ICO Approves Data-Sharing Scheme for UK Gambling Sector

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Carla Murray - Partner


For the period between April 2022 and March 2023, it was estimated that over £3 billion was spent on gambling, demonstrating the sheer size of the industry within the UK and also highlighting the potential problems with irresponsible gambling practices.

Stephen Almond, the executive director of regulatory risk at the Information Commissioner’s Office (ICO), stated:

“problem gambling has devastating consequences for people’s finances, relationships and health. We are keen to see the financial sector share data to protect people from unaffordable losses and spiralling debt”

To combat this, the ICO recently approved proposals for the sharing of financial data with gambling operators for the purpose of carrying out financial risk checks, with the ultimate aim of protecting gamblers from unaffordable losses.

However, the transfer and sharing of personal financial data needed to be considered to establish whether transferring and sharing data for such purposes would be compliant with current UK data protection law. 

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ICO approves data sharing scheme for UK gambling sector

ICO endorsement of financial risk checks and data sharing

In a letter to UK Finance (the industry body for financial services within the UK), the ICO confirmed that:

  • UK data protection law does not prevent gambling operators from conducting financial risk checks on customers; and 
  • lenders can share people’s personal information; however, this must be done transparently and proportionately.

Under the proposed safeguards developed by the ICO and the Gambling Commission, gambling operators:

  • Will only be permitted to use personal information they receive solely for the purpose of carrying out the financial risk check; and 
  • Must notify their customers that checks may be made on their financial health in the event that they incur a significant loss. 

The ICO also confirmed that it supports plans for gambling companies to share information about customers identified as ‘high risk’ who are gambling across multiple sites.

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ICO endorsement of financial risk checks and data sharing

How will the data-sharing scheme affect your business?

The data-sharing scheme will likely affect all those operating within the UK gambling sector, particularly gambling operators, credit reference agencies and banks and lenders.

In its letter to UK Finance, the ICO has stated that it expects:

  • Gambling operators to implement or update any processes to ensure the data received from credit reference agencies is analysed accurately, held securely and not used for any additional (incompatible) purpose; 
  • Credit reference agencies to conduct data processing impact assessments (DPIAs) before processing personal information for financial risk checks; and 
  • Banks and lenders to update their privacy notices (and other relevant information) to reflect the increased scope of data sharing by the credit reference agencies. 

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How will the data sharing scheme affect your business

How we can help

The Commercial Team at Myerson can help to protect your business by assisting with the following:

  • drafting data-sharing agreements;
  • carrying out DPIAs; and 
  • updating your privacy notices to ensure that they cater for such data sharing. 

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Contact Our Commercial Team

If you have any questions or would like more information regarding the data-sharing scheme, please contact our Commercial Solicitors, who would be happy to assist.


Carla Murray's profile picture

Carla Murray


Carla has over 18 years of experience acting as a Commercial solicitor. Carla is the Head of Myerson’s Technology Sector. She has handled various matters relating to commercial agreements, technology contracts, and data protection.

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