If there’s one thing the past few decades of public health policy have taught us, it’s that campaigns for more information are never satisfied with more information.
On the consumer side, the tendency is always to resort to more draconian measures if simply giving people the evidence to ‘make informed choices’ doesn’t lead to the behavioural change desired. On the state side, more data invariably serves to fuel demands that something must be done.
It is also the case that measures justified as a unique response to one especially problematic product will, if proven effective, be rolled out to other products eventually, just as the arguments and policies first employed against tobacco are now being turned on sugar and other modern vices.
So it is not just gamblers who should be concerned by plans for the Government to impose a new regime – the ‘Single Consumer View’ – on the online betting sector.
The logic behind the idea is that many problem gamblers have multiple accounts, which makes it harder for companies to monitor their habits and implement the current protections in place to try and limit people’s capacity to make life-destroying losses.
To prevent this, the plan is to mandate gambling companies to share their customers’ ‘behavioural’ data with both rival firms and two state agencies, the Gambling Commission and the Information Commissioner’s Office (ICO). At least, that’s the plan to start with – apparently the Gambling Commission is already mulling ways in which this dataset could be expanded to include more detailed ‘Know Your Customer’ data including, potentially, information on a user’s personal income.
Everybody who registered more than one gambling account would be included on this register, with no opt-out.
On the face of it, as so often, this seems sensible enough, especially if you don’t gamble. But the first thing to note is that ‘everyone with more than one gambling account’ is potentially a much, much larger pool than ‘problem gamblers’. A second account need not be part of a deliberate effort to bypass safeguarding measures, after all. One could simply have accounts with different bookies to pursue the best odds for particular events. Or have one with a bookie and one with an online poker site.
So the state may well end up holding a huge amount of personal data on people whose behaviour is not remotely problematic. If you believe the exercise of such powers should be carefully targeted and proportionate to the problem, that isn’t great.
Worse, there is no guarantee that the Government will manage to keep this data secure. Indeed, current proposals will already require the database to be accessible not just to two different state agencies but also an indeterminate number of private companies and doubtless, in time, other government bodies. It will thus presumably be held online.
Even discounting the classic ‘civil servant leaves the CDs on the bus’ scenario, the danger of this data eventually finding its way into the public domain seems considerable. The broader this dataset ends up being, the more worrying a prospect this is. And bad as it would be for non-problem gamblers, the subset of users who are genuinely vulnerable risk having their contact information and betting history fall into the hands of scam artists and other predators.
There is also the risk that once this database was assembled, it will fuel mission creep. First, because if government goes to a lot of trouble and expense to assemble something there is always huge pressure to use it. Second, because it will give the sort of person minded to intervene in the lives of others more information that offends their sensibilities.
Consider how Public Health England have previously attempted, in covert concert with pro-temperance organisations, to redefine ‘problem drinking’. Do you suppose for a minute that similar lobby groups will not bring the same pressure to bear on ‘problem gambling’? And since a broader definition will afford more opportunities to do something, and justify more power for the agencies responsible, they will likely find a receptive audience.
Finally, there is the risk of setting a precedent. The danger might not be immediately apparent, but think about the problem in the multi-decade terms that it usually takes for authoritarian public health measures to metastasise from one product to another.
Is it impossible to imagine, in the 2030s or 2040s, that we might all have been asked to create accounts – just for informational purposes! – to check in whenever we buy alcohol? Or cigarettes, assuming they’re legal? Or that the Government might see the advantages of a ‘Single Consumer View’ to send you ‘nudges’ when your groceries feature sugar or fatty foods too heavily?
Observation and data collection are not the passive, neutral acts they are sometimes dressed up as. They can both directly change our behaviour and hugely increase the capacity of the state to act on us, even before taking into consideration that it often cannot be trusted to operate securely. If this consumer-data panopticon does get built, we may all get trapped inside it sooner or later.
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