UKGC: No Data on Harm Algorithm Marketing Links
FOI reveals the regulator does not record specific data on how operators' risk algorithms interact with marketing, a key area of player protection.
A Freedom of Information request has revealed the UK Gambling Commission does not specifically record data on how operators' harm reduction algorithms influence marketing. While 236 assessments since June 2022 checked marketing rules, the regulator could not provide details on this crucial technological interaction.
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Regulator Does Not Record Key Data on Marketing and Risk Algorithms
A Freedom of Information (FOI) response from the UK Gambling Commission (UKGC) has revealed that the regulator does not record specific data on how operators’ safer gambling algorithms interact with their marketing activities. This lack of data relates to a critical area of consumer protection, where technology designed to identify at-risk players should prevent them from receiving marketing communications.
The request, dated 1 September 2025, sought to understand the depth of the UKGC’s compliance assessments into marketing and advertising rules designed to protect vulnerable people.
What the Data Shows
The FOI response confirmed that since 1 June 2022, the Commission has conducted 236 full compliance assessments that would have included checks on key marketing rules. These rules, found in the Licence Conditions and Codes of Practice (LCCP), include:
- 5.1.6: Compliance with advertising codes
- 5.1.11: Rules for obtaining consent for direct electronic marketing
- 5.1.12: Systems for honouring customer preferences regarding direct marketing
However, the response contained two significant revelations regarding the limits of the UKGC's recorded data.
No Data on Algorithm and Marketing Interaction
Crucially, when asked how many assessments made findings on the interaction between “risk algorithms” or “harm reduction algorithms” and marketing activities, the UKGC stated:
"The Commission can also confirm that we do not record information falling within the scope of questions 2 and 3 of your request."
This means the regulator does not hold structured, reportable data on its findings related to one of the most important modern safer gambling controls: ensuring that players flagged as at-risk by an operator's algorithm are shielded from marketing. The same response was given to a question about the technical mechanisms operators use to capture marketing consent.
Incomplete Picture of Overall Assessments
The UKGC also declined to provide a complete count of all assessment types (including thematic and follow-up reviews) that touched on these marketing rules. The regulator cited Section 12 of the FOIA, stating that a manual review of all records to extract this information would exceed the £450 cost limit, equivalent to 18 hours of staff time.
Why This Matters for Consumers
Modern gambling regulation relies heavily on operators using technology to protect players. Harm reduction algorithms are supposed to be a key line of defence, identifying patterns of play that may indicate risk and triggering interventions.
A critical intervention is the immediate cessation of all marketing and promotional offers to that player. The UKGC's admission that it does not specifically record findings on this interaction raises questions about the level of detailed oversight being applied to these automated systems.
While the 236 full assessments show that marketing rules are being checked, the inability to provide specific data on the link between risk identification and marketing suppression is a significant gap in regulatory transparency. For consumers, it means there is no publicly available data from the regulator to verify how effectively it is scrutinising the technology that should protect them from being marketed to when they are most vulnerable.