be completed online or on paper.
Next steps The Commission has engaged Professor Patrick Sturgis, Professor of Quantitative Social Science at the London School of Economics, to undertake an independent review of the methodology for the new survey. Presumably his review will look to understand the impact of self-selection by those with an interest in gambling and the different completion methods, along with additional factors which may have influenced responses such as the other questions and statements made within the survey. Professor Sturgis’ findings and recommendations are due to be published in early 2024, ahead of the new methodology being used for the Commission’s official statistics later that year. What this proposal lacks is sufficient time for the Commission to revise the methodology and re-test a new approach, assuming that Professor Sturgis recommends some significant changes. This seems the most likely outcome, unless his analysis provides strong reasons to be confident that the new methodology is producing accurate results while the telephone surveys and Health Surveys were not. In the meantime, it is rather disingenuous of the Commission
to imply that we should not compare the latest data to previous results, on the basis that its purpose is to track changes to gambling behaviour in the future. Problem gambling statistics are regulatory referenced in public discourse and are being used right now to inform gambling policy decisions arising from the Government’s White Paper. In addition, remote gambling operators are specifically required to consider whether their levels of customer interaction correspond to the levels of problem gambling for the gambling activities they offer. With the new survey methodology intended to replace the Health Survey data, which is currently used for this purpose, it is vital that operators can have confidence in the figures.
Melanie is a gambling regulatory lawyer with 13 years’ experience in the sector. Melanie advises on all aspects of gambling law including licence applications, compliance, advertising, licence reviews and changes of control. She has acted for a wide range of gambling operators including major online and land-based bookmakers and casinos, B2B game and software suppliers and start-ups. She also frequently advises operators of raffles, prize competitions, free draws and social gaming products. Melanie has a particular interest in the use of new technology for gambling products and novel product ideas.
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