Mr David Excell
Featurespace Limited
2nd Floor, Broers Building, Hauser Forum,
21 JJ Thomson Avenue,
Cambridge, CB3 0FA
United Kingdom
Email: [email protected]
17th August 2015
Dear Mr Excell,
Re: Endorsement of Featurespace by Sir Jeremy Heywood
You did not reply to our previous correspondence, a letter to Marc Etches on
13th February 2015, to which you were copied. Since that letter there have been
a number of relevant developments which we outline below.
Firstly, the Campaign commissioned an evaluation of the Responsible
Gambling Trust (RGT) research, carried out by Professor Linda Hancock and
assisted by Shannon Hanrahan. These individuals have impeccable credentials
and have no commercial motivations. Their evaluation is very critical of the RGT
research, particularly so of Featurespace’s contribution. It finds adequate
evidence to support a maximum stake reduction on FOBTs, despite the
research being designed to avoid investigating this aspect.
Secondly, when Lord Gardiner quoted Dr Adrian Parke, a researcher
commissioned by the RGT, in the House of Lords, he attributed Dr Parke’s
comments to the RGT. However, Lord Gardiner was subsequently corrected by
our Campaign. This resulted in the RGT having to state that it did not have a
view on FOBT stakes.
Thirdly, the respected researchers of GeoFutures and NatCen, also involved in
the RGT research, have had ample opportunity to endorse your comments
regarding the £2 stake limit, but have declined to do so.
Fourthly, Featurespace has recently entered into a commercial relationship with
William Hill.
Fifthly, Sir Jeremy Heywood of the Cabinet Office has taken the very unusual
step of endorsing the Featurespace representations regarding capability to
deliver problem gambling harm minimisation.
Finally, Featurespace has a close long-term relationship with Betfair, but there
has been no public disclosure of Betfair utilising Featurespace’s moneylaundering identification or harm minimisation technology.
A number of important questions arise as a result:
(1) As the RGT states that it has no position on FOBT stakes, and as the
evaluation of the RGT research shows there is support for stake reduction, will
you now be willing to admit that your comments against FOBT stake reduction
were not evidence based? If not, are you willing to provide evidence of any
other single modification to FOBTs that would have any better impact on
reducing gambling related harm?
(2) Does each of Featurespace, William Hill, other bookmakers and the two
FOBT suppliers have access to data that could be used to identify both betting
shops that are most prone to money-laundering and loyalty card holders who
are probable money-launderers? If so, and if no action has been taken on this
data, are each of these entities in breach of money-laundering regulations?
(3) Are the Featurespace representations regarding an ability to identify FOBT
problem gambling behaviour achievable today? If not, how much time will be
needed to enable compatible functionality across all FOBTs?
(4) Even if such functionality becomes available, as this must be implemented
by the bookmakers, are there any guarantees that it will be anything other than
a PR exercise, whereby flagging a behavioural change is only notified when a
gambler is in the extreme danger zone?
(5) Even if functionality and adequate early flagging are delivered, what
evidence is there that any intervention messages will have any behavioural
impact?
(6) Has Featurespace had an opportunity to influence government through
Nesta, a charity which invests in Featurespace and in the government Nudge
Unit - The Behavioral Insights Team? Has Featurespace had an opportunity to
influence government through it's executive Dr. Mike Lynch, a scientific advisor
to the Prime Minister?
Our Campaign recognises the socio-economic costs of FOBT gambling and
seeks to reduce the quantity of harm to the vulnerable. We do not live in a land
of “silver bullets”. We acknowledge that so much more could be done,
particularly in addressing the lack of adequate access to cognitive behavioural
therapy. But a reduction in harm will be achieved through reducing the
maximum stake, as former chief economist and head of research at the DCMS,
Dr. Stephen Creigh-Tyte, argued in his paper “Some Results on the Efficacy of
Methods of Regulating Machine Gambling”.
Dr. Creigh-Tyte concluded that: “…binding limitations on wagers can limit the
maximum session losses suffered by punters. The effect tends to be greater
the higher the prize and the larger the probability of winning and the lower the
time taken by each game.”
Dr. Creigh-Tyte goes on to state that: “This finding is in line with Blazczynski et
al. which found that there was a large reduction on time played, number of bets,
money lost and consumption of alcohol and tobacco among players of
machines the stake of $1 compared with those who played machines with
maximum stakes of $10.”
We are concerned that Featurespace has acted in its commercial interests to
make misleading representations which will result in delaying the
implementation of the single most effective harm reduction measure in respect
of harm to the vulnerable caused by FOBTs – maximum stake reduction to £2.
Accordingly we request that you respond to this letter in its entirety.
Yours sincerely,
Derek Webb
Adrian Parkinson
The Campaign for Fairer Gambling
www.fairergambling.org / www.stopthefobts.org
Matt Zarb-Cousin