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Fair Game:
Producing gambling research
The Goldsmiths Report
R. Cassidy, C. Loussouarn, A. Pisac
Text © Rebecca Cassidy, Claire Loussouarn & Andrea Pisac 2013
Design by Sam Kelly
The research leading to these results has received funding from the
European Research Council under the European Union's Seventh
Framework Programme (FP/2007-2013) / ERC Grant Agreement n.
263443.
On the back cover: Wordle illustration demonstrating the frequency of
article keywords drawn from the three most recent issues of the Journal
of Gambling Studies and International Gambling Studies. International
Gambling Studies, Volume 12 Issue 3 (2012) to Volume 13 Issue 2
(2013); Journal of Gambling Studies Volume 29 Issue 1 (2013) to Vol-
ume 29 Issue 3 (2013).
1
The authors
In 2011 we began a four-year project funded by the European Research Council (ERC) to investigate new
ways to study emerging gambling phenomena across territorial, conceptual and disciplinary boundaries.
While we do not attribute any essential moral value to gambling we are interested in the inequalities it
generates within and between communities.
e work across a number of different scales, from the global and exceptional to the local and
everyday. The relationship between financial services, gambling and capitalism is of interest
to us, for example, as are apparently mundane encounters between blackjack players in a
casino in Nova Gorica. We are equally interested in the production of gambling as its consumption: it is
impossible to understand the impact of gambling products without considering the conditions which enable
and constrain their production.
In order to study these phenomena we have spent several years embedded within different gambling
cultures. Claire Loussouarn has worked with Chinese casino customers in London and more recently with
spread betting companies and the financial services industry in the City of London. Andrea Pisac is a trained
croupier who has worked in Nova Gorica and London. Rebecca Cassidy has worked in the horse racing
industries in the United Kingdom and the United States and in betting shops in London.
Rebecca Cassidy, Claire Loussouarn, Andrea Pisac, Goldsmiths, December 2013
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2
Abbreviations
BGPS British Gambling Prevalence Survey
CAGR Compound annual growth rate
DCMS Department for Culture, Media and Sport
DEFRA Department for Environment, Food and Rural Affairs
ERC European Research Council
ESRC Economic and Social Research Council
FOBTs Fixed odds betting terminals
ILSI International Life Sciences Institute
MRC Medical Research Council
NCRG National Council for Responsible Gambling
NDA Non-disclosure agreements
NLC National Lottery Commission
RGF Responsible Gambling Fund
RGT Responsible Gambling Trust
RiGT Responsibility in Gambling Trust
3
Why this report?
y 2015, it is estimated that the global mar-
ket for gambling will have grown to €351
billion at a compound annual growth rate
(CAGR) of 3%. The recovery of this sector since the
financial crisis has been remarkable, from a low of
1.9% in 2009 to a high of 8.8% CAGR in 2011.1
This growth is driven by deregulation and the
search for tax revenue, new technologies and the
opening of new markets. Although some national
governments continue to ban gambling and to de-
pict it as a vice or moral failing, others, including
the United Kingdom (UK) and Australia, have re-
cast gambling as a form of entertainment. While
presented as a response to changes in customer
behaviour, in practice, changes in the classification
of gambling are the result of interactions between
the state and other regulators, the industry, and the
consumer. In rolling out new policies based on this
understanding of gambling as entertainment, gov-
ernments have claimed to rely on what they refer
to as ‘evidence-based policy’. However, in this re-
port we show that the process of producing
evidence about gambling is fraught with political
and academic trade-offs. If evidence based policy
is all that is protecting consumers from the potential
harms caused by the deregulation of gambling, just
how well does the system that produces evidence
work?
This report focuses on the production and consump-
tion of gambling research. Its purpose is to disrupt
existing relationships between users and producers
and to provide a set of recommendations around
which discussions about the future of gambling re-
search can take place. The report is based on
qualitative data gathered using semi-structured in-
terviews with 109 gambling research stakeholders
including researchers, policy makers and members
of the industry in the UK, Europe, Australia, North
America and Hong Kong / Macau. It also makes
use of quantitative data gathered from the field of
gambling studies, including content analysis of jour-
nals and conferences. It focuses on five themes:
problems with gambling, evidence, the field of
gambling studies, money, and access.
We asked academics to reflect on their own prac-
tices. How do they decide what questions to
pursue? What methods to use? How to secure
funding for research? How would they charac-
terise the field of gambling studies? We asked
regulators and policy makers how they used re-
search. How is gambling policy devised in
practice? What counts as evidence? Gambling in-
dustry executives described their encounters with
researchers. What does the industry think of aca-
demic research? How do they feel about
granting access to data?
ambling research is not an external com-
mentary on the global process of
gambling liberalisation and contraction,
but an important part of that process. As this report
will show, it enables certain ways of thinking about
gambling to flourish, and suppresses alternatives.
As in many other research areas, money flows to-
wards conservative or ‘safe’ ideas, while serious
questions may be left unanswered, or even unfor-
mulated.
The lack of useful evidence on which to base gam-
bling policy has been noted in several recent
reports, special issues of journals, and in literature
reviews.2 However, this is the first report to explore
these ideas using qualitative data. Its unique con-
tribution is to provide illustrations of precisely how
power operates in practice, in stakeholders’ own
words.
1 H2 Gambling Capital, 2012. ‘Leading global gambling nations – Asia and egaming continue to out perform’, URL:
http://tinyurl.com/kqsay2d. 14 November. Accessed 22 October 2013.
2 In the UK, see Culture, Media and Sport Committee, 2012. The Gambling Act 2005: A Bet Worth Taking? London: The
Stationery Office. In Australia, see Productivity Commission, 2010. Gambling, Report no. 50, Canberra. See the section
‘Further Reading’ (Appendix 3) for examples of special issues and literature reviews of gambling research.
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4
Conflicts of interest
etween 2006 and 2009 Cassidy and Lous-
souarn received £90,697.22 from ‘Research
into Problem Gambling’, a collaborative re-
search initiative between the Economic and Social
Research Council (ESRC) (lead organisation) and
the Responsibility in Gambling Trust (RiGT). The
money supported Loussouarn’s PhD study of Chi-
nese casino customers in London and Cassidy’s
fieldwork in betting shops in London. All aspects of
the grant were administered by the ESRC. The
RiGT did not communicate directly with Loussouarn.
Near the end of the project, Cassidy was asked by
the RiGT to submit press releases for prior ap-
proval, a request that she declined. Between 2007
and 2009 Cassidy received ad hoc support from
the National Lottery Commission (NLC) for the
Gambling Research Network, a group of early ca-
reer and PhD researchers coming together in
London two or three times a year. Money covered
refreshments and no explicit restrictions or induce-
ments were placed on the group by the NLC.
Cassidy, Loussouarn and Pisac have paid to attend
industry-sponsored events and attended free, in-
dustry-supported events. None of us have received
any direct payments from the industry to conduct
research or speak at conferences or events.
We have no other conflicts of interests to declare.
We are grateful to the ERC whose mission ‘allows
researchers to identify new opportunities and di-
rections in any field of research, rather than being
led by priorities set by politicians’.3 With their sup-
port, we feel able to challenge the way that
gambling research is funded and produced.
he wider contribution of this report is to pro-
vide an illustration of the more general
process through which research cultures are
formed and maintained. All research is embedded
in webs of significance that anthropologists might
refer to as ‘culture’. Understanding how these rela-
tionships operate is the first step to critical
participation in any field.
3 European Research Council Web Pages, 2013. ‘Mission’. URL: http://erc.europa.eu/mission. Accessed 14 November
2013.
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5
Contents
The authors ......................................................................................................................................................................... 2
Abbreviations ..................................................................................................................................................................... 3
Why this report? ............................................................................................................................................................... 4
Conflicts of interest ........................................................................................................................................................... 5
What have we learned? ................................................................................................................................................. 8
What should be done?................................................................................................................................................... 10
Navigating this report .................................................................................................................................................... 12
Stakeholder codes ..................................................................................................................................................... 12
Glossary of expressions ............................................................................................................................................ 13
How is research produced? ........................................................................................................................................... 15
How is gambling research produced? ........................................................................................................................ 16
Case study 1: The United Kingdom ........................................................................................................................ 16
Case study 2: Croatia. .............................................................................................................................................. 18
Case study 3: Macau ................................................................................................................................................ 19
Problems with gambling ................................................................................................................................................ 21
Evidence ............................................................................................................................................................................ 35
The field of gambling studies ....................................................................................................................................... 47
Money ............................................................................................................................................................................... 58
Access ................................................................................................................................................................................ 70
Appendices ....................................................................................................................................................................... 83
1. Methodology and scope of report .................................................................................................................... 84
2. Ethics ......................................................................................................................................................................... 92
3. Further reading ...................................................................................................................................................... 93
6
Figures
Figure 1 – Stakeholder codes ..................................................................................................................................... 12
Figure 2 – The UK Model ............................................................................................................................................. 18
Figure 3 – The Croatian Model .................................................................................................................................. 19
Figure 4 – The Macau Model ...................................................................................................................................... 20
Figure 5 – Problem gambling ..................................................................................................................................... 26
Figure 6 – RGT funding plan for 2013–14 ............................................................................................................. 31
Figure 7 – Gambling journal editorial board members........................................................................................ 49
Figure 8 – Gross annual win vs RGT research spend, UK, 2012 ........................................................................ 61
Figure 9 – Sample of focus group questions ........................................................................................................... 85
Figure 10 – Interviewee data ..................................................................................................................................... 87
Figure 11 – Percentage of interviewees quoted .................................................................................................... 89
Figure 12 – Quote frequency ...................................................................................................................................... 90
7
What have we learned?
Problems with gambling ((sections 1 to 14)
Researching gambling is a complex and politicised activity. Findings are used and misused to further agen-
das which change according to the political climate. Politicians are keen to accept the revenue that gambling
generates, and to encourage the industry to base their operations within their jurisdictions, but they are also
willing to accept the political capital which comes from opposing gambling when it suits them.
In a climate of unpredictable alliances and priorities gambling researchers can find themselves either co-
opted or strongly criticised. Gambling is a polarising subject – disagreements are often passionate rather
than rational. Those who favour less regulation – libertarian politicians and members of the gambling in-
dustry – present regulation as a patronising restriction of freedom. Those who favour slower deregulation
– Churches and pressure groups – might once have used religious arguments to support their position, but
are today more likely to look at the consequences of gambling rather than its moral status.
The debate is unified by a focus on ‘problem gambling’, which presents gambling as entertainment and
places the blame for ‘bad’ gambling with the individual. ‘Problem gambling’ is silent on the relationships
between the state and gambling operators.
Evidence (sections 15 to 25)
What counts as evidence is determined by political, rather than academic priorities.
A narrow definition of evidence makes many of the questions asked by policy makers impossible to answer,
either because they are too simplistic, or because the money does not exist to fund the projects which would
allow them to be answered, or because the data required to answer them is inaccessible.
The impact of evidence is unpredictable because its reception is contingent on factors including the consti-
tution of boards, the personalities of board members, timing and luck.
The function of ‘safe’ gambling research is rhetorical. It enables the existing relationships between research,
the industry and the state to endure, while meeting public expectations that research should take place.
Finally, as in many other fields, policy makers do not make decisions about gambling based solely on
evidence, however it is defined.
The field of gambling studies (sections 26 to 34)
The field of gambling studies is closed and tightly controlled. It is shaped by relationships with the industry
and the state as well as within the academic establishment. Relationships between researchers, treatment
providers and industry are often unmediated by formal academic structures.
Conferences are dominated by industry interests and do not encourage critical debate. The industry is
adept at discrediting research, leading some researchers to self-censor or opt out of publishing.
Competition for limited funding has created a research culture that is suspicious, sometimes hostile and even
paranoid. This creates inefficiencies including unproductive rivalries and duplication. It makes it difficult to
retain good researchers and to attract new recruits to the field.
Gambling research can create reputational risks for institutions. Senior management are not always sup-
portive of colleagues working in this area. Entering and remaining in the field of gambling studies is
therefore a considerable challenge, especially for early and mid-career researchers.
Gambling journals are not highly rated and the peer review process is conservative.
8
Gambling studies is not a prestigious field when viewed from other disciplines including anthropology,
sociology, law, geography and economics. It is behind studies of tobacco, alcohol and drugs in terms of
analysis, methods used, ethical transparency and dealing with conflicts of interest.
There is a lack of collaboration between gambling studies and related fields and a reluctance to accept
alternative methodologies and wider definitions of evidence. The impact of creating disciplinary bunkers is
that internally homogeneous communities of referees and commentators participate in self-referential dia-
logues, rather than engaging in wider, more creative discussions.
Money (sections 35 to 44)
As budgets shrink, researchers are under increasing pressure from their institutions to attract external money
and present the ‘impact’ of their work in economic terms. As a result, gambling research is increasingly
dependent on industry support.
In the UK, Australia, Canada, New Zealand and the USA, national research councils expect specialised
gambling charities to support research. The uncertainty of funding streams makes it difficult for researchers
to join the field and commit to the topic.
There are no neutral sources of funding. All funding bodies are motivated by particular priorities, shaped
by distinctive administrative and bureaucratic cultures, and sustain methodological paradigms. The interests
of funders are reproduced in diverse ways, including in the questions that are prioritised in calls, the ways
in which applications are assessed and the ways in which research is disseminated.
Voluntary contributions to intermediaries responsible for commissioning research are conceptualised as gifts,
rather than a cost of doing business. This allows the industry to maintain a sense of ownership over research.
There was no consensus among our participants about the implications of accepting funding from industry
sources, directly or indirectly. Some felt that research should produce benefits for funders, including the
industry. A few felt that industry funding did not affect their objectivity. Many were reticent, but pragmatic
about the necessity to work with industry support. Some rejected money from industry and were critical of
those who did not.
There is a lack of transparency about the conditions under which research is produced, and a poor under-
standing of conflicts of interests.
Access (sections 45 to 54)
The difficulty of gaining access to gambling environments and data is one of the biggest obstacles to
producing high-quality research. The industry has the most useful data but has limited incentives to share it
with researchers.
Most requests for access to data are denied or ignored. The industry reserves the exclusive right to deter-
mine what is and is not ‘commercially sensitive’.
In order to have their requests for access considered, researchers are encouraged to ‘seduce’ the operator
and to prove their trustworthiness by producing research that is uncritical, or commercially valuable.
Granting access to researchers may enhance an operator’s reputation for social responsibility.
Academics who produce research for the industry are often asked to sign non-disclosure agreements.
Successful access is often the result of a serendipitous encounter, or the cultivation of long-term relationships
with members of the industry. It is entirely unsystematic and often unrepeatable. Ad hoc arrangements of
these kinds may be well-intentioned, well-structured and produce worthwhile insights, but they leave the
relationship between commercial sensitivity and public accountability in the gambling industries untouched.
In doing so, they detract from the systematic discussion of access which urgently needs to take place.
9
What should be done?
Problems with gambling
The state should not represent itself as the neutral referee between operators and their opponents. They
are invested in commercial gambling as both operators and collectors of tax revenue. They also play a
central role in sustaining the focus on ‘problem gambling’, an approach that obscures the relationships
between the industry and the state.
Critical studies of gambling should investigate a wider range of social processes, including not only individ-
ual behaviour but also problem games, problem products and problem policies.
Evidence
Policy makers should consult a wider range of experts and recognise a wider variety of evidence. By
focusing exclusively on problem gambling and causal relationships they serve the interests of the industry,
which is interested in limiting regulation and minimising change.
The field of gambling studies
Gambling studies should, like other disciplines, have a professional code of ethics.
Where relationships exist between researchers and operators these should be a matter of public record
and embedded within formal academic structures.
Gambling studies journals and gambling conferences should require authors and speakers to declare con-
flicts of interest, not limited to the particular article or presentation in question.
Gambling studies journals should include referees and articles from a wider range of disciplines.
Researchers should publish in a wide range of forums in order to raise standards, ensure that discussions
about gambling are not restricted to gambling journals, and encourage colleagues outside gambling studies
to recognise gambling as a valid topic for research.
Money
Gambling research should be funded by a compulsory levy that is administered by research councils.
Calls for research should not focus exclusively on problem gambling.
Research councils should prioritise interdisciplinary projects, particularly those that seek to use innovative
methodologies.
Research applications should be reviewed by academics from a range of disciplines.
There should be a range of funding available to provide support for researchers at every stage of their
career, and for projects of all scales.
Expert panels should be constituted by academics from a range of disciplines who are at different points
in their careers.
10
Access
Access should be part of licensing and not based on ad hoc agreements.
Researchers should not enter into exclusive agreements with particular operators.
There should be a public discussion about the relationship between commercial sensitivity and public ac-
countability. Questions to be discussed include the use of non-disclosure agreements and the right of
operators to veto publications.
Researchers should disclose, in every publication, conference or event in which they are presenting their
research, the conditions under which they have been granted access.
11
Navigating this report
This report quotes a wide variety of stakeholders identified by codes which are explained below. The
report also uses expressions whose meanings are discursive and may not be instantly obvious. Their defini-
tions are found in the glossary, below.
Stakeholder codes
The analysis presented in this report has emerged from our discussions with 109 stakeholders in the gam-
bling research field. Their opinions are presented alongside relevant arguments.
We have devised a simple code which indicates the gender, type of stakeholder being quoted, the region
in which they work, their years of experience, and their case number. In some cases these details have been
withheld in order to reduce the likelihood that individuals may be identified.
STAKEHOLDER
Research User
Up – Policy Maker
Ur – Regulator
Ut – Treatment
Provider
STAKEHOLDER
Indu stry
In – New Industry
Io – Old Industry
STAKEHOLDER
Researcher
Ra – Academic
Rc – Commercial
Ri – Industry
GENDER
F – Female
M - Male
REGION
AU – Australia
CA – Canada
HK/M – Hong Kong / Macau
NZ – New Zealand
OE – Other European
SEE – South East Europe
UK – United Kingdom
US – United States
YEARS OF EXPERIENCE
(xx)
EXAMPLE
FRaUS(11)66
F – Female
Ra – Academic
US – United States
(11) – 11 years of experience
66 – code number NUMBER
xxx
EXAMPLE
MInUK(2)51
M – Male
In – New Industry
UK – United Kingdom
(2) – 2 years of experience
51 – code number
Figure 1 – Stakeholder codes
12
Glossary of expressions
The ‘gambling field’ consists of the networks and
relationships between stakeholders, including the
state and the industry, researchers and treatment
providers, their attitudes and interests. The rela-
tionships between research producers and those
who commission, fund and use research create the
political economy of the gambling field: the struc-
tural relationships that frame the movement of
money, knowledge and policy between stakehold-
ers.
Gambling studies is a sub-discipline which is dom-
inated by the so-called ‘psy’ sciences and
anchored in journals which include the Journal of
Gambling Studies, based at the University of Ne-
vada in Reno, and International Gambling Studies,
whose chief editor is based at the University of
Sydney.
Gambling research refers to all academic studies
about gambling carried out by members of a va-
riety of disciplines, including but not only, the
discipline of gambling studies.
Problem gambling is a socially and politically con-
structed behaviour which attributes the blame for
excessive gambling consumption to the ‘faulty’ in-
dividual.
Classified as an impulse control disorder in the most
recent edition of the Diagnostic and Statistical Man-
ual of Mental Disorders (DSM-V), pathological
gambling is a narrower category of gambling dis-
order which meets the criterion of psychiatric
diagnosis.
Commercial gambling refers to a profit-making
industry which is legal, state-owned or regulated
and licensed to provide a variety of gambling
products, such as casino games, betting or online
gambling.
‘Gambling industry’ is a heterogeneous group of
operators that vary across sectors and jurisdictions.
It includes land-based operators such as casinos
and betting shops, as well as online gambling pro-
viders.
‘Psy’ disciplines include psychology, psychiatry,
psychotherapy and psychoanalysis, which focus on
individual deficiencies, pathologies and deviations
from the norm.
A conflict of interest is a set of circumstances and
relationships that might undermine researchers’ in-
dependence in the way they conduct, design and
present their research findings. Conflicts of interest
are commonly understood as benefiting the inter-
ests of the gambling industry and the government,
but may equally arise in relation to research un-
dertaken for an anti-gambling charity or indeed
any interest group.
Social responsibility is the expectation placed on
gambling operators to provide adequate educa-
tion to minimise the risks of excessive consumption
among their customers.
Responsible gambling is a politically constructed
idea that individual consumers should be responsi-
ble for managing their own excessive behaviour.
Harm minimisation promotes the idea that man-
aging gambling harms is a matter of educating
consumers who are making poor or irrational
choices in their gambling behaviour. In its least crit-
ical version, it assumes that harm is an inevitable
consequence of commercial gambling, but not a
reason to limit its supply. On the contrary, harms
are to be managed through the encouragement of
‘responsible gambling’.
13
The Goldsmiths Report
14
How is research produced?
We all conduct research in our everyday lives,
whether this is searching online for a better deal
for car insurance or reading a review for a movie
in a newspaper. We learn to recognise and rank
different kinds of evidence both formally, through
schooling, and informally, by accumulating experi-
ences of using data successfully or otherwise. We
learn to distinguish between paid-for infomercials
and genuine news items (although this distinction is
increasingly fraught). We go to trusted sources for
information. Periodically, we experience crises of
confidence when a previously reliable source is ex-
posed as biased or incomplete. We adjust our
searches in relation to these events, and constantly
evaluate information on the basis of its origin, both
intuitively (correct spelling inspires confidence,
emoticons may not) and in relation to structures in-
cluding regulators, parliamentary enquiries and
the wider media.
esearch has also become a specialised in-
dustry, delegated to the scientific
community, and subject to a plethora of pro-
fessional standards. The most powerful recent
trend in this professionalisation is the emphasis
placed upon ‘impact’, particularly when measured
in economic terms. A host of accompanying terms,
‘deliverables’, ‘outputs’, ‘added value’ and so on,
have entered the academic lexicon. Professional
research, according to this model, is no longer an
esoteric pursuit that takes place in the studies and
libraries of the ivory towers, but an outward-look-
ing, commercially engaged and consequential,
real-world activity.
This model of research fits imperfectly with the in-
dustries described by Charles Livingstone and
others as ‘dangerous consumptions’ – gambling, to-
bacco, alcohol and drugs.4 Is the role of
researchers to contribute to the knowledge of the
tobacco industry or gambling operators to make
their products more profitable? Or is it to reduce
the harms produced by these industries on behalf
of the state? Both scenarios produce problems. The
first because, although it is now uncontroversial to
assert that research should be leveraged to assist
industries, particularly on a national or regional
basis, there is something distinctive about danger-
ous consumption industries that makes this proposal
distasteful, or at least politically risky. Unlike farm-
ing, or computer design, these industries are to be
tolerated, rather than encouraged. On the other
hand, the idea that research orients the moral com-
pass of the state in guarding against the harms
produced by these industries is unrealistic – the
state is the greatest beneficiary of their activities
in some cases. In Canada, the provincial and terri-
torial governments are the monopoly operators of
legal gambling, which, in 2010– 11, generated
revenue (after prizes paid, before operating ex-
penses deducted) of approximately
$13,956,407,000.5 In jurisdictions with private op-
erators, gambling generates significant tax
revenue: in Australia, an average of 10% of the
total tax revenue of state and territory govern-
ments, including 17% in the Northern Territory.6
This is the background to one of the pressing ques-
tions raised by this report: what is the purpose of
gambling research?
4 Livingstone, C. 2013. ‘Researcher profile: Monash University’, URL: http://tinyurl.com/lyrc97n. Accessed 14 November
2013.
5 Responsible Gambling Council, 2012. Canadian Gambling Digest 2010–2011.
6 Hancock, L. and O’Neil, M. 2010. Risky Business: Why the Commonwealth Needs to Take Over Gambling Regulation. Gee-
long, Vic.: Alfred Deakin Research Institute, 11.
R
15
How is gambling research produced?
Academic research is usually produced at univer-
sities and may be unfunded or funded by national
research councils (such as the ESRC in the UK), or
international funding bodies, such as the European
Research Council. Gambling research which takes
place in universities and centres may also be
funded by organisations and charities set up to dis-
tribute funds levied from the industry. These
organisations take a number of different forms and
include the Responsible Gambling Trust (formerly
RiGT) in the UK and the National Centre for Re-
sponsible Gaming in the US. Recently, and to an
increasing extent according to our participants, re-
search in universities is funded by direct
contributions from the gambling industry.
Commercial research is commissioned by various
trade associations, such as, for example, the Asso-
ciation of British Bookmakers in the UK, to comment
on gambling trends and issues as well as to edu-
cate their key stakeholders. Commercial research
can also be produced by financial investment com-
panies in order to explore, assess and promote
emerging gambling markets and products. For ex-
ample, KPMG, a global network of professional
advisory firms, has produced several reports on
online gambling: its key trends, regulation issues
and risks.
Policy research, commissioned by local authorities,
NGOs, Churches and governmental bodies, is un-
dertaken by academics and professional
researchers in order to collect data that can be
used to assess the impact of new gambling venues
or products; new regulation; and new prevention
and treatment programmes.
either the personnel who work in these
three fields, nor the data they produce,
are neatly divided or homogeneous. The
British Gambling Prevalence Survey (BGPS), for
example, was conducted and produced by
NatCen, a British independent social research
agency, in 1999, 2007 and 2010 with the aim of
measuring participation in all forms of gambling
and estimating the level of problem gambling. The
1999 survey was commissioned by GamCare (a
charity providing support and treatment for prob-
lem gamblers), while the 2007 and 2010 surveys
were commissioned by the Gambling Commission
(the UK regulator) and funded by the Department
for Culture, Media and Sport (DCMS). DCMS has
indicated that it will not support a further study. In
2013 the Association of British Bookmakers of-
fered to fund a fourth prevalence study to be
carried out by the Gambling Commission.7
Case study 1: The United Kingdom
In 2012, five years after the Gambling Act 2005
was fully implemented, a select committee found
that, ‘an area of consensus between industry bod-
ies, faith groups and academics alike was the need
for more and better evidence on problem gam-
bling and specifically about its causes’. They
recommended that ‘the Government works with the
Gambling Commission to provide a clear indication
of how it intends to ensure that sufficient high-qual-
ity research on problem gambling is available to
policy-makers’. They also noted that ‘it is particu-
larly important that research is seen to be
independent and comparable over time to show
whether or not there is a change in the levels of
problem gambling’.8
7 Anonymous. 2013. ‘British bookmakers make prevalence study offer’, TotallyGaming.com.
8 Culture, Media and Sport Committee 2012. ‘Conclusions and recommendations’, in The Gambling Act 2005: A Bet Worth
Taking?, 2.
The UK-based researchers we interviewed have
been supported by a variety of sources including
the gambling industry, research councils [the ESRC
and the Medical Research Council (MRC)], non-de-
partmental public body the National Lottery
Commission, and charities such as the Responsible
Gambling Trust (RGT). RGT is funded by voluntary
donations from the gambling industry. In the year
ending 31 March 2014 RGT plans to distribute a
total of £5,307,960: 84% of this money will be
N
16
spent on treatment, 10% on research and 6% on
education.9
lthough the funds allocated to research by
the RGT are limited (recent examples of
MRC grants on gambling range between
£214,202 and £1.6 million, for example), because
they are funded on a voluntary basis by the indus-
try and have specific responsibilities to support
gambling research, they act as a bellwether, re-
flecting and anticipating important changes in the
relationships between industry, research, the regu-
lator (the Gambling Commission) and the state.
RGT was formed in 2012 when a short-lived ex-
periment with a tripartite structure which
separated fund raising, distribution and setting the
research agenda failed.10 RGT is currently respon-
sible for both raising and distributing funds, in
accordance with a research strategy which is ad-
vised by the Responsible Gambling Strategy
Board and endorsed by the Gambling Commission.
The chief executive of the RGT is Marc Etches, who
led the campaign to create a casino in Blackpool
until 2004, afterwards acting as a consultant for
clients with interests in ‘leisure, gambling, hospital-
ity, and tourism’. In 2004, The Guardian described
him as ‘the gambling lobby’s most visible face’.11 A
year after taking up his post in 2013, he told In-
tergame that, ‘Gambling is a legitimate and
popular leisure activity and the industry’s record of
support for those who do suffer with problems is a
good one and perhaps ought to be more cele-
brated.’ He added that the industry is ‘kept at
arm’s length’ from research and that ‘the govern-
ance arrangements that we are putting in place
will ensure that everyone can have absolute confi-
dence in the independence and objectivity of the
research process’.12
Of the 27 interviewees who discussed RGT, 18 ex-
pressed serious doubts about their independence.
Eleven researchers told us that they would not con-
sider applying for funding from this source, either
because it didn’t provide grants that were large
enough to support meaningful projects, or because
it constituted a conflict of interests, or because it
would negatively impact their reputation for inde-
pendence.
Neil Goulden, Chairman of RGT, began his career
at Ladbrokes before moving to Gala Coral. At the
time of writing he is also Chair of the Association
of British Bookmakers (ABB), although he has re-
cently indicated his intention to step down from this
role. In 2013 Goulden wrote that, ‘There is very
clear evidence that problem gambling is about the
individual and not any specific gambling product
or products.’13 As our report will show, this idea is
strongly resisted by many researchers, who sup-
port the more nuanced perspective that the harms
caused by gambling emerge from a complex en-
counter between people, products and
environments.
oulden’s role at RGT has attracted criti-
cism in the UK among anti-gambling
campaigns and also from within the gam-
bling industry. Consultant Steve Donoghue has
blogged that, when research into electronic gam-
bling machines is published in September 2014,
during the build-up to the general election, ‘it will
be Neil Goulden who has to present its findings
with his RGT hat on and then respond to the results
with his ABB hat on. A farcical situation that can
only end up with those campaigning against the
Fixed Odds Betting Terminals (FOBTS) arguing that
the results have been influenced by the cuckoo in
the nest.’14
9 Responsible Gambling Trust Web Pages, ‘Commissioning plan’, URL: http://www.responsiblegamblingtrust.org.uk/Com-
missioning-plan. Accessed 14 November 2013.
10 For a description of the demise of this structure see Culture, Media and Sport Committee 2012, The Gambling Act 2005:
A Bet Worth Taking?, paragraphs 85–93.
11 Mathiason, N. 2004. ‘The man with a winning bet on Blackpool’, The Guardian, 26 September.
12 Liddle, S. 2013. ‘RGT stresses independence in Cat B research’, Intergameonline.com, 7 February.
13 Anonymous, 2013. ‘Gaming machines policy must be evidence based’, Centrallobby.politicshome.com, 13 April.
14 Donohue, S. 2013. ‘Why many hats don’t help when the sky falls in’, GamblingConsultant.co.uk, 22 February.
A
G
17
Intermediary
Industry State
Research Education Treatment
Academic Funding
Bodies
Tax
Voluntary Levy
The UK Model
Figure 2 – The UK Model
Case study 2: Croatia
The Ministry of Finance is responsible for regulat-
ing and licensing games of chance, including the
lottery, casino games, betting and slot machines in
Croatia. The Croatian Lottery (Hrvatska Lutrija) has
the monopoly on lotto games and a licence to or-
ganise all other games of chance. Other gambling
operators, who must be registered in Croatia, may
apply for licences for all other games of chance.22
All gambling operators pay a fixed annual licence
fee (valid for 15 years) and a fixed monthly tax
deducted from their monthly turnover. Fees and tax
rates vary between sectors. Lotto, for example,
pays no annual fee and monthly tax of 10%. Slot
machines pay an annual fee of HRK 10,000.00
22 2009. Zakon o igrama na srecu (Gambling Act). Narodne Novine, no. 87. URL: http://www.zakon.hr/z/315/. Accessed
21 September 2012.
23 2011. ‘Izvjesce o obavljanoj reviziji godisnjeg izvjestaja o izvrsenju drzavnog proracuna Republike Hrvatske za 2011’
(Croatia’s 2011 Annual Budget Report). Drzavni ured za reviziju. URL: http://tinyurl.com/q2ddrq9. Accessed 29 November
2013.
24 2012. ‘Drzavni proracun 2012’ (Croatia’s 2012 Annual Budget Report). Ministarstvo Financija Republike Hrvatske. URL:
http://tinyurl.com/p7zk5av. Accessed 29 November 2013.
(€1,313.00) per slot machine and monthly tax of
25%.
roatia’s income from gambling tax was
HRK 668,868,424.18 (€87,829,781.62) in
201123 and HRK 675,389,111.46
(€88,686,019.55) in 2012.24 The Ministry of Fi-
nance collects the tax from gambling operators
and decides how it will be distributed. Currently,
50% of the total is spent on supporting good
causes. There are no specific funds for treating
gambling problems, educating people about gam-
bling or for gambling research. For example, in
2013 the 50% of total tax revenue was distributed
as follows: development of sport (35%); dealing
C
18
with drugs misuse and treating all other addictions
(5.58%); humanitarian activities (9.11%); helping
those with disabilities (16.2%); promoting technol-
ogies (5.18%); promoting culture (11.89%);
education of children and youth (4%); promoting
civil society (13.04%).25 In Croatia, all academic
research is funded by the Croatian Science Foun-
dation (Hrvatska zaklada za znanost): no themes
or subjects are specified as high priority.
The Croatian Lottery often, but not regularly, con-
tributes money to self-help groups for treating
gambling-related problems. However, these ar-
rangements are based on relationships between
stakeholders, rather than structural. This situation
may change as the Croatian Lottery has joined the
European Lotteries and the World Lottery Associa-
tion and may seek social responsibility credentials.
Treatment providers are particularly anxious that
there is no provision in the Gambling Law to chan-
nel revenue specifically to the treatment of people
with gambling problems.
Industry State
Research
Education
Treatment
Academic
Funding Bodies
Tax
The Croatian Model
Lottery
Humanitarian
Activities
Technology Culture
Sport
Civil Society
Helping those
with disabilities
Figure 3 – The Croatian Model
Case study 3: Macau
In 2006, Macau overtook Las Vegas to become the
world’s most lucrative gambling market. The larg-
est proportion of expenditure is generated by
visitors from the Chinese mainland playing high
stakes baccarat. In 2012 gambling generated $33
billion (or €23.2 billion), 40% of GDP; 1.6% of
25 2012. ‘Uredba o kriterijima za utvrdjivanje korisnika i nacinu raspodjele dijela prihoda od igara na srecu za 2013.
godinu’ (Criteria for the distribution of tax revenue to good causes) Narodne Novine, no. 144. URL: http://narodne-
novine.nn.hr/default.aspx. Accessed 21 September 2012.
gross gaming revenue is paid to the Macao Foun-
dation, which distributes funds to support not-for-
profit projects.
According to their website, ‘The Macao Foundation
is instituted to promote, develop or research on cul-
tural, social, economic, educational, scientific,
19
academic and philanthropic activities, as well as
activities that promote Macao. The Macao Founda-
tion mainly conducts its activities in Macao, and
conducts exchanges and co-operations with institu-
tions at home and abroad having similar ideals.’
The Macao Foundation received 4.09 billion pata-
cas (or €388.7 million) in 2012 and received
criticism from the Commission of Audit for poor su-
pervision of its chosen investments.26 In addition to
cultural and social activities, it funds academic re-
search and has emphasised ‘responsible gambling’
for the past two years.
ccording to researchers, there are three
sources of funding for research in addition
to the Macao Foundation. Industry may
commission research but in practice rarely does so,
arguing that, as a highly taxed industry, they have
already provided the necessary support. Re-
searchers can also apply to research funds at
publicly funded universities but these are not spe-
cific to gambling. The Social Welfare Bureau, the
welfare services division of the Macau government,
regularly commissions policy-oriented research.
While funding for research is described as ade-
quate by our interviewees, high-quality,
independent research is severely restricted. Aca-
demics at public universities are not allowed to go
into casinos except on particular public holidays, or
when they have applied for special permission (see
section 47). The government is ‘not easy to work
with’ and ‘not as transparent as in western coun-
tries’ (see section 47). Not every discipline is
supported. The Science and Technology Fund does
not, for example, recognise psychology as a sci-
ence (see section 39).
Intermediary
Industry State
Research Social and
Economic
Development
Academic
Funding Bodies
The Macau
Model
Treatment
Contributes 1.6% of its Gross Revenue
Contributes 83% of Public Revenue
(Culture, Arts, Charity, Community, etc.)
Figure 4 – The Macau Model
26 Quintã, V. 2013. ‘Macau Foundation locks down subsidies’, macaubusinessdaily.com, 7 August.
A
20
Problems with gambling
Problem gamblers have been used by politicians and regu-
lators. They say they are passing the law to protect the
player but what they really want is to make money. Politi-
cians use the casino industry to stigmatise problem gambling,
then they win votes. But these gambling operators pay most
tax, and end up blamed for problem gambling. So they lose
on all sides. MUrSEE(25)10
“
21
Headlines
• Gambling is an increasingly significant source
of revenue for governments. (section 1)
• Gambling research is dominated by strong
vested interests, and findings may be used in-
appropriately. (section 2)
• Gambling is divisive. It provokes passionate
disagreements between defenders of religious
or ethical positions and those who advocate
freedom of choice. (section 3)
• Definitions of gambling are locally various.
What counts as ‘gambling’ in one place may
not do so in another. (section 4)
• The field is dominated by the idea of ‘problem
gambling’. (sections 5, 6)
• The idea of problem gambling normalises the
majority of gambling while blaming the minor-
ity for not playing well. (sections 7, 8)
• ‘Problem gambling’ is silent on the relation-
ships between the state and gambling
operators. At the same time, it is an essential
mechanism that sustains those relationships.
(section 9)
• Policy makers trust and demand numbers. (sec-
tion 10)
• Framing gambling as a public health issue
does not guarantee a strong research tradi-
tion. (section 11)
• An emphasis on treatment, harm minimisation
and responsible gambling sustains the current
arrangements between the state and the in-
dustry. (sections 12, 13)
• The idea of responsible gambling is travelling
through professional and informal interna-
tional networks and standards from more to
less mature jurisdictions. (section 14)
22
Gambling makes money for governments
Gambling is increasingly legal and therefore reg-
ulated, enabling governments to capture revenue
through taxation. In the past governments acted as
policemen, either enforcing bans or keeping legal
gambling crime free. More recently they have be-
come important participants in gambling markets
as both operators and tax collectors.
I remember when gambling was like the Wild
West and some of us can tell you where all the
bodies are buried. It’s not like that any more.
The online business has really cleaned up its act,
but in the early days it was hair-raising. It’s quite
dull now that we are a regulated industry. We
have to play it straight because our closest part-
ners are governments. MUrOE(21)93
The state sees the gambling industry as their
golden goose, filling their budget. I’ll be open:
the state loves the gambling industry.
MUtSEE(23)141
If you did good reliable research on which
product is most addictive in all the EU countries,
then you could change the legislation all around.
But nobody wants that because of the taxes.
MUpOE(20)6
In the UK there has been a national lottery since
1994. In Canada all forms of legal gambling are
run by provincial and territorial governments. In
Australia, gambling taxes from commercial opera-
tors account for an average of 10% of state
revenue: 17% in the Northern Territory.27 Some of
our participants described a culture of depend-
ency, where the state is less likely to suggest
measures to protect consumers from the harms that
may arise from gambling if they are likely to have
a negative impact on profit and therefore taxa-
tion.
The industry is interested in research as a public
relations tool. They are terrified of research that
might cut consumption. I think they’re pretty open
about that. They’re businessmen, they’re not go-
ing to cut their legs off. My concern is more the
government complicity, the way in which govern-
ment is involved. XXXXX
Gambling is dominated by vested interests
Gambling research is a political activity. Research
funding structures, no matter how different they
are from one jurisdiction to another, are affected
by the interests of the state as operator or regula-
tor and the gambling industry as a source of
revenue. Research is thus always subject to co-op-
tion onto political agendas, which may or may not
be transparent or consistent. Gambling research
can be used by policy makers and the media in
ways that are unanticipated and may be inappro-
priate. Vested interests vary through time and
space and reflect the social histories of gambling
in particular jurisdictions.
Gambling is a politically charged field. Any
time you do research you have some random
guy in [the] legislature use it incorrectly and mis-
interpret it, and it goes on like that so I think
there are all these things around it that makes it
difficult to do academic research. FRaUS(11)66
27 Hancock and O’Neil, Risky Business, 11.
You have so many different interests to try to
anticipate: politicians, regulators, law enforce-
ment. You have to see where the power lies and
that’s not always obvious and can change fast.
MRiOE(15)89
The problem is that the state issues licences and
receives a lot of money from that. So is it really
in their interest to have research on gambling
when they make money on gambling? Is it really
in their interest to know what the real situation
with gambling products and practices is? MI-
oSEE(20)3
The state receives millions of euros, but those
who become victims of gambling receive noth-
ing. They are lost in the system: they become
victims of loan sharks, their families are broken,
they receive inadequate treatment, they spread
23
the problem to others because others care about
them. MUtSEE(13)142
Gambling is controversial
Despite efforts to recategorise it as a form of lei-
sure, gambling remains divisive. Debates are often
passionate and polarised between religious or
moral positions that seek to minimise opportunities
for gambling, and commercial or free choice mod-
els that seek to submit gambling choices to the logic
of the market only.
How dare Nanny State tell me how I can spend
my money? This is a free country. MIoUK(11)42
The traditional view was ‘Why should a Chris-
tian put their trust in chance?’, ‘Why should they
be worried about greed or money, when we
should be trusting in God rather than winning the
lottery?’ However, the current position of this
church, you could say has developed, some peo-
ple would say has been watered down. When
the gambling bill was going through that was
the time to campaign on right and wrong. Car-
rying on complaining won’t do anything at all.
It’s a waste of breath. It’s not like we’ve aban-
doned our principles, it’s just that for a
consultation document gambling is already
there and you can only really answer the ques-
tions they ask. MUpUK(6)99
The gambling field started in some places from
a position of advocacy so you really had peo-
ple who felt very strongly one way or another
almost morally about gambling, whether it’s
right or wrong and so you had people who were
kind of looking for evidence to support their
world view. FRaUS(11)66
Politicians can gain support by opposing or con-
demning gambling.
Gambling will always be a matter of con-
science. It is morally aspirational to oppose
gambling. MUpUK(40)87
If you are a minister you don’t want to be any-
where near gambling because it is so politically
sensitive. Politicians are self-interested and they
are re-elected by local populations and so if
there are things that can draw them to their local
attention then they will take them up. Some will
take them up with a lot of passion and with a lot
of knowledge, some will take them up with a lot
of passion and very little knowledge and of
course there will be those who have very strong
personal views about gambling. So in a way
politics reflects, as often it does really, life in
general. That’s how most people are. There will
be a reason why you might have a view, and if
you do have a view around things like gambling
it’s often quite a strong view. MIoUK(12)41
There is no universal definition of gambling
At the most basic level, there is no internationally
shared definition of what is, or is not, gambling.
The gambling industry includes a range of sectors
with very different characteristics and interests in-
cluding: lotteries, sports betting, casinos, arcades,
online, bingo and poker. Even in neighbouring ju-
risdictions within Europe, gambling may be
understood and regulated quite differently. As a
result, there is a mosaic of national markets and
regulators, even at the same time as technology
reduces the significance of territorial and political
boundaries for consumption. This variation has a
huge impact on research and means that findings
are not directly comparable across jurisdictions.
You have to understand that there is nothing in-
herent that gambling shares all over the world.
Sports betting in the US is mob dirty. It cannot
be a part of the campaign to make online legal.
Now where in Europe could you imagine a simi-
lar situation? These things are very distinctive.
Everything about them, the way that power
works in the system, and the way that people
gamble. MRiOE(15)89
24
Research has many different problems, of per-
sonality, or comparability and of rigour. First of
all, there is no agreement about what ‘gam-
bling’ actually means, so, as lawyers, we are
able to create all kinds of exceptions, even
some that seem contrary to common sense. The
motivation for this comes from many directions:
from regulation, but also from commercial pres-
sure, mainly taxation. So, we are not in
agreement about what is gambling, we con-
stantly talk past each other. The differences are
in fact locally significant, so this is not always a
failure, but an attempt to take into account local
sensibilities, understandings, culture if you will.
It’s not a deliberate thing, it is part of the com-
plexity of studying gambling, a process that is
culturally diverse at the most profound level.
MUrOE(7)91
Most research focuses on problem gambling
Gambling is a complex phenomenon which can be
usefully studied in a variety of ways.
It’s important to understand that this is really
quite a hard thing to study. When I say that the
standard [of the research] isn’t particularly high,
that should be set against the context that this is
a difficult thing to study. Gambling is a multifac-
eted social psychological thing, and there are
huge numbers of ways of looking at it and un-
derstanding it. XXXXX
Despite this, gambling research is dominated by a
focus on ‘problem gambling’, variously defined
and understood.
Research producers and users regularly call for a
widening of perspectives to include a greater va-
riety of approaches. However, the political
economy of gambling research (including funding,
commissioning and dissemination) is strongly
skewed towards problem gambling research, as
we will show. Narrow understandings of gambling
as a problematic behaviour associated with the in-
dividual have stabilised under present conditions,
reinforcing disciplinary divides at a time when mul-
tidisciplinary approaches are being encouraged
outside the field of gambling studies.
The term ‘problem gambling’ implies an individ-
ual subject and it’s quite difficult to break out of
that given that there is such interest in continuing
to focus on problem gambling and issues that fix
individuals rather than communities, and also
vested interest in not bringing too much scrutiny
to bear on the parties that benefited so much
from the growth of the gambling industry
through a period of deregulation.
FRaAU(15)25
The dominant strand is still a quantitative, posi-
tivist model and a psychological approach to
gambling is definitely dominant. Addiction is al-
ways the first thing that people want to talk
about. XXXXX
25
Problem gambling dominates the entire field
Figure 5 – Problem gambling. Data drawn from the papers given at the University of Nevada’s 15th
International Conference on Gambling & Risk Taking (21–31 May 2013) and the European Association
for the Study of Gambling’s 9th European Conference on Gambling Studies and Policy Issues (18–21
September 2012).
From policy making to research questions, problem
gambling and the related concepts of ‘responsible
gambling’ and ‘harm minimisation’ dominate all as-
pects of the field. Research focusing on problem
gambling receives most funding and is most widely
disseminated. Funding structures which promote
‘safe’ research inhibit academics, consciously or un-
consciously, directing their attention towards
conservative themes. As a result, many ethical is-
sues surrounding gambling harm as a wider public
health issue are overlooked.
I have been interested in why the field is domi-
nated by problem gambling and it certainly has
to do with how the field is constructed and where
researchers are getting their money. XXXXX
There are two sides to gambling research in Aus-
tralia: there is a large group who uses gambling
research as they would with any research to
build an academic career […] not having any
particular purpose in mind, and then there is a
public health purpose which is to build an evi-
dence base in support of reform. XXXXX
I tried my best but sometimes I felt alone. For this
reason, I think people try to write more on re-
sponsible gambling, talking to visitors, talking to
gamblers. I think that’s relatively easy. I think
that also explains why we have lots of articles
about problem gambling but not qualitative ap-
proaches to operations, how they work in
practice. Of course I can switch my research top-
ics to other areas. For example, I can ask
problem gamblers, ‘What do you feel?’ ‘What
can government do to help you?’ That kind of
stuff would be relatively easy. But I’m bored
when I read these articles. I can guess more or
less what is going on behind them. That’s some-
thing which pushes me to do something different,
I would say interesting. MRaHK/M(6)12
The problem gambling paradigm
You should work on the political economy of the
industry, because it is completely fascinating.
Have you read Polanyi? If you don’t get how the
economy reproduces itself you have no idea of
how to make an intervention. The gambling in-
dustry is impenetrable. It reproduces seamlessly,
and the problem gambling stuff is a big part of
that. MInUK(2)51
The problem gambler is a socially constructed and
vigorously maintained category which emerged in
late-modern consumer societies. A problem gam-
bler is someone who is indulging in ‘inappropriate
26
consumption’.28 The dysfunction is therefore lo-
cated with the individual or citizen: the person,
rather than in wider relationships. This idea is epit-
omised in Margaret Thatcher’s famous assertion
that ‘there is no such thing as society’.29
A strong premise of the commercial gambling in-
dustry is that a gambler has a choice, as a
consumer, to spend their money as they wish. By
normalising and institutionalising gambling, the
state has discursively created an abnormal cate-
gory of people who cannot consume appropriately
– the problem gamblers.
Gambling regulation and the way gambling oper-
ators organise gambling rests on the idea of
informed choice, or ‘buyer beware’.30 This model
presupposes that if a consumer is presented with
enough information about a gambling product and
its possible harms, anything they do is their own re-
sponsibility (and fault).
I am very much in favour of the informed choice
model. If people have the information, they can
use it or not. The decision needs to be based on
a voluntary basis. We need to give them infor-
mation to motivate them to decide they want to
go home. If they have options, then they can de-
cide. MUpOE(10)6
Why should we spend time and money re-
searching these things? Well, because as far as
we can in a free society we are not going to
prohibit the consumption of crisps, what we want
to be able to do is create informed consumers.
Now I’d be the first to recognise that this is a
new form of conceiving citizenship in civil society.
Governments allow opportunities to be created
through privatisation, licensing. If you want to
you can, you are a free agent, choose, we will
put warning labels on food. Red, bad for hearts,
green eat me, amber only a little. There’s a per-
fect analogy: the food industry falling over itself
to complain about the way in which the Food
Standard Agency wants to do this. The food in-
dustry says you’ve got to give consumers much
more information and of course all they’ve got
is tiny print on the back of a bottle of Coke. Ul-
timately it’s a political question, how do you
conceive of your society? MRaUK(40)57
These choices, however, take place in environments
that are manufactured to maximise profits.
The prevailing paradigm is one that is excusa-
tory, it is one that not just by default but by
explicit design sets out to blame the individual
[…] In the UK you’ve got a very discouraging
political context, in terms of free markets and
informed consumers: anything goes as long as
people get a bit of information and then what-
ever they suffer is their own fault and they have
to suffer and bear the blame. That then becomes
quite an impediment to more critical research
because then they are working outside the par-
adigm so it’s more difficult to get funded.
XXXXX
Images of problem gamblers
The notion that there are problem gamblers is
almost necessary to justify gambling as a form
of entertainment because it legitimises it and if
you take that away from people it becomes
more difficult to construct gambling as an enter-
tainment. The staff found it problematic if you
encourage people to think of customers as
friends, then it upsets people if what you are
doing is hurting them. Whereas if you have the
more traditional Las Vegas style that the custom-
ers are all idiots then you’re not that personally
28 Reith, G. 2007. ‘Gambling and the contradictions of consumption: a genealogy of the “pathological” subject’, American
Behavioral Scientist 51(1): 33–55, 41.
29 Interview 23 September 1987, as quoted by Douglas Keay, in Woman's Own, 31 October 1987, pp. 8–10.
30 Hancock and O’Neil, Risky Business, 11.
affected by anything that happens to them be-
cause they are constructed in a different way.
FRaUK(2)58
By categorising a small minority of people as
‘problem gamblers’, the state and the industry are
able to continue to promote gambling as a safe
and legitimate form of leisure and entertainment
for the ‘normal’ majority. Images of problem gam-
blers in our data are many. They include those
labelled as losers, weirdos or simply those who
27
don’t gamble well, but most are flattened out and
decontextualised accounts of problematic people.
Industry’s views of problem gamblers, in particular,
are often deterministic and derogatory. They are
seen as people who are unable to control their be-
haviour. Some described treatment as a waste of
money, and people with gambling problems as
‘problem people’.
Problem gamblers are problem people. They
are drug addicts, criminals, they are unable to
control their impulses and this is why it is impos-
sible and pointless trying to prevent them from
harming themselves. All the studies about comor-
bidity in Australia show this – these are
damaged people. The research in the UK is far
behind Australia. Treatment is standard cogni-
tive behavioural therapy. And this is why so-
called talking cures are worthless. They are an
expensive cosy chat with a friendly face, but
they don’t cure problem gambling. They might
even enable problem gambling. The evidence
just isn’t there to evaluate these treatments. The
treatment providers hide it because they know
it will show they don’t make any impact. If we
had that hard evidence it would show spontane-
ous recovery as they’ve found in Australia and
the US, and the treatment providers would be
out of a job, so they have a vested interested to
conceal their recovery rates. MIoUK(11)42
Gambling is about greed and it requires disci-
pline more than anything, to walk away. Ask a
gambler why he has a problem and he will say
‘I was unlucky or made a mistake on a card, or
a cheque wasn’t paid through’. He’ll never say ‘I
just lost £500 on a FOBT, my giro hasn’t come
through’, the truth. MIoUK(20)74
The industry people say: ‘We don’t want prob-
lem gamblers.’ It’s like the problem gambler is a
kind of species, it’s bizarre. It’s not only bizarre
from a research point of view, from any kind of
cultural or social point of view it’s quite bizarre.
The industry produces this figure. They really
simplify it. The problem gambler is like a cari-
cature. The problem gambler is someone who
doesn’t gamble well. Like in Australia, the idea
is that people gamble money for fun, so this Aus-
tralian problem gambler is spoiling it for the rest
of us. It’s very much how it works. FRaAU(15)25
In practice, there was disagreement within the in-
dustry about how to understand and deal with
problem gamblers.
At the end of the day we are running a business
and we don’t want to ruin lives, we don’t want
to wreck people. We have personally inter-
vened if people have got themselves into
trouble, we don’t want to have that on our con-
sciences. I don’t think every company is the same.
Some companies think of their customers as to-
tally different from themselves or their families.
They objectify them and that gives them carte
blanche to exploit them. Especially if they can
laugh at their problems. I would say that we
have retained our empathy compared to other
gambling companies that I’ve worked with. We
are part of the world still and so that person
who can’t make their house payment could be
your sister or sister in law. And then you see
there is no real choice but to step in and say
you’ve had enough. I think research should focus
on patterns that indicate problems with gam-
bling, but I can also see how that would be a
very difficult thing to identify because you’ve
got such varying expenditure. So you’ve got to
go a lot with feel, what seems right and what
stinks. If it stinks, shut down the account, or talk
to your customer. It isn’t impossible to do and it
just means don’t be greedy. That’s what they
should teach gambling executives. Don’t be
greedy. MInUK(10)45
In shops we must get better at identifying prob-
lems. You are not allowed to tell someone
they’ve got a problem. Even if someone is
clearly betting beyond their means they may be
insulted. Managers are now button pushers, no
one wants them to manage they just want them
to follow protocol. You imagine a Tote shop on
the corner of a housing estate, old Doris is she
really going to say, ‘Blimey Bob, you’ve gone
from 50p to £50 a race! Are you sure?’ This is
the problem of a profit-related business. MI-
oUK(20)74
Uncertainties about who the problem gambler is
and how they come to occupy this category persist.
Many stakeholders were aware of the lack of a
clear definition of problem gambling, and instead
worked with various different images, depending
on their position, methodologies and agendas.
28
We say we don’t want problem gamblers, but
what’s the difference between a problem gam-
bler and a really good, loyal customer? It’s in
the eye of the beholder really. Does the person
think he has a problem? Can he sustain his ex-
penditure? If he can’t he won’t be back. If he can
then who’s to say he has a problem? We should
make him welcome. He’s a bread and butter cus-
tomer. Years ago he would be welcomed. Now
are we saying that if you spend too much you
have a problem? Who gets to decide how much
is too much? It’s a free country and he can spend
his money how he pleases. What it’s got to do
with anyone else I don’t know. This is where the
government has got things wrong. My wife buys
a lot of shoes and handbags. She doesn’t need
them. They are expensive. I don’t go to her and
say, ‘Madam, I’m afraid I think you have a prob-
lem. Could you please seek counselling?’
MIoUK(17)54
Poker is great, it’s a cure for problem gamblers.
Those who become addicted to slot machines
and roulette should be treated with poker. The
problem here is that when you say you play
Bela, it’s okay, but the moment you say you play
poker, they think you’re a gambler. Poker
doesn’t allow you to form a habit and addiction
is nothing but a habit. Poker has strong rules, it
teaches you money and time management skills.
An addict takes £10 and goes gambling hoping
to win £10,000. This is madness. A poker player
takes £10 and plays hoping to win £12. There’s
no skipping steps here. Poker builds strong char-
acter. MIoSEE(30)11
The focus on problem gambling produces ‘safe’ research
The so-called ‘psy’ disciplines of psychiatry and
psychology, by focusing on problem gambling as
a definitive and measurable activity, produce
‘safe’ research, which focuses on the ‘faulty’ indi-
vidual, passing responsibility for the existence of
markets for risk-taking from the state to the indi-
vidual consumer. Gambling is studied as an
individual pathology, unrelated to the wider socio-
political context. This research is silent about rela-
tionships between the state, the industry and the
consumer.
Psychology invites some very safe research in
that a lot of the research has come out of labs
and is not really contextualised in any sort of
policy context. There are probably not that
many psychologists who I would say have ques-
tioned the prevailing paradigm that tends to
legitimate a lot of the government and industry
coalescence of interests. XXXXX
‘Safe’ gambling research is also informed by and
reproduced through the use of certain concepts.
‘Responsible gambling’, for example, is a powerful
construct which, with ‘problem gambling’, filters
and narrows down research themes and methodol-
ogies that are rewarded by funders and journal
editors. Such key concepts also influence what
counts as evidence both in academic terms and as
a basis for policy making. The major policy contri-
bution of problem gambling research is to promote
‘responsible gambling’, a product that is difficult to
define, and possibly oxymoronic. Newcomers to
the gambling industry were struck by the use of
these terms by gambling executives, and fasci-
nated by their political genealogies.
Research looks at problem gamblers. Gambling
operators talk about responsible gambling –
how much did they have to pay to get that
phrase into the gambling jargon? ‘Promoting re-
sponsible gambling’. Anyone who has read
anything about messaging can see what a bril-
liant sleight of hand that was for the gambling
industry. Well, just try out these two different
approaches: Preventing problem gambling.
Promoting responsible gambling. Which would
you rather have? What about cigs? ‘Preventing
chain smoking’ or ‘Promoting moderate smok-
ing’: which would you sign up for? MInUK(5)53
When we came into his business we were abso-
lutely flabbergasted that there was a built-in
cushion for bad products. Problem gambling!
When gambling goes wrong! (laughs) You know,
you get this big let off. It says, ‘Don’t worry if
people get addicted to your machine or your
game – there are some real weirdos out there.
What can you do? People are weak.’ At a very
29
basic level, it shifts responsibility from the indus-
try to the consumer, and that is great for us, but
not so great for you. MInUK(2)51
Policy makers trust numbers
Quantitative research methods can produce fast
empirical results that are commonly perceived as
credible and scientifically objective by policy mak-
ers. Numbers and statistics are particularly valued.
Qualitative research methods translate less well
into policy settings, as they are often based on
specific phenomena or contexts and may not pro-
duce generalisable insights.
Some disciplines like psychology are actually
very good at being able to do something fast
and empirical and get the results out quickly.
You can have a veneer of objectivity and scien-
tific respectability with numbers. That goes a
long way with the bureaucrats. MRaAU(12)98
To have an impact, and I’m talking now as a lob-
byist, you need something snappy and easy to
explain. You literally have minutes to make an
impression. MRiOE(15)89
Psychological research is regarded as more
credible and scientific and that’s in spite of long-
established disciplines of public health, of geog-
raphy, public economics. FRaAU(15)25
As cultural anthropologists, we were the only
group of researchers who used qualitative meth-
ods. No one else, not even sociologists, or
communicologists, were trained in qualitative
methods. The general attitude is that such an ap-
proach is not scientific as well as representative
enough. Qualitative methods are currently sup-
pressed at the Slovenian academic centres.
FRaSEE(6)1
The gold standard of this numbers ontology is the
prevalence study, the most common metric used by
politicians and regulators. It is used to assess the
overall ‘health’ of gambling, and, in theory, to as-
sess the ‘impact’ of changes in policy. At times,
entire gambling policies appear to hinge on the
outcomes of periodic prevalence studies. In prac-
tice, as we show in sections 23 and 24, prevalence
studies often fail to capture much of what is consid-
ered important about gambling by policy makers
and researchers, and their findings are subject to
huge variations in interpretation.
It’s really unhelpful that problem gambling is ex-
pressed as a proportion of 1%. I’ve heard that
figure given at seminars and so on: the 1 versus
the 99 and it’s not right, it’s incorrect. They
should talk about the population numbers – the
450,000. They have tried hard to introduce this
idea of behaviours on a spectrum so that you
aren’t just focused in on one end of it, and so
that’s why they had all that information about
people at risk, but it just got ignored. A lot of
policy weight is hung on the prevalence survey
and I think they would be better to take a more
rounded perspective. If I’m looking through the
eyes of policy makers, if you are looking for an
evidence base, if you’ve got something that
people generally accept then it’s an easy option
to take, ‘Thank god it’s something they can
agree on!’ FRcUK(6)62
Is gambling a public health issue?
In most jurisdictions, problems caused by gambling
are couched in terms of individual pathology. In
practice, this means that the roots of the problem,
as well as the solutions, are sought in the ‘addicted’
individual, leaving societal factors unexamined.
Anything to do with gambling products, their tech-
nological wiring, or their accessibility, is presented
as of secondary significance when devising treat-
ment approaches or assessing policy.
In New Zealand, Canada and Norway, problem
gambling has been presented as a public health
issue to a greater or lesser extent and with varying
outcomes. In its ideal form, a meaningful public
health approach would include the state and the
30
workings of the gambling industry as legitimate
objects of study, not just the ‘addicted’ individual.
Many researchers suggested that the public health
model would produce a more nuanced approach,
encouraging the production of diverse types of ev-
idence. However, in practice, the political
implications of such an approach, and the potential
impact on gambling consumption, limit its influence.
I keep chuntering on and on about the regula-
tory model that’s applied in the gambling
context which is essentially a command-and-con-
trol model, which I think is just hideously out of
date, given all the technology that now abounds
in gambling, and really doesn’t address things
from a public health perspective, and I’ll prob-
ably keep going on about it till the grave but if
you are truly interested in reducing harm as a
government official then surely you should be
using the industry against itself and making sure
that they use some of that expertise and some
of that brain power that it’s recruiting to help
mitigate the downsides of its own products. Al-
most force the industry into taking a longer-term
perspective rather than what everyone admits
to: a year on year slash-and-burn policy to-
wards customers. MInUK(8)35
In New Zealand gambling is explicitly formu-
lated as a public health issue. I don’t think it’s
going to happen in Britain. I can’t see the De-
partment of Health wanting to take
responsibility for it and I think there are plenty
of powerful stake holders who think it works for
them where it is in DCMS. FRcUK(6)62
Approaching gambling as a public health issue
does not in itself guarantee a critical examination
of the underlying politics of the field.
It has now gone from an illness [or] medicalised
version into more of a public health one, but in
terms of influence of the industry, their under-
standing of public health is a very conservative
one and doesn’t take on board much about pre-
vention apart from education and information
for the individual to make more informed
choices, but the choices are constrained by the
toxicity of the product and the lack of care and
vision in both the regulatory paradigm and the
way that venues are run by operators. XXXXX
The industry would rather support treatment than fund research
Figure 6 – RGT funding plan for 2013–14. This shows the proportion of funds given to research and
treatment .
The problem gambling model emphasises treat-
ment and harm minimisation rather than using
research to investigate the causes of harm and how
it can be prevented. Focusing on treatment sug-
gests that harms are the inevitable price of a
commercial gambling industry.
31
The danger is that when lobbying for greater
independence and objectivity in research the in-
dustry will say ‘Well, we are paying tax, a
voluntary contribution for treatment and also
paying a voluntary contribution for something
which is of no benefit to us and there’s a lot of
research that puts us in a negative light.’ I’ve
seen GamCare in a public meeting where the
most vociferous and aggressive member present
from the industry said, ‘I don’t know what all this
fuss is about! We should just write a cheque for
GamCare.’ And GamCare were present and
they nodded. So, that really is (laughs) that re-
ally is the position, in terms of independent
research. MRcUK(10)79
Well, industry fund GamCare, one has to rec-
ognise the reason for that: it is a nice little cross
over for everybody. It’s probably still a bit of a
mix of ‘Hmm, slight worry, but we had better go
with it’ and some are going with it rather more
openly than others. It is not a homogeneous
whole. That’s always played out in funding,
bingo people say ‘But we are soft! It’s the ma-
chines people who should be stumping up’.
MRaUK(40)57
The political sensitivity around the funding of Gam-
Care in the UK illustrates how relying on a single
source of industry funding – either as a researcher
or a treatment provider – makes one vulnerable
and unable or unwilling to ask challenging ques-
tions.
Working with the agencies, because their fund-
ing is coming from the industry, there is a certain
party line. They are very, very careful for ex-
ample when it comes to what they say about the
FOBTs which I know do cause a significant
amount of problems for a significant amount of
people that did not have gambling problems in
the past. But because GamCare is afraid of up-
setting the gambling industry by saying that
they tend to downplay it. And I’d like to say I’m
certainly not anti-gambling, I’m not anti-industry,
in fact I have a very good relationship with the
industry, but yes, I feel that one is stifled when
working with agencies that receive all their
funding from that source because they are very
afraid of saying anything negative that might
upset them. XXXXX
GamCare have now said publicly that they have
no intention of taking a view on fixed odds bet-
ting terminals because that’s biting the hand that
feeds them. And informally most of them will
say, well and truly, ‘Yes, betting terminals are
the devil’s work.’ But it’s true that there’s a cer-
tain reluctance on the part of some of the big
players to actually come out and say it because
they fear for funding. Research has taken a
backward rather than a forward step. Which in
turn is predicated on GamCare’s desire to not
rock the boat. MRcUK(10)79
Can problem gambling be cured?
If problem gambling existed then it would be a
problem for the NHS and they would find a cure
for it. MRcUK(4)56
The treatment of problem gambling reflects the
idea that it is an individual pathology. This model,
several treatment providers have noted, treats the
problem gambler – a politicised construct – rather
than a person with a gambling problem.
GamCare has shifted. It was once much more
about someone’s social problems. It’s starting to
shift a bit more now, taking on board that
maybe there might be an aspect of brain chem-
istry for example, more of a disease model
stance on it, and saying there’s no gender dif-
ference is all a part of that, like saying, now we
are treating a problem gambler rather than an
individual who has a gambling problem and
why. Treat the problem gambler rather than the
person who has developed a gambling prob-
lem. Shorter-term, more medical models, a focus
on data collection to an extreme degree, a fo-
cus on completing accurate paperwork rather
than time with clients. More number-crunching
data from treatment, rather than freeing time
for face to face. Demand on therapists is in-
creasing in terms of the number of people they
are expected to see in a day. And this is de-
manding work, there is a limit to what you can
32
process. Now it’s how many people can we get
through as efficiently as possible. XXXXX
Some treatment providers chose a ‘middle way’,
emphasising the environmental and temporal fac-
tors in gambling behaviour and presenting
gambling as a form of exchange which relies on
and creates various relationships. This approach
stresses the importance of learning and unlearning
different types of behaviours.
I want to take the middle way. There are things
going on in the person that have either predis-
posed them to having a gambling addiction or
have actually triggered it because there are is-
sues in their lives and there’s a personality area.
That’s my natural orientation. But increasingly I
have a lot of sympathy for the public health
model, which is looking at the fact that there is
a huge public health dimension and the extreme
example of that is New Zealand. They would
take a radically other stance and say basically
it’s [the] industry. Psychologists are employed in
working out time in front of slot machines and so
on and machines themselves are addictive. […]
And so you’ve got a kind of a radical view of
the public health, it’s all the fault of the industry,
it’s all their fault, it’s a bit like drugs, it’s antiso-
cial and it shouldn’t be allowed. Where I sit is I
want to see both sides of those. I would adhere
to, not a medical model, I don’t see it as a dis-
ease, I see it as a maladaptive learned
behaviour. That with therapy, counselling sup-
port, can be unlearned. MUtUK(27)82
If clients express anxiety about gambling brains
and genes, I say, let’s talk about learned behav-
iour. We learn how to be a woman, how to be
a man. To me gambling is all about relation-
ships. Those that don’t work, do work, having
them or not having them. There are so many dif-
ferent ways of gambling now, and the
psychology of problem gambling hasn’t
changed. We’re wasting money on that.
XXXXX
In Hong Kong and Macau, treatment providers sug-
gested that therapy focused on a sovereign,
isolable individual may not be appropriate outside
Europe and North America, highlighting the fact
that the ‘problem gambler’ is a social and historical
construction.
For Chinese people there are family members
involved, not like western people where you are
responsible for yourself. It’s not the case for Chi-
nese people. […] So in our centre we emphasise
help for the family members. MUtHK/M(13)103
Exporting responsible gambling
The problem gambling paradigm is being ex-
ported from mature to younger jurisdictions
through international trade organisations which call
for responsible gambling measures. In mature juris-
dictions problem gambling has been subjected to
critical attention, even if this has not succeeded in
promoting alternatives. Elsewhere a focus on prob-
lem gambling is regarded as a necessary first step
in the attempt to encourage the industry to engage
in greater ‘social responsibility’. In south-eastern
Europe and Hong Kong / Macao, for example,
there is a sense that the government should take a
more prominent role in developing responsible
gambling policies. This role would also involve com-
missioning and directing research, which has
hitherto been motivated by commercial incentives.
Previously the government focused on the devel-
opment of the gaming industry so they would
encourage competition to increase the gaming
revenues. They didn’t do a lot on responsible
gaming and were publicly criticised.
MRaHK/M(2)13
The casinos are not very active in this area of
problem gambling because it doesn’t make
money. Their interest is more to make money
than other things. I haven’t heard them do any
research in Macau. FUtHK/M(8)106
In Croatia the first prevalence study of the adoles-
cent population was an important step in raising
awareness that gambling could produce social
harm.
The first prevalence study in Croatia was im-
portant for us because we could finally draw on
the evidence gathered in our own country. Until
33
then, I’d always use data from EU countries or
Canada or Australia. I was never sure how Cro-
atian data compares to those others. It turned
out that our problem gambling rate in adoles-
cents is higher than in Europe. My conclusion is
that gambling in Croatia is not regulated
enough or not regulated well enough, with very
little awareness of responsible gambling on the
part of the operators. MUtSEE(23)141
With no systematic funding structure in place, treat-
ment providers and researchers from the newer
jurisdictions find it important to frame gambling in
terms of addiction in order to invite a more com-
mitted response from the state. They must also be
careful to avoid antagonising either operators or
the state.
In my opinion, measuring the problem gambler
incidence rate and prevalence rate between
different places: growing the evidence base
and localisation is the purpose of gambling re-
search. FUtHK/M(6)107
When we set up self-help groups we had to
avoid stigmatising gambling operators. We
wanted a truce, so we spoke of the pathology
that can be a result of games of chance rather
than of games of chance being pathological in
themselves. We received support from both
state-run and private gambling operators.
MUtSEE(23)141
In mature jurisdictions this process took place some
time ago.
In the early days I exploited problem gambling
to the hilt, to get the issue on the agenda. The
industry got a bit fed up with it and I could see
why. XXXXX
34
Evidence
The Daily Mail has had more impact on policy than any re-
searcher or centre. Is this evidence-based policy? I think not!
It is politics pure and simple. MUpUK(18)100
“
35
Headlines
• Research does not produce the kind of evi-
dence required by policy makers in order to
change legislation. (sections 15, 16)
• There are basic and profound disagreements
about what constitutes evidence in gambling
research, even within stakeholder groups. A
recognition that different research questions
and methods produce a variety of forms of ev-
idence is missing. (sections 17, 18, 19)
• Policy makers do not make decisions about
gambling based on evidence, however it is de-
fined. (section 20)
• Research in natural environments and in labor-
atories is complementary. These ways of
working and their findings need to be produc-
tively combined in multidisciplinary
experiments. (section 22)
• Data produced by prevalence surveys are
subject to widely different interpretations.
(section 23)
• Prevalence studies do not produce evidence of
causal relationships. (section 24)
• A narrow definition of evidence makes many
of the questions asked by policy makers im-
possible to answer, either because they are
too simplistic, or because the money does not
exist to fund the projects which would allow
them to be answered, or because the data re-
quired to answer them is inaccessible. (section
25)
36
The tyranny of evidence
Have you got actual evidence that FOBTs cause
problem gambling? Because that is the only way
that we will get them banned. Listen, I didn’t
come into politics to liberalise gambling, I can
tell you. MUpUK(11)88
It is conventional for stakeholders to assert that the
growth of commercial gambling should be man-
aged by evidence-based policy. The UK
government, for example, will not make any
changes to policy unless it is presented with une-
quivocal evidence that problem gambling is
caused by particular products or pieces of legisla-
tion. This was made clear during a discussion in the
House of Commons in January 2013:
Hugh Robertson: Yes, the Government are
seriously concerned about problem gam-
bling. This is one of those quite tricky areas
where common sense suggests that it is a ma-
jor problem but there is a lack of evidence to
back that up. I very much hope that the major
research project that is being undertaken will
give us the necessary evidence and, abso-
lutely, once the problem is proved to exist,
the Government will act.
John Penrose (Weston-super-Mare) (Con-
servative): Does the Minister agree that
there is currently not much evidence to prove
that fixed odds betting terminals are the most
addictive form of gambling? Although I ap-
plaud his concern for the problems caused by
problem gambling, will he reassure the House
that he will proceed only on the basis of firm
evidence when that is available? 31
Politicians are held to this guarantee by each other,
and also by the industry. In April 2013, Chairman
of the Association of British Bookmakers Neil
Goulden said that: ‘The Government has promised
an evidence-based policy review and we will hold
them to that promise.’32
There is a dearth of evidence on which to base policy
Policy makers complained that research did not
provide the kind of evidence they required to
make decisions. They struggled to apply findings
from other jurisdictions to their own, and to com-
pare the methods and metrics used by different
researchers. They were unable to bring research
together into a single coherent body.
We have absolutely no research on which to
base policy. Nothing is directly translatable
from the US or Australia. Yeah, you can kind of
make a leap and say, well what has happened
when they introduce machines in these places, or
whatever, but really it is guesswork and minis-
ters don’t want that, because they need to justify
political decisions on the basis of black-and-
white evidence. We just don’t have that. There’s
a huge gap. I’d say expectations of stakehold-
ers are completely unrealistic. We find one
piece about opening a casino in Atlantic City
and they just jump on it and you say, well it’s not
31 House of Commons Debates, 13 January 2013, col. 443.
32 Anonymous, 2013. ‘Gaming machines policy must be evidence based’, Centrallobby.politicshome.com, 13 April.
quite that straight-forward because you might
need to look at who wrote it and when, and the
particular context and all that and they look at
you with panic! MUrOE(8)92
Unfortunately there is absolutely no reliable re-
search in this area and we can’t work out why.
Is it because the government won’t support it, or
because the industry won’t play ball? It’s really
frustrating. We all felt on the council that before
we made such a big move we would need to
understand the implications, but we just couldn’t
find any relevant material. That’s why we
looked into commissioning ourselves, which
turned into a complete joke. Gambling research
is just like local politics! Factions, vested interests
and no money! That turned out to be an expen-
sive red herring. MUpUK(3)95
37
The problem is that research often cannot give
us concrete answers because there are problems
with methodology, the industry often won't par-
ticipate, then the conclusions and
recommendations are very limited. I do know
that it took us 100 years to get good research
on alcohol and we are not many years in[to] this
research. Research that is there is reliable for
the moment in which it's being produced. I don’t
say it’s bullshit, but it’s very difficult to compare
and be relevant more broadly. That makes it
difficult. And it has to do with politics as well.
Researchers can write and say what they like
but it’s the politicians who make decisions.
MUpOE(20)6
Where do policy makers look for evidence?
In 2011 Gary Banks, chairman of the Productivity
Commission in Australia, spoke of the importance
of consulting a wide variety of evidence in order
to formulate gambling policy, referring to a ‘trian-
gulation’ approach, which drew systematically
from a range of sources.33 Despite his intervention,
the 49 witnesses consulted by the most recent select
committee on gambling in the UK included 25 in-
dustry and trade organisation representatives. The
committee also heard from six regulators, six rep-
resentatives of faith groups and two treatment
providers. Only two researchers, Professor Jim Or-
ford and Heather Wardle of NatCen, were called.
After presenting their findings, chair John Whitting-
dale MP, concluded that:
Gambling is now widely accepted in the UK
as a legitimate entertainment activity. We
took a lot of evidence in this inquiry, from all
sides, and while we recognise the need to be
aware of the harm caused by problem gam-
bling, we believe that there is considerable
scope to reduce and simplify the current bur-
den of regulation and to devolve decision-
making to a more local level.34
Their central recommendation: to remove the limits
on the numbers of FOBTs in betting shops in order
to reduce clustering on British High Streets was de-
scribed as ‘completely illogical’ by the Local
Government Association: ‘It’s clearly not sensible to
increase the number of slot machines in betting
shops to tackle the problem of too many slot ma-
chines.’35
Evidence of what, for what, and by whom?
Gambling policy is not based on evidence, but
on the politics of what counts as evidence. It is
whoever decides this question who holds the
cards. MUpOE(18)100
There are basic and profound disagreements even
within stakeholder groups about what counts as ev-
idence, and what level of proof is required to
support a statement or argument. Despite this, an
explicit discussion of the concept of evidence or
how it is used in practice is often missing from pol-
icy debates and consultations. Certain kinds of
33 Banks, G. 2009. ‘Evidence-based policy making: What is it? How do we get it?’ (ANU Public Lecture Series, presented
by ANZSOG, 4 February), Productivity Commission, Canberra.
34 ‘Reduce centralized gambling regulation, says Committee’, www.parliament.uk, 24 July 2012. URL: http://ti-
nyurl.com/bqhmmjs. Accessed 14 November 2013.
35 Clyde Loakes, vice-chair of the LGA’s Environment and Housing Board, quoted in Bridge, T. 2012. ‘LGA: Action against
gambling clusters is “completely illogical”, LocalGov.co.uk, 24 July.
evidence are favoured, and others discounted, for
reasons that are rarely made explicit.
The awareness that evidence is always of or for
something, and therefore that it exists in relation to
a question, is lacking. The knowledge-making prac-
tices of the gambling field determine that this
question is often ‘What causes problem gambling?’
Some industry participants in particular expressed
a preference for proof of causal relationships
based upon large-scale, quantitative data.
The industry likes empirical research, based on
quantitative data and hard evidence. Evidence
38
means if x then y. They don’t want low-quality
research that focuses on problem gamblers and
is based on hearsay. They don’t want research
that threatens profits, like work on Fixed Odds
Betting Terminals. They are the goose laying
golden eggs. MIoUK(11)42
Others expressed dissatisfaction with this ap-
proach.
We cling onto this sort of position that is person-
ified by Harvard in particular, this uber-
empiricist worldview where everything can be
objectively measured in some way, whereas I
think that research that has been done from a
qualitative perspective actually sheds a great
deal more light on what gamblers really think.
I’m very pragmatic in my views of what is good
enough evidence. The old idea of taking a pre-
cautionary principle is entirely apt when it comes
to social harms like gambling and alcohol and
so the quest for the sort of levels of causality
and association and proof that the commission
and the strategy board keep chuntering on
about are a waste of time. MInUK(8)35
Researchers also called for recognition of a variety
of forms of evidence on the basis that different
problems called for different types of questions
and therefore different methods. Too often prob-
lem gambling is presented as the only possible
problem. Problem games, problem products and
problem policies, for example, receive much less
critical attention.
I think that one of the things that frustrates me
about the research environment at the moment
is that there is not enough appreciation of dif-
ferent methods and how every method is
question relative. You have to think about the
question you are trying to answer. XXXXX
Some felt that gambling studies was slow to recog-
nise the importance of qualitative approaches,
unlike alcohol research, and suffered from a nar-
row definition of evidence which was not shared by
related disciplines (see also sections 26–34).
One of the ways in which the industry-friendly
academics attacked us at workshops and con-
ferences was around the fact that our stuff was
only anecdotal and that we were cherry picking
things that were negative or bad. In fields like
alcohol or leisure studies there’s a huge amount
of qualitative research … they recognise it as a
valid evidence base and I think that’s partly why
the narrow policing of the field around a par-
ticular tradition of quantitative research is part
of the way in which they are able to undermine
more critical work. Because they just don’t care
to accept the same kinds of evidence which other
fields or disciplines would. FRaUK(7)67
What kind of evidence does the industry value?
The industry commissions and welcomes research
which suggests that gambling is a positive social
activity which is not harmful for the majority of
gamblers.
Have you read the new book by Patrick Ba-
sham? Gambling: a healthy bet. It’s one of the
new bits of work coming out which proves that
the idea that gambling is harmful has been cre-
ated and nurtured by do-gooders and religious
nuts. This is the kind of work that we want to see
– open and accurate, evidence-based and un-
biased. Gambling is educational, sociable, it
teaches them about risk, it is enjoyable, it is part
of every culture. If gambling was bad for us then
it would have died out! People aren’t stupid. It’s
good for us, this is Basham’s point, and well
overdue. Time we had someone providing a sci-
entific view in research when we find so much
misinformation that the press loves and the in-
dustry despairs about. MIoUK(2)32
Betting shops are very sociable places aren’t
they? Very sociable. Very misunderstood. Won-
derful characters there. You should write
something about that. That would really be quite
unique and we would welcome that kind of
work. MIoUK(5)31
Other members of the industry use research to bet-
ter understand how to produce addictive or ‘sticky’
products.
What we want to know is what could we offer
to big poker players in order to be more attrac-
tive to them? I also think we would need to know
39
better how a poker room would communicate
with the rest of the casino. You know, how to get
these players to play other table games, to re-
ally gamble. MIoSEE(15)5
The only thing I might use gambling research for
is to tell me how to set up stakes and prizes. So
I might look at a problem gambling paper, or
read Natasha Schull’s book to see how I make
my products sticky, addictive, or whatever.
MInUK(5)53
Policy is not based only on evidence
The difficulties of producing evidence-based poli-
cies are not unique to gambling. In 2012, Davies
used four UK case studies to illustrate that although
there are relatively few cases in which unequivocal
evidence can be used directly, data may also be
used ‘conceptually’: to enlighten and thereby indi-
rectly influence policy and ‘symbolically’, ‘to
legitimate and sustain predetermined positions’.36
The impact of evidence is not predictable, because,
as Banks has argued, its reception is contingent on
many other factors: ‘policy decisions will typically
be influenced by much more than objective evi-
dence, or rational analysis. Values, interests,
personalities, timing, circumstance and happen-
stance – in short democracy – determine what
actually happens.’37
From a lawyer’s perspective this is why evi-
dence-based policy is a bit of a red herring. It
draws a veil over a lot of more complicated
economic and political issues. MRiOE(15)89
The main issue for gambling with the exception
of Las Vegas and Macau is that it’s just not im-
portant. If you say the laws are outdated the
general response is ‘well, yeah’. There’s no real
attractiveness for a politician to say ‘I’m going
to change the gambling law’! Then, when you do
ask for a decision, no matter what evidence you
put in front of them they make their minds up on
the weirdest and most irrational grounds. It is
predictably unpredictable. If you don’t like the
decision today, wait until tomorrow and try
again! MUrOE(9)90
36 Davies, P. 2012. ‘The State of Evidence-Based Policy Evaluation and its Role in Policy Formation’, National Institute Eco-
nomic Review 219 (1): R41–R52.
37 Banks, Evidence-based policy making: What is it? How do we get it?
At the most mundane level there was a lack of time
to devote to understanding complex questions and
arguments.
Gambling is a complicated subject and politi-
cians don’t have time to understand it. It’s all
about politics … MRiOE(15)89
At a local level, policy making was circumscribed
by national legislation.
Even if the research showed that there was a
direct correlation between betting shops and
deprivation there’s nothing we can use it for ex-
cept raising awareness. In practical terms
research is useless when you have national reg-
ulation … real politics takes over. FUpUK(2)96
At all levels, policy makers were mindful of poten-
tially hostile media reactions to changes in
legislation.
Gambling is a poisoned chalice for ministers and
politicians. There are no votes in gambling, no
good news stories, just the Daily Mail breathing
down your neck, waiting for the next single
mother on benefits to rack up an enormous debt
with some bookmaker. Then you get it in the
neck. Legislating is a nightmare. People don’t re-
spond to the evidence, they have preconceived
ideas about gambling, and you can’t unsettle
them using evidence, that is such an idealistic ap-
proach. Those attitudes are deeply ingrained
and they are there to represent their constitu-
ents, and so they reflect their views as best they
can. MUpUK(40)87
Several stakeholders suggested that continually re-
ferring to a lack of evidence justified a ‘wait and
40
see’ policy of inaction and was part of a wider
power game in the field. This constitutes a ‘sym-
bolic’ use of evidence, according to Davies’
categorisation.
This issue is becoming a really hot potato and
everything that we do must be accountable. We
are looking at votes, and the council would like
to commission research to be seen to be doing
something. FUrUK(2)94
We did a study of how to implement in high
schools a programme on problem gambling pre-
vention. We gave the commissioners concrete
recommendations of how to introduce people
who would moderate such programmes at
schools and educate the general public. [...] Un-
fortunately, the research probably ended up
somewhere in an archive, the project was closed
and that’s it. Such is the practice in this country.
FRaSEE(6)1
One civil servant told me the industry was pres-
suring government to have more pokie machines.
They were having trouble saying no because
there was no evidence at all, and the very fact
that we could start this programme, they could
say ‘Well let’s wait and see what the evidence
says before we make a decision.’ Even if the ev-
idence is in process or they didn’t use it, they
could use it to put a buffer in between industry
and individuals or government. I found that out
after the fact that [because of] us running that
programme there was no increase in poker ma-
chines in that time. So in a way the effect on
policy wasn’t a positive one, it was one you
wouldn’t have noticed, it was the fact that noth-
ing did increase while you were doing it as part
of a process rather than I had some unique in-
tervention that could either help problem
gamblers or help efficiency of management or
regulation. It was more that you could be used
as part of the discourse and that in itself had an
outcome. MRaAU(12)98
Size matters
Those who used quantitative methods favoured
large samples and criticised ‘evidence’ based on
small samples. The most common complaint, from
economists in particular, was that psychologists
used small-scale surveys to support generalisations
about the wider population.
I review a lot of gambling research and I have
seen what I think is poor practice in terms of
people making highly questionable inferences
from very small and highly selective samples, in
terms of the survey evidence people have used.
I might be partial being an economist, but I think
there are some poor practices in some of the
gambling literature: very questionable infer-
ences, making very strong inferences from very
weak data. XXXXX
I’m not hostile to psychology or qualitative re-
search but I think there is overconfidence in
psychology that your findings are strong enough
that you would tell regulators that you should
change policy, when in fact you’ve talked to too
few people to interfere in a commercial sector.
You need evidence which is stronger than inter-
viewing people. XXXXX
Those who used small samples argued that conclu-
sions based on small samples, whether of
quantitative or qualitative data, needed to be
measured and provisional, but could nonetheless
generate important insights.
I cringe at some of the papers published now
that have a dataset of 1 million. The first paper
I wrote was based on eight gamblers. It’s still a
nice little paper. The idea of datasets of hun-
dreds of thousands is quite recent. XXXXX
Between the real world and the laboratory
There is a long tradition of researchers attempting
to reproduce the conditions under which gamblers
make decisions in the laboratory, commonly using
psychology students as their subjects. Lab-based
studies are thought by some to be capable of
41
providing evidence about causal relationships be-
tween frequency of bet or volume of stake and
behaviour. They are often contrasted with studies
that take place in ‘natural’ environments including
betting shops and casinos where it is far more dif-
ficult to attribute changes in behaviour to isolated
variables.
I think the naturalistic studies inherently have a
number of limitations, in terms of you have very
little control over the environment and I think
that’s where the lab-based stuff that we do has
some advantages. I often end up in conversa-
tions with people about the importance of the
lab stuff, they just say ‘These simulations, they
are too basic, they don’t capture what we’re in-
terested in and it all should be field research.’
And I suppose I feel as though I’m banging my
head against a brick wall in that I don’t seem
able to convince them. In the laboratory our ap-
proach is a very piecemeal [one] and I admit
that but we basically take structural character-
istics more or less one at a time. So, okay, let’s
just do a study on near misses, we’re going to
strip a slot machine down to its bare bones and
we are going to either present different rates of
near misses or we are going to present near
misses and ask them to give some sort of rating
or some sort of behavioural measure after them,
and we are going to try to work out how the
near miss works in this experiment. This is very
methodical, very piecemeal work, but that way
you can, if you see an influence of that thing that
you’ve manipulated, I think you have a very
clear signal that that does something and hope-
fully that would then converge with some
naturalistic fieldwork that might give you a clue
that that was a relevant variable in the first
place. I think it’s very hard from the field re-
search to know that this is from the rate of near
misses, or whatever. It’s the lab studies that al-
low us to identify which is the key thing that we
should be legislating. XXXXX
Stakeholders in every sector felt that lab-based
studies could also produce unrealistic depictions of
gambling experiences.
A lot of the literature is quite medicalised and
quite quantitative, but also that whole neurosci-
ence literature trying to look at the medical
nature of addiction and seeing that stuff where
the brain lights up when they play a fruit ma-
chine, and I have quite a few concerns about
that approach because it’s quite reductive and
determinist. FRaUK(7)67
The stuff on risky decision making done with
Psych 101 students, I have some difficulties with
that. These are very simple tasks which are very
alien from the environment in which you would
be making those decisions. And you’re looking
at adolescents up to 25. They are not repre-
sentative of the adult population.
MRaUK(40)57
There has been necessarily, and I understand
why, a lot of lab work and a lot of work with
students at universities and so on as proxies for
real behaviour but actually let’s really try and
look at what real people do in real time. MI-
oUK(12)41
Being incredibly cynical, we all hear stories of
drugs companies wanting to sell their drugs. I
think it’s incredibly disempowering for clients to
hear that. There was a bit in a programme
where a brain was scanned and it frightened the
living daylights out of so many clients, because
if there’s something wrong with my brain how
am I ever going to be able to change my be-
haviour? But again my evidence suggests that if
it’s been argued that problem gambling exists
because of something faulty in their neurotrans-
mitter or something, how do we explain people
who do stop gambling and have still stopped a
year later as a result of actually looking at what
it was that triggered it in terms of their relation-
ships and their lifestyle? How do you explain
that? XXXXX
None of our participants suggested that lab studies
could replace naturalistic studies, and many felt
that both were essential, as they answered differ-
ent questions and provided different kinds of data.
When you’re looking at processes that you’d
like to in some sense measure, you really have
to have good experimental design, sometimes
work in the lab, sometimes work on the internet,
and then, just bring some really sort of good
quantitative methods, I think they are comple-
mentary, I don’t think that one is prior, they are
there to understand things at different levels
42
and I’ve become much more catholic in the meth-
ods that I use, I really don’t mind using different
methods now. XXXXX
Prevalence studies – the holy cow of gambling research
Let’s just take prevalence research for a mo-
ment. It’s one of those holy cows, where
everybody recognises that this cow is slightly im-
perfect and it’s been in the field quite a few
years now but actually it sort of works and it sort
of gives you an output of milk called surveys that
are done from time to time, but nobody ever
asks the question of whether conducting preva-
lence research in the way that we do is the right
approach. […] And so much is predicated on
this. And so we don’t talk about that, it’s the im-
perfect cow in the corner of the field that we all
know and love and milk and actually perhaps
we ought to be thinking whether some other
beast might serve our purpose better but I think
that would be a question just too hard to ask at
the moment. MInUK(8)35
Prevalence studies express the number of problem
gamblers as a percentage of the population. They
are commonly commissioned by the state as well as
being accepted as authoritative by the industry. As
the recent select committee report in the UK
showed, they are of limited value as a basis for
policy because they are subject to widely different
interpretations. The select committee described the
evidence provided by the prevalence study, and
the range of possible interpretations of its findings.
It is important to note that, whilst the increase
in the number of problem gamblers observed
between 2007 and 2010 is most likely to be
0.9% (a 50% rise), the increase could in fact
lie within a range of between 0.7% and
1.2%. In other words, the percentage in-
crease could be in the order of between 16%
and 100%. Whilst the most likely level of in-
crease identified by the BGPS is 50%, this
result is defined as only marginally significant
due to factors such as the relatively small
sample size.38
38 Culture, Media and Sport Committee, The Gambling Act 2005: A bet worth taking?, paragraph 25.
39 Culture, Media and Sport Committee, The Gambling Act 2005: A bet worth taking?, paragraph 26.
It then goes on to quote an alternative interpreta-
tion.
Whilst it is agreed that the findings of the
BGPS are significant in the sense that they
are ‘statistically significant’, there is debate
as to whether this translates into ‘real-world’
significance. Gambling industry representa-
tives argue that little has changed, with the
Bingo Association stating that: ‘levels of prob-
lem gambling remain broadly the same as
before the Act was implemented’.39
As well as problems of statistical significance, there
is limited consensus on who qualifies as a problem
gambler and whether self-reported data is a
sound basis for such a survey.
I think that the methodology behind trying to
identify who is and is not a problem gambler
could have had a different approach that would
have been more effective. I’m not convinced by
the history of those three surveys. I will wait and
see what comes out of the replacements, but I
suspect that I shall have similar reservations
about that. This is of course because they are
based on screens which are questionable and
variable, but also because so much of it comes
out of self-report and of course if you are being
asked whether you have a problem I think natu-
rally you would shy away from saying that you
have. MIoUK(12)41
There is also no agreement as to how the study can
capture people who are at risk and have not yet
developed a problem, or whether this measure-
ment is significant. The prevalence survey provides
a snapshot of problem gamblers without giving
any indication of how this behaviour changes
through time. It does not include data about how
non-problem gamblers are affected by problem
gambling.
43
The large population surveys have been done
thousands of times. Most funding around the
world has been sucked into this. Mainly, I would
argue, because they are very convenient for in-
dustry and government because most of the
surveys pretty much say the same thing, that 1
to 2% per cent of the population has got prob-
lem gambling issues, but beyond that there is
very little investment, except some investment in
treatment research. XXXXX
I don’t think the prevalence study is any good,
that sounds horrible, because it’s a big study
and it’s quite well done, but the questions are
not fabulous. The data that you get relates to
the questions that you ask. FRaUK(11)61
There are alternatives to using prevalence studies
to express the number of problem gamblers as a
percentage of the total population, including refer-
ring to the actual number, or identifying additional
categories such as people at risk of developing a
problem.
I’m less interested in the proportion of the whole
population that has a gambling problem. I’m
much more interested in the number of gamblers
who have got a gambling problem. If we were
only to concentrate on that issue then we could
stop some of this daft talk about ‘Well it only
affects a tiny number of people’ blah de blah
and ask ‘Who’s at risk?’ MInUK(8)35
In policy it’s typically a quantitative basis, tied
to the evidence-based policy, where numbers
seem to be the most important thing. You look at
prevalence studies and those kinds of things, the
interest is not the number of problem gamblers
but the percentage, which is interesting because
that percentage could be a large number of
people. It’s funny how it becomes acceptable for
industry or state to say the rates are 1 to 3%
and therefore that’s fine. Gambling studies, at
least in the main journals, is dominated by a
numbers ontology. XXXXX
Prevalence studies paradoxes
When commissioned, the Gambling Commission
described how the prevalence study would be used
to provide comparisons between ‘pre- and post-
implementation of the Gambling Act 2005’ and ‘to
help develop policy for the regulation of gambling
and to advise the Secretary of State on gambling
issues’.40 However, the type of evidence called for
by policy makers and industry is much more specific
than the type of evidence that the prevalence
study produces. The prevalence study measures the
percentage of problem gamblers in the popula-
tion, while evidence which supports a change of
regulation is expected to capture causal relation-
ships between particular products or policies and
problem gambling. This understanding of evidence
is described in statements from the Gambling Com-
mission, for example:
To date there is no evidence that establishes
the nature of any causal link between gaming
machines (fruit machines, slot machines) and
40 Gambling Commission Web Pages, 2013. ‘British Gambling Prevalence Survey 2010’. URL: http://tinyurl.com/keuzf2y.
Accessed 14 November 2013.
41 Gambling Commission Web Pages, 2013. ‘Frequently Asked Questions’. URL: http://tinyurl.com/lkpkqkw. Accessed 14
November 2013.
problem gambling. While rates of problem
gambling may be higher amongst gamblers
who participate in certain activities, this does
not necessarily mean that the type of gam-
bling in question causes people to develop
problems to a greater extent than other
forms of gambling.41
According to this understanding of evidence, no
significance can be attached to higher rates of
problem gambling associated with any particular
product, as problem gamblers may choose to use
these products, but their problem gambling may
have been ‘caused’ by anything (a genetic or per-
sonality predisposition, for example). This use of
evidence is also illustrated by the select committee
of 2012:
The imprecise nature of [the BGPS] findings
also results in part from the lack of any sig-
nificant studies on the causes of problem
gambling. Professor Orford told us that the
44
increase in problem gambling levels was as
a ‘consequence of the changes introduced un-
der the Act’. Whilst we recognise that the
figures from the BGPS show a likely increase
of 50% in the numbers of problem gamblers,
we have seen no hard evidence to support
the view that this increase was the result of
the 2005 Act.42
The prevalence study supports and enables strate-
gic inertia. Between prevalence studies the
approach to policy can be ‘wait and see’. Once
results are known, they may be endorsed or con-
demned as having fallen short of the standard of
evidence required to justify changes to policy.
The prevalence study we wait for and if it’s
good news and stands up then it will be useful.
If it doesn’t it gets rubbished, we just ask is it
robust and will it stand up in court. It depends
on what hat I’m wearing. If the rate goes up and
I’m objecting to a licence or to deregulation in
another sector then that will be of use. MI-
oUK(20)74
Gary Banks, chairman of the Productivity Commis-
sion in Australia, has described the double
standard employed by the industry in arguments
about evidence:
The industry essentially owes its existence and
current size to the lack of an evidence-based
approach to liberalization, which has resulted
in extensive ‘community-based gambling’. It
subsequently protested only a little at the
lack of evidence for most of the (ineffectual)
harm minimisation measures introduced over
the past decade, despite their compliance
costs. But it has been insistent on high stand-
ards of proof for measures that promise to
be effective. One major industry group even
suggested that no measure should be intro-
duced if the possibility of error was more
than 1 in a 1000!43
In the UK, the situation is comfortable: the govern-
ment, the regulator and the industry all endorse the
position that problems with gambling are caused
by faulty individuals rather than dangerous prod-
ucts or policies.
Research conducted outside the control of the in-
dustry was treated with huge caution and even
suspicion because there was a fear that work
may suggest that gambling problems are not
only caused by the weakness of character or
mental health but could actually reflect the way
that gambling is marketed and provided. What
no one will say and what the (UK Gambling)
Commission has refused to say throughout is that
causality may run in both directions. Or, if not in
both directions, then at least to the extent of
saying, well, it could be the product and not the
person. Essentially, they say: ‘no, let’s just throw
all our money at treatment’ and all members of
the industry held quite closely to that.
MRcUK(10)79
Beyond prevalence studies
There was no agreement as to whether or not it
was in principle possible to produce evidence of
causation between particular products and prob-
lem gambling, or between changes in policy and
changes in the rate of problem gambling ex-
pressed as a percentage of the total population.
A mixture of longitudinal studies, qualitative stud-
ies into gambling behaviour and its environments,
complemented with lab experiments to assess the
way both gamblers and non-gamblers interact with
products, could provide evidence from a number
of different perspectives. However it would be
42 Culture, Media and Sport Committee, The Gambling Act 2005: A bet worth taking?, paragraph 27.
43 Banks, G. 2011. Presentation to South Australian Centre for Economic Studies, Corporate Seminar, Adelaide, 30 March,
6.
very expensive and still might not meet the stand-
ards of proof called for by the industry, regulators
and policy makers.
In order to establish causality, you need longitu-
dinal studies. Let’s start with an example, let’s
say the hypothesis is ‘Slot machines cause gam-
bling problems’. That is often stated as a fact in
the field, but if you look at the bulk of research,
what’s been done is asking gamblers in treat-
ment which game they played that got them into
trouble and the bulk of those people will say slot
45
machines. So your evidence there is retrospec-
tive. People looking back and trying to identify
the cause of their problems, and it’s based on a
very small sub-sample of gamblers who have
problems because we know that not many gam-
blers with problems go into treatment. So you
then have some evidence that suggests there’s
this link. What you would need to do to establish
that with more certainty is to, if you didn’t have
issues of funding, which are huge, you would do
a very large-scale longitudinal study starting
with people who may be prone to having gam-
bling problems but you would have to start
early and see who plays what games and then
who develops problems. That would be a first
step and you might find through that design that
people who ended up playing slot machines
would then have greater incidence of gambling
problems. From there, you ask the question, well
is it slot machines causing gambling problems or
is it potentially something about the people and
their personalities that draws them both to slot
machines and draws them to potentially have
problems as well, the third variable. And so then
I would say you might need to start moving to-
ward laboratory experiments, where you have
a casino lab and you’re looking at some kind of
large-scale study where people who haven’t
been gambling are introduced to many differ-
ent types of games, maybe across a couple of
weeks, and you might see who has markers of
developing problems based on that. That would
be more of a control study. So that’s one way to
go about establishing evidence for that hypoth-
esis. I think it’s important that you use multiple
methods – every method has its own problems.
With casino labs the argument is that it is not
very realistic – even if you give people real
money it’s not money that they earned that they
care about so they don’t think about it in the
same way. You really need a whole mix of
methods and all the evidence pointing in the
same direction before you can be sure of a
causal link. If you’re a funder and you don’t
have a full understanding of these design issues
then a longitudinal study is a lot more expensive
than doing the same kind of thing with a cross-
sectional study. There’s debate as to what you
can measure with repeated cross-sectional stud-
ies. We would argue you can’t measure
causality and impact and other groups might
say that you can get at it at least. FRaUS(11)66
46
The fiel