Insightful comments from the Gambling Commission CEO and ABSG Chair during Safer Gambling Week 2021

In blogs published on the Gambling Commission’s website during this year’s ‘Safer Gambling Week’ (1 to 7 November 2021):

  • Andrew Rhodes, the Commission’s CEO has offered his reflections on the subject of safer gambling and the need to see much greater compliance from the industry across the board, and
  • Anna van der Gaag CBE, Chair of the Advisory Board for Safer Gambling (ABSG) has reflected on the need for listening, learning and acting when it comes to tackling gambling harms.

Other insightful comments by Andrew Rhodes feature in an article within the 4 November 2021 edition of The Racing Post entitled ‘We still see far too many extreme cases’ – Gambling Commission chief speaks out.

You can read below each of the above-mentioned blogs and selected comments made by Andrew Rhodes in The Racing Post article.

1. Andrew Rhodes blog

Facing the facts on the road to safer gambling

Whilst many will be discussing the merits or otherwise of ‘safer gambling’ during this Safer Gambling Week, Gambling Commission CEO, Andrew Rhodes, offers his reflections and the need to see much greater compliance from the industry across the board.

I’m a big football fan and a long-time supporter of Swansea City (no need, I’ve heard them all). As any football fan will tell you, the best matches are when you don’t notice the referee. Clean competition, where no one’s hurt and everyone goes home having been entertained. I sometimes think there are a lot of parallels between the job of a football ref and our job at the Gambling Commission.

In an ideal world we would have little to do. But we’re nowhere near that. The last few years is a tale of escalating enforcement by the Commission, not less. Now we want to get to that ideal, with the level of harm caused by gambling dwindling, and having a constructive and collaborative relationship with industry can be part of how we get there. From my meetings with industry, I know operators want that too. But if we want a grown up relationship, we need to start from shared facts.

First, gambling is normal. Some will attack that statement, but we shouldn’t shy away from it. Over 40% of the population gambled in the last four weeks and over half of them did so online. That’s tens of millions, buying a lottery ticket, betting on sport, playing bingo and the rest.

But another fact we shouldn’t shy away from is that gambling exists to make a profit, taking money from its customers. At over £14 billion, gambling in Great Britain is the size of British agriculture. £450 per second was lost by people gambling in Great Britain in 2019/20. For millions this is the cost of having a good time.

But for hundreds of thousands of people it’s problem gambling. It is harm.

It’s people suffering from financial, mental and physical harm because of either their own gambling or that of their loved ones or friends. It’s real, life-changing and can happen to anyone.

It’s also a churning, changing group of people too. There is nothing static about it.

Gambling is normal but harm must not be. We will continue to work to drive the levels of harm down. There are still far too many operators not abiding by our rules and that is not acceptable. We want a constructive relationship with industry. But it must be on the basis of compliance and for all the good efforts made, we still see too many instances of things that everyone agrees are things we should not be seeing. These things are not historic – they are happening now.

And this is why the Single Customer View project is such a great opportunity for industry.

This is not some Big Brother style ‘gamblers register’. It’s about helping operators solve their own problem. Look at Pubs. There is a point where a Pub landlord will stop serving you, often as much for your own good as it is for their business. And other Pubs won’t serve that same customer either. Good operators don’t want to serve a customer who has already had enough elsewhere. The Single Customer View is about preventing just that. We know it’s technically possible. The ICO has published on how it can be done safely, protecting people’s data. It’s now for industry to trial a solution.

I’m clear on the road ahead and so is the Commission. We are more focussed than ever on our core purpose of making gambling fairer, safer and crime free. We want to collaborate with the gambling industry in this work. But to do so we all need to face the facts.

2. Anna van der Gaag blog 

We don’t have enough evidence yet?

Anna van der Gaag CBE, Chair of the Advisory board for safer gambling (ABSG) reflects on the need for listening, learning and acting when it comes to tackling gambling harms.

Evidence-based medicine, whose philosophical origins extend back to mid-19th century Paris and earlier, is the conscientious, explicit and judicious use of current best evidence in making decisions about the care of individual patients. The practice of evidence-based medicine means integrating the best available external clinical evidence from systematic research with individual clinical expertise and the patient’s values and expectations.

Sackett, Scott Richardson, Rosenberg, Haynes (1998, p.2)

One of the challenges of moving forward with addressing gambling related harms is the often repeated “We don’t have enough evidence yet”.

As a life long researcher, I support the need for more research. But there is an urgency here. Individuals are suffering harm. So what kind of evidence are we looking for? For what purpose?

Those involved in the measurement of health care have tended to use somewhat polarised frames of reference; positivist versus interpretive, objective versus subjective, empirical versus narrative, expert versus lay person, each one claiming superiority over the other in an increasingly politicised world of measurement. What creates a way through this forest of conflicting views?

Action can inform research

Dave Sackett, one of the great founding fathers of evidence-based practice in healthcare, frequently lamented the misinterpretation of EBM as one kind of evidence, usually quantitative, randomized and expensive. He, along with other key system leaders in health care, argued strongly that evidence-based practice involved the interaction of three elements – research, clinical judgement and the voice of users, and not, as many proposed, research evidence alone.

More than twenty years ago, Muir Gray asserted that health care would, in his words “not only need to retain and improve on the achievements of the modern era but also respond to the requirements of a post-modern society, namely concern about values as well as evidence.”

These observations are no less relevant today than they were some two decades ago. We must not wait for one type of research evidence to be fully complete before moving forward on planning provision of services. We must evaluate carefully as provision evolves, and adapt accordingly, listening to those who already provide treatment and support.

We must listen to what people with lived experience tell us. For individuals, populations, and for society as a whole, these tested observations are key organizing principles that can help to create a path to better understanding and improved access to services and support.

About the advisory board for safer gambling

The advisory board for safer gambling (ABSG) provide independent advice to the Gambling Commission with the aim to help achieve a Great Britain free of gambling related harms. They are one of three advisory groups who support the Gambling Commission in its work to make gambling fairer, safer and crime free.

The ABSG also supports the Gambling Commission as it collaborates with others to implement the National Strategy to Reduce Gambling Harms, ensuring progress is made on it’s strategic commitments.

You can find out more about their work by visiting the ABSG hub on our website.


  • Muir, G. (1999) Postmodern medicine Lancet 354, 1550.
  • Sackett, D, Scott Richardson, W, Rosenberg, W, Haynes, RB. (1998). Evidence-based medicine. Edinburgh: Churchill Livingstone.

The Racing Post article

Also particularly worthy of note are the following revealing comments by Andrew Rhodes an article in the 4 November 2021 edition of The Racing Post entitled ‘We still see far too many extreme cases’ – Gambling Commission chief speaks out:

  • although in general terms be believes that “the industry has the resources, knowledge and ability to achieve a very high level of compliance and safety and a very low level of harms”, there are still “far too many extreme cases that everybody in the industry agrees we should not see”, adding “as one operator said to me today, ‘We have to stop the own goals’. I think Safer Gambling Week is part of that.”
  • although there has been a ‘significant decrease’ in the overall problem gambling rate (0.3% in the year to September 2021, compared to 0.6% in the year to September 2020), it is difficult to say whether the reduction is sustainable given the upheaval caused by Covid-19, adding that:
    • “everybody is right to treat these with a little bit of caution, not because I think they are wrong – I think they are right – but we need to understand what the continuing trend is because it has been such a disturbed period of time” and that
    • there is “a lot of room for improvement”, commenting further that: “there is a lot of variability between operators and we are still seeing a high level of compliance issues in our inspections that we would not expect to see. There are quite a lot of extreme cases of people losing tens of thousands of pounds in a very short window without intervention. We don’t expect perfection but we are not seeing those cases reducing in numbers fast enough. They are not historic cases, as some would argue, they are real time and we are seeing them too often”.
    • “A lot of progress has been made and I don’t want to take away from that, but these own goals are why some people think the industry is not taking this seriously.”

Commenting on public and Parliamentary criticisms levelled against the Commission, Rhodes has commented in The Racing Post article:

  • on the subject of the collapse of Football Index earlier this year:
    • “I don’t accept that we took no steps and had no intervention at all. I think the criticisms that are fair are that we could have drawn things to a close earlier but the outcome would have been the same” and
    • “With anything we think is novel and not what we might call more typical gambling, we now look at it differently in terms of what might its risk profile be in future, what exposure might it have”
  • on the subject of highly critical reports published last year by the National Audit Office, the Gambling Related Harm APPG and the House of Commons Public Accounts Committee in relation to what he described as “an emotive, charged, political and opinion-heavy sector”:
    • “There are things that we need to do better and I think there always will be” and
    • “The industry is 800 times the size of the Gambling Commission, so in order to get the best outcomes you need to focus on where you can get the greatest impact with those resources and I think that’s a key focus.”
  • on the subject of the ongoing investigation into the competence and effectiveness of the regulator of British gambling, the Gambling Commission”,currently being undertaken by the Parliamentary All Party Betting & Gaming Group (APBGG):
    • “If there are organisations that feel abject terror from the regulator I would be surprised. It’s definitely true there are operators who do not like being on the wrong end of enforcement action so the very easy answer to that is comply with the regulations and it won’t happen.”
  • on the subject of the Commission’s Remote Customer Interaction Consultation and Call for Evidence (that ran between November 2020 and February 2021) and, in particular, its proposal “to introduce stronger requirements, including that operators must conduct defined affordability assessments at thresholds set by the Commission“:
    • “I think this is something that will most likely form part of our advice around the Gambling Act review. We don’t plan to introduce something right now – but that doesn’t mean to say we are going to wait for the final culmination of the Gambling Act review if we think there are things that we need to do to safeguard consumers.”
  • on the subject of the potential illegal online gambling black market risk in the event that overly restrictive gambling regulatory requirements (such as more stringent affordability checks) are introduced:
    • although such a risk does exist, he thinks: “we have to be careful not to overstate it and what we can’t do is use it as a reason not to raise standards within the legitimate licensed industry. We can’t have a race to the bottom.”
  • on the subject of fears that a ‘singular customer view’, under which information from different gambling operators could be shared, could potentially lead to betting operators closing down accounts of successful customers:
    • “Single customer view is about triggers of harm behaviour, not triggers of successful gambling. If the industry tried to build that you would see intervention from the regulator because that would be going well beyond what we are trying to do.”
  • on the subject of the future role of the Gambling Commission:
    • although his ideal scenario is for it to get to the position “where all we have to do is issue licences”, the Commission “will never get all the way there but that is really where I would like us to be. We shouldn’t need to take action.”