£532,000 Gambling Data Plan Raises Privacy Questions Before Any Contract
The Gambling Commission is seeking market input on three years of anonymised financial data from British adults. No supplier has been chosen.
The Gambling Commission is planning a £532,000 project to obtain anonymised financial transaction data from adults in Great Britain. The data could help the regulator assess gambling spending, financial risk and consumer harm.
The procurement is still at the pre-market engagement stage. The Commission has not selected a supplier or awarded a contract.
The proposed service would run from 1 February 2027 to 31 January 2030, with an estimated value of £532,000 excluding VAT.
What data could be collected
The Commission is seeking a large, ongoing dataset covering adult residents of Great Britain. The information could include:
- transaction dates and times;
- transaction amounts and running balances;
- merchant names and descriptions;
- merchant category codes or another classification system;
- a unique identifier for each anonymised person.
Suppliers would also need to explain how they could identify gambling payments within wider financial activity. The Commission said gambling transactions can be difficult to classify using Open Banking data.
It is considering suppliers with their own identification methods or arrangements with third parties.
Linking gambling activity to financial wellbeing
The proposal could also include demographic information such as age and gender. Other possible measures include the Problem Gambling Severity Index and indicators of financial wellbeing, such as a credit rating.
This would allow the regulator to compare gambling payments with wider financial circumstances. It could also show spending across multiple licensed gambling businesses, which may not be visible in data from a single operator.
The Commission has previously used anonymised Open Banking data in research. A report published on 22 January 2026 examined spending on free draws and prize competitions using transaction data from consenting participants.
The report warned that its sample was not fully representative of Great Britain. That limitation would remain relevant when assessing any broader dataset.
Privacy safeguards will be central
Anonymisation would not remove the need for strict data governance. The proposed dataset could contain detailed financial histories, demographic attributes and persistent identifiers that allow activity to be tracked over time.
Information Commissioner’s Office guidance says organisations must assess re-identification risks when data is pseudonymised or combined with other information.
A final procurement would need to set clear rules for access, retention, permitted uses and protection against reconstructing individual identities.
Connection to wider regulatory changes
The project comes as the Commission prepares to introduce Financial Risk Assessments for some high-spending customers. In July 2026, it said the checks would be introduced in stages.
The initial stage would cover most customers aged 25 and over who exceed £5,000 in net deposits over a rolling 24-hour period.
The final planned thresholds are lower:
- more than £1,000 in net deposits over 24 hours for customers aged 25 and over;
- more than £3,000 in net deposits over 90 days for customers aged 25 and over;
- lower thresholds for certain higher-risk groups, including customers under 25.
The proposed transaction dataset is separate from those operator-level assessments. It is intended to support market research and regulatory analysis, not to create a direct check on every gambling customer.
What happens next
The engagement process will test whether suppliers can provide the data, identify gambling payments accurately and offer workable access and pricing models.
No supplier, operating dataset or final data specification has been confirmed. A separate procurement decision and formal contract award would be required before the service begins.
The project’s practical impact will depend on whether the Commission can gain broader visibility of gambling-related financial risk without creating disproportionate privacy risks.