A Very Public Deception: Part III – Conspiracy of Silence

Why did many who knew that gambling suicide statistics were unsound keep quiet?

A previously released version of this article mistakenly attributed the wrong author. This article has been written by Dan Waugh.

This is the third in a series of articles examining claims made by state bodies about suicides in England associated with ‘problem gambling’. In the first we demonstrated that estimates of suicide mortality produced, first by Public Health England (‘PHE’, 2021) and then by the Office for Health Improvement and Disparities (‘OHID’, 2023) are categorically unsound. In the second, we looked at the behaviour of PHE and OHID, finding indications of a priori bias, research neglect and poor governance.

In this third article, we examine the conduct of others in positions of authority and ask why so many people who knew that the PHE and OHID claims were unreliable decided to look the other way. We also highlight the contributions of those who were prepared to apply critical analysis. We observe that, while gambling disorder has been recognised as a risk factor for self-harm for more than 40 years, efforts to address this are unlikely to be advanced by the use of junk science; and question how far those who have propagated misinformation should be trusted in the future.

Why did the Gambling Commission not ‘do the right thing’?

By April 2022, Britain’s Gambling Commission knew that estimates of suicide mortality published by PHE were “unreliable” and based on “inaccurate” assumptions. This may have been a somewhat uncomfortable discovery, given that the regulator had previously described the review as “important and independent” – an opinion based on a reading of nothing more than the executive summary (it had not been party to even this much when it agreed to provide PHE with “a supportive quote”). It also knew that PHE was far from “independent” or impartial, having been made aware of its desire to apply tobacco-style controls to participation in betting and gaming.

At a meeting in March 2022, Gambling Commission officials admitted that they did not understand how PHE had arrived at some of its estimates (no-one could have been expected to - the calculations were mathematically incorrect). In April, these officials circulated a highly critical review of the PHE report, in which they noted that the suicide claims were not based on “reliable data”. The Commission however, elected not to take up the matter with the OHID (which had subsumed PHE upon the latter’s disbandment) or to inform the Secretary of State. The market regulator – which counts “doing the right thing” among its corporate values – elected to suppress its own critique. In one rather sinister coda, an official speculated that PHE’s claim of more than 400 suicides might be rescued, if only future prevalence surveys could show a higher rate of ‘problem gambling’ in the population. At this point, the Commission had already started work on a new Gambling Survey for Great Britain in the expectation that – through methodological artefact alone – it would produce a higher rate of ‘problem gambling’ than reported by NHS Health Surveys.  

When asked by journalists whether it considered the PHE claims to be reliable, the Gambling Commission responded that it was not its role to review the work of other state agencies; but failed to mention that this is precisely what it had done. As late as 2023, its chief executive, Andrew Rhodes, continued to defend the OHID estimates, despite being aware of problems; and it seems likely that the market regulator has been involved in promoting the PHE-OHID claims via approval of regulatory settlement funds (to Gambling with Lives and the Association of Directors of Public Health among others).

The ABSG and the irrelevance of accuracy

In the summer of 2022, the OHID wrote to the Gambling Commission’s Advisory Board for Safer Gambling (‘ABSG’) to ask for its opinion. In her response, the ABSG’s chair, Dr Anna van der Gaag agreed with critics of the PHE report, writing: “I see their point about basing calculations on the Swedish hospital study leading to an over estimation of the numbers”. She suggested however, that accuracy in such matters was unimportant and that any attempt to apply scrutiny was “a distraction from what matters to people and families harmed by gambling”. In other correspondence, Dr van der Gaag disparaged the efforts of researchers examining PHE’s claims, comparing them without foundation to ‘Big Oil’. Dr van der Gaag’s apparent indifference to accuracy represented a change of heart from three months earlier when the ABSG had described PHE’s highly exact (but false) estimate of 409 suicides associated with problem gambling as a “catalyst towards action”. The Gambling Commission, for its part, allowed the ABSG to publish this statement in the full knowledge that it was based on unreliable data.

The following year, Dr van der Gaag was one of two co-adjudicators responsible for allocating around £1m in regulatory settlement funds for the purposes of research into suicide and gambling. Applicants were specifically directed towards the OHID analysis (i.e. estimates that the ABSG knew were flawed) as well as claims by the activist group, Gambling With Lives (‘GwL’) - despite the fact that even the OHID had criticised the basis of one GwL claim. One of the successful bids (a £582,599 award to a consortium led by the University of Lincoln) included GwL as an active member of the research team.

The Silence of the ‘Independents’

Among those who have supported the claims of PHE-OHID are a number of self-styled ‘independent’ researchers. These include academics from the universities of Cambridge, Hong Kong, Lincoln, Manchester, Nottingham and Southampton, as well as King’s College, London, who have cited the estimates uncritically in their work. Perhaps they considered (naively, if so) that research produced by the Government is unimpeachable; yet the errors made by PHE-OHID are so glaring that no researcher of any calibre could have failed to notice them. An unwillingness to subject such serious claims to critical analysis before repeating them indicates – at the very least – an absence of intellectual curiosity. Much is made of the need for research independence (typically defined solely by an absence of industry funding, regardless of ideology or other affiliations); but independence has little value if it is not accompanied by intelligence and integrity.

Breaking ground

A small number of groups and individuals have been prepared to apply scrutiny and challenge, despite the circumstances. In addition to the current series, Cieo has published a number of articles on the problems with PHE-OHID (as well as other issues with activist research). The Racing Post and a handful of journalists, including Christopher Snowdon, Steve Hoare and Scott Longley have been prepared to challenge the PHE-OHID claims. Figures from trade groups, bacta and the Gambling Business Group have spoken out publicly on issues with PHE-OHID.

Officials at the Department for Culture, Media and Sport have displayed a capacity for critical analysis, notable by its absence elsewhere in Whitehall. Their White Paper on reform of the betting and gaming market acknowledged valid concerns about self-harm but conspicuously omitted the OHID figures. Lord Foster of Bath, a stern critic of the gambling industry, has acknowledged that the PHE-OHID claims are not reliable and – in a display of honesty and humility rare in the gambling debate - apologised for using the figures himself. He continues to make the case for self-harm to be treated seriously in a gambling context; but without recourse to spurious statistics. Philip Davies, the Conservative Member of Parliament for Shipley, has challenged unsound statistics in parliamentary debates; and Dame Caroline Dinenage’s select committee for Culture, Media and Sport noted concerns of reliability in its report on gambling regulation. The Gambling Commission’s executive director for research and statistics, Tim Miller, has been prepared to discuss and acknowledge problems with PHE-OHID where his senior management colleagues have not. Doing the right thing can sometimes be a lonely endeavour.

Time to come clean

The PHE-OHID deception happened because people in positions of authority considered it acceptable to publish inaccurate mortality statistics. One even suggested that scrutiny of misinformation - rather than its manufacture – is unethical. It is reasonable therefore to ask how far the organisations involved in the cover-up might be trusted. In July this year, the Gambling Commission intends to publish statistics on the prevalence of suicidal behaviour amongst gamblers. It has also (as noted above) sponsored Gambling Research Exchange Ontario’s (‘GREO’) programme of research into wagering and self-harm – a programme explicitly grounded in the PHE-OHID fabrications. If the Gambling Commission, the ABSG, GREO and others are unwilling to come clean about the problems with PHE-OHID, any further research is likely to be viewed with suspicion. Contrary to what some appear to believe, it is the production of unreliable research – rather than its scrutiny – that undermines public trust in authority. Attempts to address health harms in any domain will be ineffective if they are based on inaccurate evidence – and manufacturing mortality statistics should never be acceptable.

An independent and open review should now be carried out into the PHE-OHID deception; but it is difficult to see how this will happen. The Department of Health and Social Care and the Gambling Commission are unlikely to embrace scrutiny; and the DCMS will not wish to embarrass either its regulator or another government department. There are too many people in Parliament and the media who have been complicit; and too few prepared to break ranks. The gambling industry meanwhile (with a number of notable exceptions) has shown little appetite for challenging misinformation. There is one hope – that the Office for Statistics Regulation will be prepared to take an interest in the integrity of public health estimates. Such an intervention would go some way towards restoring trust in public bodies.