The future of the gambling industry hangs in the balance


Back To News

The future of the gambling industry hangs in the balance

Bans and limits make for easy headlines, however, if the industry is to make sustainable, long-term progress and significantly reduce harm, it must adopt a collaborative, data-driven approach to addressing the protection of at-risk players, argues Will Mace, founder of EQ-Connect.

(Also published in EGR Intel –

The gambling industry has undoubtedly become a ‘safer’ place for players in the last few years with new regulation bringing additional safeguards, clearer consumer guidelines and advice and more ways to seek help, however it unquestionably still has a long way to go. There are still far too many cases of significant harm being suffered, as any of the treatment centres, such as the Gordon Moody Association, will confirm.

Fortunately, further change is inevitable as both the industry increasingly coalesces around the need to ‘do more’, and external pressure on responsible gambling approaches boiling point. What is less sure, however, is the direction of change.

In the last six to 12 months there has been a significant escalation in public and political discourse about the state of the industry, as commentators set the tone and parameters for the forthcoming legislative review. The most vocal lobby want to make gambling safer through a series of blanket measures, universally applied to all. The language used is primarily of control, of bans and boundaries, seeking to prohibit ‘all advertising, sponsorship, marketing, and inducements’ and to impose stake, deposit and prize limits. They want to restrict gambling to the point where it is all but impossible for anyone to suffer any form of harm; and they certainly make a passionate argument, citing some of the many tragic cases to reinforce their perspective.

It is easy to see why a restrictive approach such as this might appear attractive – initially at least – bans and limits make for easy headlines and facilitate the claim that strong, effective action has been taken to protect the vulnerable.


This lobby makes the assumption that anything more than the occasional flutter is some sort of sign of delinquency, that requires the patrician arm of legislation to protect against. They do not seem to allow for the fact it may be possible to enjoy more – even much more – than a bet or spin or two, without risk of delinquency or of suffering harm.

According to Health Survey figures[1] 2.7% of adults were considered low-risk gamblers, 0.8% were classed as moderate-risk gamblers, and a further 0.5% were classified as problem gamblers. Low risk is defined as gamblers who experience a low level of problems, with few or no identified negative consequences. By this data, 96% of adults are not at-risk. This is not to seek to marginalize, or to downplay the problem in any way, but rather to highlight that not every gambler is at risk of harm and so blanket measures are simply inappropriate. It is clearly possible to enjoy more than the occasional flutter without risking harm and without needing such patrician protection.

The data-driven identification approach

How then do we balance the urgent need to do more to protect those that are at risk while allowing those that are not at-risk to gamble as they wish?

A more nuanced approach than universally applied bans and limits is clearly needed, one where the priority is firmly on the identification of at-risk players followed by subsequent interaction with them to reduce risk and prevent harm.

While this requirement does currently exist in the LCCP (licence provisions) – tucked away in Social Responsibility Code Provision 3.4.1 – the House of Lords Select Committee felt it so important that they recommended making the identification and prevention of harm one of the Commission’s central statutory aims. Disappointingly, there has been little focus on this recommendation in much of the subsequent discourse.

The recommendation should go further. The UK Gambling Commission should clearly define and describe what it means by the identification and prevention of harm – and it should set a very high bar.  Currently, the UKGC offers little more than arbitrary guidance on ‘what to look for’ and makes vague and unsatisfactory statements such as ‘use a range of indicators relevant to your business’ and ‘how you monitor activity depends on your business’.

Going above and beyond

The Commission should specify a minimum standard – a machine learning based behavioural analysis model – to identify any risk of harm, requiring every operator to employ, or to exceed it, as an enforceable minimum standard as part of their licence conditions. And they should back this standard, not just with the ad hoc fines they have issued of late, but with the threat of licence terminations and even personal criminal liability.

Implementing such a data-driven approach would of course take investment, collaboration, and bold leadership – both from the Commission and from the industry – but it would deliver significantly enhanced protection to the at-risk, at the same time as allowing those not at-risk – the 96% – to gamble as they wish.

Industry voices might respond by saying “we are doing this already”, and for a handful of operators this is true, but for many, it is far from the case. The industry needs a comprehensive approach in which every operator is applying consistent minimum standards; it needs a collaborative approach in which data on at-risk players is shared between operators to achieve a common view of a players risk of harm (Neil McArthur’s ‘silver bullet’); it needs a more transparent approach in which data on at-risk players is available for real-time 3rd party inspection; and finally, it needs a much more vocal approach, if the advocates of bans and limits are not to win the day.

The future of the gambling industry is hanging in the balance…

[1]    Health Survey England 2018, conducted by NHS Digital and released in December 2019.  Republished by UKGC Gambling participation in 2019 – Annual Report.

  1. Terms

By accessing the website at, you are agreeing to be bound by these terms of service, all applicable laws and regulations, and agree that you are responsible for compliance with any applicable local laws. If you do not agree with any of these terms, you are prohibited from using or accessing this site. The materials contained in this website are protected by applicable copyright and trademark law. 

  1. Use Licence

Permission is granted to temporarily download one copy of the materials (information or software) on EQ-connect’s website for personal, non-commercial transitory viewing only. This is the grant of a licence, not a transfer of title, and under this licence you may not: 

This licence shall automatically terminate if you violate any of these restrictions and may be terminated by EQ-connect at any time. Upon terminating your viewing of these materials or upon the termination of this licence, you must destroy any downloaded materials in your possession whether in electronic or printed format. 

  1. Disclaimer

The materials on EQ-connect’s website are provided on an ‘as is’ basis. EQ-connect makes no warranties, expressed or implied, and hereby disclaims and negates all other warranties including, without limitation, implied warranties or conditions of merchantability, fitness for a particular purpose, or non-infringement of intellectual property or other violation of rights. 

Further, EQ-connect does not warrant or make any representations concerning the accuracy, likely results, or reliability of the use of the materials on its website or otherwise relating to such materials or on any sites linked to this site. 

  1. Limitations

In no event shall EQ-connect or its suppliers be liable for any damages (including, without limitation, damages for loss of data or profit, or due to business interruption) arising out of the use or inability to use the materials on EQ-connect’s website, even if EQ-connect or a EQ-connect authorised representative has been notified orally or in writing of the possibility of such damage. Because some jurisdictions do not allow limitations on implied warranties, or limitations of liability for consequential or incidental damages, these limitations may not apply to you. 

  1. Accuracy of materials

The materials appearing on EQ-connect’s website could include technical, typographical, or photographic errors. EQ-connect does not warrant that any of the materials on its website are accurate, complete or current. EQ-connect may make changes to the materials contained on its website at any time without notice. However EQ-connect does not make any commitment to update the materials. 

  1. Links

EQ-connect has not reviewed all of the sites linked to its website and is not responsible for the contents of any such linked site. The inclusion of any link does not imply endorsement by EQ-connect of the site. Use of any such linked website is at the user’s own risk. 

  1. Modifications

EQ-connect may revise these terms of service for its website at any time without notice. By using this website you are agreeing to be bound by the then current version of these terms of service. 

  1. Governing Law

These terms and conditions are governed by and construed in accordance with the laws of UK and you irrevocably submit to the exclusive jurisdiction of the courts in that State or location. 




1. Privacy Policy 

EQ-Connect (EQ) have developed this Policy to describe how we handle personal information collected from persons who use the EQ website, or who, following an invitation from EQ during any marketing and /or event communication processes, such as in –person, email, telephone, text messaging direct mail and online, provide personal information to EQ. 

Personal information means any information relating to an identified or identifiable natural person; an identifiable person is one who can be directly or indirectly identified by reference to an identifier such as name, an identification number, location data, online identifier or to one or more factors specific to the physical physiological, genetic, mental, economic, cultural, or social identity of that person. 

Sensitive personal information is a subset of personal information and is generally defined as any information related to racial /ethnic origin, political opinions, religious beliefs, trade union membership, physical or mental health, or other medical information including biometric and genetic data, or sexual life preferences. In some instances, sensitive personal information may also include criminal allegations or convictions, precise geolocation information, financial and bank account numbers and unique identifiers such as government issued security numbers, driver’s licence, and passport numbers. 

When you visit the EQ website we collect personal information about your visit. Our web server automatically records details about your visit (for example, your IP address, the type of browser used, the EQ website pages that you visit and the duration of your visit). 

In addition, we collect the personal details which you provide online, for example, when you enter personal details (e.g. name, gender, address, email address, phone number) on a website registration page. 

We also collect personal information directly from you during sales or purchasing activities and/or in connection with marketing events, for instance: business cards; personal contact details; emails and other social media. 

In some circumstances we may also collect personal information about you from third parties, such as your employer, or professional organisations to which you belong, or personal information that you have placed in the public domain, such as from Facebook or LinkedIn. 

By providing your personal information as described above, or by proceeding with your visit to EQ’s websites, you are accepting and consenting to the practices described in this Privacy Policy, and you agree to the transfer, storing or processing of your personal information in the manner described in this Policy. 

If you subsequently wish to withdraw your consent to the collection and handling of your personal information, then you may follow the instructions on any communications you receive from us or contact 

Other websites, which are not operated by EQ, reached by links from these sites are not covered by this Policy. We encourage our users to be aware when they leave our site and to read the privacy statements of each website that collects personal information. Please note that we do not accept any responsibility or liability for policies or the use and/or reliance of data appearing on other websites. 

1.1. Information we collect 

We collect and process the following personal information (which may in certain circumstances include sensitive personal information) about you: 

Information you give us: This is information about you that you give us by filling in forms on our site or by corresponding with us by phone, e-mail, text messaging, direct mail, online or otherwise. It also includes information you provide us through electronic or hard copy business cards, for instance, when you fill out: contact forms; content download requests; event registration forms; information request forms and/or when you report a problem with our site. 

If you are a job applicant we collect, store and use information you provide on your application form(s) for the purposes of recruitment. The information you give us may include your contact details, job application, curriculum vitae, covering letter and any references provided. It may also include sensitive personal information, for instance, on a disability that is relevant to your interview, for which we will require your explicit consent to collect and retain your personal information. 

Regarding each of your visits to our website we will automatically collect the following information: 

We, by using a tracking code from a third-party provider, also collect information on the public IP address of the requesting computer. This tool provides us with information as to the company that has visited our website(s), but individuals cannot be identified by this tool. 


1.2. Cookies 

Cookies are small files of letters and numbers. These files are either stored in the memory of your computer or other device such as mobile phones or are placed on the hard drive of your device. 

Our website uses cookies to provide you with an effective browsing experience. You can read more about this in our cookie policy. 

1.3. Uses made of the information 

Regarding information you give us, we will use this information for: 

Regarding collected information, we will use this information: 

Regarding information we receive from other sources, we will only collect and handle your personal information in accordance with your contact preferences. 

You can also subsequently inform us of your contact preferences, including any request to withdraw your consent to the collection and handling of your personal information by contacting: Data Protection Officer, EQ-Connect, Parsonage Farmhouse, Marlborough, SN8 3SD, UNITED KINGDOM 

1.4. Sharing Information 

Although we make every effort to preserve user privacy, we may need to disclose personal information when required by law, including (without limitation) to comply with applicable local laws or judicial proceedings, court orders or any other legal processes. 

Personal information is also used by companies in the EQ Group. When we share personal information, we do so in accordance with data privacy and security requirements. All our employees and contractors are required to follow a group data privacy policy when handling personal information. 

It may be shared under contractual control with other companies who collect and handle personal information on our behalf. For these purposes information may be transferred to other companies located outside the European Economic Area. Any personal information that is transferred will be protected accordance with applicable laws. When we transfer personal information from the European Economic Area to other countries in which applicable laws do not offer the same level of data privacy protection as GDPR, we take measures to provide an appropriate level of data privacy protection. 

In some circumstances personal information may be shared with third parties for legal reasons, such as: 

1.5. Storing Information 

EQ is a UK based organisation, but personal information may be stored and processed outside of the European Economic Area. We take steps to ensure that information we collect is processed according to this Privacy Notice, the requirements of GDPR and other applicable laws. 

1.6. Retaining Information 

EQ may be required to use and retain information for legal and compliance reasons, such as the prevention, detection, or investigation of a crime; loss prevention or fraud. We may also use personal information to meet our internal and external audit requirements, information security purposes, and as we otherwise believe to be necessary or appropriate: 

  1. a) under applicable law;
  2. b) to respond to requests from courts, law enforcement agencies, regulatory agencies and other public and government authorities;
  3. c) to enforce a contract; or
  4. d) to protect our rights, privacy, safety or property or those of other persons

1.7. Data Security 

We have physical, electronic and administrative security processes in place in our facilities to protect against the loss, misuse, unauthorised access, or alteration of information. Our company uses secure encryption technology for all sensitive and financial personal information transmitted. 

Despite this, the transmission of information via the Internet is not completely secure and we cannot guarantee the security of your personal information transmitted to our site; any transmission is at your own risk. We do not accept liability for any interception of your personal information that may occur. 

1.8. Your Rights Correcting/Updating/Deleting/Deactivating/Accessing Personal Information 

If you wish to correct/delete/edit/deactivate and/or update information or you no longer require our service, you can notify us of this change by contacting us (see below). 

You may, where permitted by GDPR, submit a Subject Access Request (“SAR”) to the Data Protection Officer to check whether we hold your personal information; and/or, require us to provide you with a copy of your personal information; and/or, require us to correct or delete or restrict the processing of any of your personal information that is inaccurate or that you don’t want us to hold. This request should be made in writing to our contact address (below). 

1.9. Contacting Us 

Data Protection Officer, EQ-Connect, Parsonage Farmhouse, Marlborough, SN8 3SD, UNITED KINGDOM 

1.10. Other 

Emails and other electronic communication with us and/or any EQ company may be monitored. Calls to us and/or any EQ company may be recorded for business continuity, quality control, regulatory and/or monitoring purposes. 

1.11. Changes to our Privacy Notice 

We may, from time to time, make changes to our Privacy Notice. Please check back frequently to see any updates or changes to our Privacy Notice. 

GDPR definition 

As from 25 May 2018 onwards, Regulation (EU) 2016/679 (the “General Data Protection Regulation” or “GDPR”) and the Privacy and Electronic Communications (EC Directive) Regulations and any guidance or codes of practice issued by the European Data Protection Board or Information Commissioner (the UK’s independent authority established to uphold information rights) from time to time (all as amended, updated or re-enacted from time to time); and with effect from the date the United Kingdom exits the European Union (“Brexit”) such applicable law of the United Kingdom as has been enacted to provide for Brexit and the transposition into domestic law of the GDPR and/or replacement by new legislation achieving similar or equivalent effects to the GDPR.