Author: rebecca.axford

By Dr Raffaello Rossi, Lecturer in Marketing

In 2020, the UK government announced an overhaul of the Gambling Act to make the laws “fit for the digital age”.  Having spent a couple of years researching gambling ads on social media – I thought: “wow, this is exactly what we need” – not only because our own research had shown:

• 1m UK gambling ads per year on Twitter only,
• Two-thirds of all gambling accounts followers online are under 25,
• Gambling ads on social media are highly appealing to children – but not to adults, and that
• During one weekend, gambling ads on X (Twitter) reap an incredible 34 million views – putting social media marketing now at the heart of the industries marketing efforts.

However, my enthusiasm waned when the Gambling Act Review White Paper was unveiled in April 2023. Surprisingly, it lacked in actual interventions around (online) gambling marketing, and did not follow what most of our European neighbours have recently done. Whilst Belgium and Italy have recently almost entirely banned gambling marketing, Germany and Netherlands have intervened in several key areas – making Great Britain increasingly an outliner by allowing almost all forms of gambling marketing with minimal restrictions on online efforts.

Source: Rossi, R., Nairn, A., Ford, B., and Wheaton, J. (2023). Gambling Act review: how EU countries are tightening restrictions on ads and why the UK should too. The Conversation. UK.

The challenges of regulating online advertising

The core challenge lies in the fundamental differences between online and offline marketing, rendering our current regulatory framework, rooted in the offline world’s regulations from the 1960s, inadequate and unable to work efficiently.  Online marketing presents distinct features that require tailored regulations, and I’d like to highlight three crucial differences:

Firstly, the advent of “targeted ads” – enables incredible precise demographic targeting, surpassing traditional marketing capabilities. This enables brands, for example, to show ads only to males, age 18-25, that play football, and follow sports-related accounts online. This targeting far exceeds the possibilities of traditional marketing, and if not restricted, could enable gambling brands to focus their marketing communications on young and vulnerable audience – who, from a business point of view, is the most lucrative audience.

Secondly, the transient nature of online ads, such as “stories” or paid-for ads, poses a challenge to accountability.  Unlike TV commercials with a centralised database were ads are stored, there’s no mechanism to store and monitor online ads. Once they are gone (e.g. after 24h for stories, or after being deleted by the account) – they are gone!  So, how is this policed?  Currently, we are mainly relying on users to report potential breaches.  This means users need to act quickly when encountering a suspicious gambling ad, screenshot the ad, and finally, report it the Advertising Standards Authorities.  However, I don’t think many people do so.  But, what this means, is that the lack of policy in place to deal with this systemically, has created a “dark space” where advertising may go unchecked. In other words, I believe, that neither researchers, policy-makers nor enforcement officers at the ASA have a clue of what is actually happening out there, as we do not have the provisions to monitor it.

The final challenge stems from the unprecedented volume of online and social media advertising.  With 1 million unique UK gambling ads on Twitter alone, the sheer diversity of content makes policing and monitoring a daunting task. With AI coming into the mix – as Edoardo Tozzi has shown – this might make things even worse.  So far, gambling brands’ main costs in creating their 1m ads per year has been paying for their staff to design them.  Now, with AI being able to create ads within seconds, soon we might not see 1m ads per year, but 10-times or 100-times as much – there is virtually no limit.  And no policies in place that would protect us.

So, where are we going from here? 

Well, first of all, I believe we need to start accepting that online marketing is so fundamentally different, that our old laws and regulations don’t work. What should follow is the introduction of online specific marketing regulations.  However, I also believe that we need to start facing an uncomfortable truth: we need to start regulating the volume of (gambling) marketing, as opposed to solely focusing on the content.  Because even if the 100m AI-generated ads adhere to all regulations, do we really want to see our world plastered in gambling ads?

Reposted from the University of Bristol Business School blog

 

By Billy Greville, PhD Researcher at University of Bristol Business School

As I approached the M SHED museum, the impressive event space located in one of Bristol’s key cultural harbourside landmarks, I was reflecting on the colloquium’s theme this year: Building capacity in gambling harms research. As a 2nd year PhD researcher this seemed to not only capture the sentiment of my own journey over the past 12 months, but also the journey we are all on, as those who are pushing hardest to prevent and reduce gambling harms.

To build capacity sounded like a rallying cry; an opportunity to sharpen our conceptual and empirical tools, and hear directly from those with lived experience, campaigners, regulators and policymakers — all of whom are needed to effectively address the challenges emerging from a global gambling industry estimated to reach over $1 Trillion by 2030.

The whole is more than the sum of its parts…

Capacity building by silos would soon fail, however. So, the key premise of the colloquium was to bring together, both online and in person, a diverse mix of expertise from across the world — including governmental representatives, research experts and those with lived experience — to discuss ways of tackling gambling harms. The holistic approach provided what felt to me like a credible foundation on what is often the wide-reaching yet slippery grounds of gambling, requiring interdisciplinary knowledge and often transdisciplinary solutions.

The morning welcome speech by Co-chairs of the Hub, Sharon Collard and Agnes Nairn, echoed this, emphasising the importance of encouraging new kinds of people and perspectives to work with the Hub, as it continues its mission to raise awareness of gambling harms, strengthen consumer protection, and enhance support and treatment.

The day included a lively poster session, with over 20 researchers showcasing their work, and centred around four thought-provoking keynotes and panel speaker sessions, each anchored within one of the key research challenges of the Hub.

Session 1: Perceptions, Motivations, Decisions: What initiates gambling harms?

Lord Foster, long-time gambling reform campaigner and sitting House of Lords member, kicked things off with an impassioned keynote speech, pointing out that regulation needs continuous reform. He discussed some limitations of the White Paper, lacking proper restrictions on gambling products and marketing and advertising, especially sports betting. He also reiterated his belief that in a smartphone era gambling must now be treated as a public health issue.

Not surprisingly, advertising featured prominently in the panel session. University of Bristol’s Michael Banissy discussed how advertising and other cues in our environment play on specific networks in the brain, increasing the possibility of gambling harms.

Andy Taylor, from the Committee of Advertising Practice, offered insight into the restrictions they face as a downstream regulator, advising researchers wishing to collaborate to align projects within their regulatory scope.

Ghent University’s Steffi De Jans brought a fascinating case study to the session, talking about the implications on the recent ban of gambling advertising in Belgium. I wondered how much Belgium’s cultural morality played into this success, perhaps encouraging more political will as voters’ values may have aligned with a ban, and what this might mean in a UK context.

Another interesting topic that emerged was product design. Guy Bray from GamCare spoke about how advertising pulls young gamblers in, however it’s an app that traps them in a state of play. I thought about how this contrasts with advertising regulation. Addiction by design in a risky context such as gambling is highly problematic, yet, to me, seems to get less regulatory emphasis.

Session 2: Narratives, Practice, Representation: What is the everyday practice and portrayal of gambling in social groups?

During this session, the voices of those with lived experience of gambling harms came through strongly. Peter and Steph Shilton’s keynote speech demonstrated the secretive nature of gambling, and the extensive lengths people can go to hide it from their loved ones. Steph also highlighted the challenges loved ones face as “silent victims”, often overlooked for treatment and support.

This was echoed by BetKnowMore UK’s Liz Riley, who highlighted the issues women face as affected others, often carrying the extra burden of financial responsibility, feelings of Isolation and shame, or even coerced into keeping gambling secrets from other family and friends.

Wendy Knight, from GLEN, powerful reading of the poem, “I am Addiction”, authored by an anonymous writer, further brought me viscerally into the world of somebody suffering from gambling harms. I recommend anybody working in gambling harms research to read it also.

Another important theme of this session was the evolving nature of gambling, its craftiness in finding new gamblers through emerging contexts.

University of Bremen’s Tobias Hayer discussed the growth of sports betting in Germany; it’s portrayal by advertising as low-risk and harmless, just a new type of fan activity, helping create social norms linking gambling to supporting your team.

Sam Kirwan, from the University of Bristol, discussed how unregulated crypto assets are a new form of investing practice but moulded in the shape of gambling. What I found particularly interesting was how young people, often described as being worse off than previous generations, were lured into using cryptocurrencies as a hope device for longer term life goals such as buying a house. The similarity to gambling struck me, how in recessionary times gambling is often highest amongst people who face the most severe financial problems.

Session 3: Experience, Risk, Harm. What social and special inequalities exacerbate gambling harms?

Gambling harms can play out and affect groups of people and places differently. As the Guardian’s Rob Davies discussed in his keynote, the clustering of betting shops in less affluent areas target communities and embed gambling harms. This session also pointedly demonstrated the need to consider other marginalised or overlooked groups.

Bournemouth University’s Reece Bush-Evans talked about how marginalised groups such as the LGBTQIA+ community can suffer more or in unexpected ways from gambling harms. Bristol University’s Jo Large also discussed the hidden harms of betting shop employees; how they felt unqualified to handle the levels of problematic behaviour they witnessed daily and felt a burden was placed on them to enforce regulatory rules.

All different examples yet display brilliantly how we must continue to understand the full ecology of gambling harms.

Linking to this, Lee Kah Wee, from the National University of Singapore, brought another unique perspective to the session. He talked about how casinos in Singapore use public transport infrastructure as a form of advertising, targeting customers with a private bus service, bringing the casino to the doors of locals and high-net-worth tourists. Ultimately, they act like mobile advertising, providing a brand experience of luxury. He finished his talk by posing a question: Are casinos exporting harms beyond their buildings?

This occupied my thoughts during the afternoon coffee break. If we consider gambling as a public health issue, as Public Health England suggests, could we create a powerful narrative by framing all PR, sponsorship, marketing or advertising as examples of operators exporting gambling harms beyond their sites?

Session 4: Innovations, Transition, Change: What socio-technical innovations can help combat gambling harms?

The gambling industry is highly innovative, driving profits by leveraging data and new technology while employing the best talent. This informative session showcased how we must continually seek out our own innovations, to both understand and effectively make use of emerging technology and big data to combat gambling harms. The speakers all provided compelling ideas on this call to action.

In her keynote speech, Carolyn Harris, Labour MP for Swansea East, stated that gambling is now firmly on the political agenda. She spoke about how machines are dictating our lives more than ever, and how the impacts of the first iPhone and the gambling act, both from 2007, has transformed gambling into what it is today.

Jamie Wheaton, from University of Bristol, provided an excellent overview of the status of socio-technical innovations in the gambling industry today. Chris May, from Mayden Health tech, discussed how a data-driven approach can be used to help with prevention and treatment, offering bespoke services for gamblers. From the Behavioural Insights Team, Ruth Persian spoke about their Activity Statement research in Australia and how having personal statistics on gambling usage made a big difference to people, empowering more informed financial decisions. I found Clean Up Gambling’s Matt Zarb-Cousin’s idea of gamifying recovery particularly interesting. His notion of using technology to maximise recovery, not profit, seemed like a perfect mantra for this session, inverting the traditional tech model.

The end yet just the beginning

This year’s inaugural colloquium created a rich and lively environment facilitating a cross-pollination of ideas amongst a fantastic intersection of people, all passionate about reforming the gambling industry. I walked away knowing much more about the broad challenges faced yet, perhaps more importantly, inspired by the growing body of expertise on display and a steadfastness to continue working hard on my own research. I look forward to carrying on the conversations at next year’s event.

 

Prof. Agnes Nairn, Co-Director of the Bristol Hub for Gambling Harms Research, and Dr. Raffaello Rossi, Hub Communications Lead, feature in this impact story for the University of Bristol Business School about their research into protecting children from the harmful effects of gambling advertising on social media.  The full story can be read below, or by following this link.

Gambling problems in children
If you’ve never heard of skin gambling, loot boxes or matched betting, try asking the nearest teenager. In fact, these are all ways in which children and young people can be lured into online gambling.

The number of UK children with gambling problems has quadrupled to more than 50,000 in just four years. With the opening of child gambling clinics to tackle rising rates of problem gambling, the NHS and government have recognised this serious and growing issue. Indeed, the manifestos of all main political parties at the last general election pledged to tackle gambling regulation as a priority. There are strict regulations regarding advertising for online gambling, but for a few reasons, these are not always being followed when it comes to social media platforms.

The role of advertising
Focusing on the role advertising plays in these developments, research by Professor Agnes Nairn and Dr Raffaello Rossi investigated the effects of social media gambling ads on children and young people. Their first research project with Ipsos MORI and Demos focused on gambling ads on Twitter.

Using big data analytics of over 880,000 UK gambling ads, along with data of 1,000,000 users, they found that:

• 41,000 UK children follow Twitter gambling accounts
• two-thirds of engagements with these ads were made by under 24-year-olds
• the big UK gambling brands post around 29,000 ads per year

71% of gambling ads failed to fully comply with regulations set by the Advertising Standards Authority (ASA).

Esports, a form of competitive video gaming, that predominantly attracts amateur and professional players in their early 20s or younger, was of particular concern. The research offered novel insights into esports gambling adverts, highlighting the stark difference between these and traditional gambling (such as football betting) and their strong appeal for children.

This research was published in Biddable Youth, a major report by the University of Bristol Business School and the Centre for the Analysis of Social Media at Demos. The report formed part of a much larger research project funded by GambleAware, aiming ‘to assess the extent, nature and impact of gambling advertising on children, young people and vulnerable groups in the UK.’ Some of the results were also published in an academic paper in the top peer-reviewed Journal of Public Policy and Marketing.

The initial study aimed to understand the ecosystem of gambling ads on Twitter, this presented some serious concerns surrounding the potential effect the ads on children. As a result, Nairn and Rossi moved on to a second study, to examine whether children and young people find gambling advertising more appealing than adults.  Conducting an online experiment withover 650 participants aged 11-78, the research found that gambling advertising on Twitter is strongly and significantly more appealing to children and young people than to adults. Esports ads and ads using content marketing (a form of stealth advertising that is harder to recognise) were found to be especially appealing, triggering happiness, excitement and delight in under 25-year-olds.

A lack of awareness
Agnes Nairn, Professor of Marketing at the University of Bristol Business School, says that the lack of awareness about this trend is a real problem: ‘Parents don’t have a clue about esports at all. And if they do, they don’t know about the gambling that goes alongside it. So, they’re not likely to be talking to their kids about it, in the way they might talk about online poker or regular sports gambling.’

 As with many other technology sectors, esports is developing faster than its regulators can move to control it. There are rules that should prevent esports betting advertisers from targeting children and young people such as disallowing the use of images of under-25s in gambling adverts. However, Professor Nairn found they were being flouted time and again: ‘Most of the superstars in esports are under 25. When you show a picture of them in a betting promotion, you are already breaking regulations.’

 A further concern was that, of the 888,000 tweets sent by betting-related accounts that were examined using computer-aided analysis, only 7.3% were found to contain any warning about the minimum age for gambling, responsible gambling, or terms and conditions in the text. For esports accounts, this number fell to just 0.1%, displaying the very worst in advertising practices.

 There is also an issue with the time of day these tweets are posted, Professor Nairn explains: ‘There are huge esports communities in China, South Korea or the USA, meaning that although this may not be a strategy, children are seeing esports bookmakers’ tweets posted in the middle of the night here in the UK.’

 Manual content analysis by the researchers found that 17% of esports tweets encourage betting late at night or in the small hours. Separate research has shown that esports marketing late at night is more likely to effect vulnerable users and make them spend more.

Strong appeal to children
Dr Raffaello Rossi said: “The overwhelming strong appeal of gambling advertising on social media to children is of huge concern, as the earlier people start gambling the more likely it will become habitual and problematic.

 “That’s why there needs to be much stricter and clearer rules in place to clamp down on the issue, which could easily spiral out of control given how long children and young people spend on social media these days. Many of the adverts may look entirely innocent and harmless, but they in fact pose a serious risk of getting a whole new generation of gamblers hooked on a serious addiction which has devastating consequences.”

Recommendations
The research contains several recommendations, aimed at industry and advertisers, technology companies, and regulators. These include:

• Making existing age verification tools available to all advertisers.
• Integrating more explicit references to age restrictions and safe gambling in advertising content.
• Ensuring existing regulations and best practices in regard to licenced betting are followed.
• Considering the potential value of education initiatives for parents and young people.
• Esports gambling advertising, which automatically appeals to children and young people, should be banned.
• Gambling content marketing, which masquerades as something appealing, to be rigorously regulated and informed by what is proven to attract young people.
• Regulators to broaden the age range of a ‘young person’ from 16-17 to 16-24-year-olds.
• Social media platforms to only allow gambling ads on social media when users actively opt-in to receive them.

Professor Nairn is pleased with the response so far. ‘We’ve had really good dialogues with the Advertising Standards Authority,’ she says. As a result, they have changed the regulation that stipulates that gambling adverts should not be “of particular appeal” to children (i.e. more appealing to children than adults) to “of strong appeal”.  This is a breakthrough because under the previous regulation, an advert could be extremely appealing to children (for example something related to premier league football) yet not prohibited just because if was equally appealing to adults.’  Beyond this, Dr Rossi said: ‘It is great to see that the advertising regulator is taking our work seriously – they have now included content marketing in their remit – a big breakthrough.’

Impact
Beyond receiving substantial national and international media coverage, the researchers were invited to give evidence to the Department for Digital, Culture, Media & Sport (DCMS), the National Digital Ethics Expert Group by the Scottish Government, and the House of Lords’ Peers for Gambling Reform.  The research was extensively debated in the House of Lords, repeatedly mentioned in House of Commons, and cited in the DCMS Gambling Act Review White Paper.

The research led to three direct changes in current advertising regulations:  First, a public consultation into the appeal regulations that should protect children from harm via gambling ads was announced by the ASA in response to the research findings. The consultation led to updated and clearer regulations to improve the protection of children.

Second, an advice notice clarifying the regulations for esports betting advertising has been published by the advertising regulators.

Finally, the ASA has addressed a loophole raised by Nairn and Rossi; namely, that content marketing (a form of advertising very appealing to children) was not in their remit. Following the research, the ASA announced a change in position, such that all content marketing is now in remit – not just for gambling, but for other products and services too, creating an important change in how social media ads are regulated.

In addition to Bristol offering advice to UK organisations such as the ASA, international interest in the report has resulted in invitations to speak to European and Asian audiences. ‘There are very different views about gambling in different countries,’ says Professor Nairn. ‘This makes it a very rich area to consider internationally: there’s a lot of mileage in it yet.’