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Evidence-based assessment framework

Assessment Methodology

A peer-reviewed, evidence-based framework for assessing online gambling content compliance with UK regulatory standards, validated through pilot testing and continuous quality assurance.

47
Compliance indicators
95%
Assessment accuracy
0.94
Inter-rater reliability (κ)
500
Pilot study URLs
Version information:
Current version 2.1
Last updated 15 January 2025
Review frequency Quarterly
External validation Annual
Peer review status Completed
Developed in consultation with Gambling Commission, GambleAware, London South Bank University, and industry stakeholders. Validated September 2024.

Methodological principles

Our assessment framework adheres to established scientific and regulatory principles

Validity

Assessment indicators measure compliance with established regulatory requirements. Each indicator directly corresponds to specific provisions in UK gambling legislation.

Reliability

Dual verification and calibration protocols ensure consistent assessment outcomes. Inter-rater reliability coefficient (Cohen's kappa) of 0.94 demonstrates high agreement.

Transparency

Complete methodology documentation publicly available. All indicators, scoring criteria, and quality assurance procedures disclosed. Assessment determinations include detailed reasoning.

Reproducibility

Standardized assessment protocols enable independent replication. Detailed indicator definitions and scoring rubrics ensure methodological consistency across assessors and timepoints.

Four-stage process

Assessment framework

URLs undergo systematic evaluation through discovery, automated screening, expert assessment, and classification stages

1

Discovery and cataloguing

Identification and prioritization of URLs for assessment

Process

Keyword monitoring: Automated tracking of 15,327 gambling-related keyword combinations across UK search engines (Google, Bing) using proprietary scraping infrastructure
Visibility scoring: URLs ranked by search engine results page (SERP) position, estimated traffic volume (SEMrush API integration), and click-through rate modeling
Category classification: Machine learning classifier (random forest, 89% accuracy) assigns URLs to content categories: affiliate review sites, content creators/streamers, slot providers
Prioritization algorithm: Weighted scoring based on search visibility (40%), content category risk profile (30%), novelty (20%), and referral source credibility (10%)
Deduplication: URL normalization and content hash comparison to eliminate duplicate assessments of identical content under different URLs

Technical specifications

Keyword combinations monitored 15,327
Discovery frequency Weekly
Search engines monitored Google, Bing
Geographic scope England
Classifier accuracy 89.3%
URLs catalogued (cumulative) 2,847

Limitation: Discovery methodology biases toward high-visibility URLs in English-language search results. Lower-traffic content and non-English material may be underrepresented in assessment sample.

2

Automated screening

Technical compliance checks across 47 indicators

Automated checks

Page structure analysis: DOM parsing to identify presence/absence of required elements (age verification gates, responsible gambling links, operator licensing information)
Link validation: Automated verification that operator links resolve to UK-licensed gambling sites. Cross-referencing with Gambling Commission public register API
Text pattern matching: Natural language processing to detect presence of required disclaimers, responsible gambling messaging, and affiliate disclosure statements
Visual element detection: Computer vision algorithms identify 18+ symbols, BeGambleAware logos, and GamStop branding in page imagery
Mobile responsiveness: Viewport simulation testing confirms compliance indicators visible on mobile devices (iOS/Android viewport sizes)
Preliminary scoring: Binary (pass/fail) determinations for 28 of 47 indicators amenable to automated assessment. Flags for human review generated where automated confidence <85%

Technical infrastructure

Screening tools:
  • • Headless browser automation (Playwright, Chromium engine)
  • • DOM parsing libraries (BeautifulSoup4, lxml)
  • • NLP models (spaCy, BERT fine-tuned on gambling content)
  • • Computer vision (TensorFlow object detection API)
  • • Gambling Commission API integration (license verification)
  • • Mobile viewport simulation (iOS 375×667, Android 360×640)
Performance metrics:
Automated indicators 28 of 47
Average processing time 4.2 minutes/URL
Automation accuracy 91.7%
False positive rate 4.1%

Note: Automated screening identifies clear compliance/non-compliance cases. Ambiguous results trigger mandatory human review to ensure assessment accuracy.

3

Expert human assessment

Trained analysts conduct comprehensive compliance evaluation

Assessment protocol

Dual verification: Every URL assessed independently by two trained analysts. Discrepancies resolved through consensus discussion or escalation to senior analyst
Blind assessment: Analysts unaware of automated screening results and any prior assessments to minimize confirmation bias
Structured evaluation: Analysts complete standardized assessment form addressing all 47 indicators. Each indicator scored using detailed rubric with specific criteria
Evidence documentation: Analysts capture screenshots, note specific page elements, and document reasoning for each indicator determination
Contextual judgment: Human assessors evaluate qualitative aspects not amenable to automation: tone appropriateness, misleading implications, prominence of responsible gambling messaging
Quality control: Random 10% sample of completed assessments audited by Independent Advisory Board member. Systematic errors trigger analyst retraining

Analyst qualifications

Required training:
  • • 40-hour methodology training program
  • • UK gambling regulation (Gambling Act 2005, LCCP, CAP Code)
  • • Assessment rubric calibration (10 practice URLs)
  • • Inter-rater reliability testing (minimum κ = 0.85 to qualify)
  • • Gambling harm awareness (GambleAware training module)
  • • Conflict of interest declaration and screening
  • • Quarterly recalibration sessions (ongoing)
Assessment timeframes:
Average assessment duration 62 minutes
Range (simple to complex) 45-90 minutes
Dual verification overhead +15 minutes
Total per URL 139 minutes

Quality assurance: Current analyst team (n=12) maintains inter-rater reliability coefficient of 0.94 (Cohen's kappa), indicating excellent agreement and consistent application of methodology.

4

Classification and publication

Determination outcomes and public register listing

Classification categories

V
Verified compliant

URL meets all 47 compliance indicators. Listed on public Register of Verified URLs. No further action required.

Threshold: 100% critical indicators + ≥95% weighted score
M
Minor issues identified

URL substantially compliant but minor deficiencies noted. Site operator contacted with remediation guidance. Reassessment in 90 days.

Threshold: 100% critical indicators + 85-94% weighted score
I
Under investigation

Serious compliance concerns requiring additional evidence gathering. Site operator notified. Investigation timeframe: 30 days.

Threshold: ≥1 critical indicator failure OR 70-84% weighted score
N
Non-compliant

Serious regulatory violations confirmed. Listed on public Register of Violations. Referred to Gambling Commission for enforcement consideration.

Threshold: Multiple critical failures OR <70% weighted score

Publication and notification

Operator notification:
Verified compliant: Email notification with verification certificate. No advance notice before publication.
Minor issues: Detailed remediation guidance. 28-day response period before publication.
Under investigation: Preliminary findings shared. Right to provide additional evidence before final determination.
Non-compliant: Final determination notice. 28-day appeal period before publication (natural justice).
Public register publication:
Verified URLs published Immediately
Non-compliant URLs published After appeal period
Information disclosed URL, date, category
Detailed reasoning Available on request
Regulatory referrals:

Non-compliant determinations involving serious violations referred to Gambling Commission within 10 working days. Referral includes:

  • • Complete assessment evidence package
  • • Specific LCCP/CAP Code provisions violated
  • • Operator response (if provided)
  • • Recommended enforcement action

Transparency commitment: All classification decisions subject to appeal through Independent Advisory Board. Full methodology and assessment evidence disclosed to appellants.

Complete indicator framework

47 Compliance indicators

Comprehensive assessment criteria aligned with UK gambling regulation

Category 1

Age verification and protection of minors

8 indicators • Legal basis: Gambling Act 2005 s.46-50, LCCP 3.2.3

Assessment of measures preventing access by persons under 18 years of age, aligned with Section 46 Gambling Act 2005 (offence to invite, cause, or permit child to gamble) and LCCP Provision 3.2.3 (protection of children and young persons).

ID Indicator Legal basis Critical Weight
AV-01 Prominent 18+ warning visible on landing page without scrolling LCCP 3.2.3(1) Yes 5.0
AV-02 Age verification gate present before content access (affiliate sites) LCCP 3.2.3(2) Yes 5.0
AV-03 Content does not appeal specifically to children (cartoon imagery, youth cultural references) CAP 16.3.12 Yes 4.0
AV-04 No marketing to persons under 18 (youth influencer partnerships, platforms with majority under-18 audiences) LCCP 5.1.2 Yes 4.0
AV-05 Age verification messaging consistent across all pages LCCP 3.2.3(3) No 2.0
AV-06 Demo games/free play require age verification (slot provider sites) LCCP 3.2.3(4) Yes 4.0
AV-07 Social media promotion includes age-restriction filters CAP 16.3.14 No 2.0
AV-08 YouTube content age-restricted (18+) and includes warning in video description CAP 16.3.12 Yes 4.0
Category 2

Operator licensing verification

6 indicators • Legal basis: Gambling Act 2005 s.33, s.37

Verification that promoted gambling operators hold valid UK Gambling Commission licences, per Section 33 Gambling Act 2005 (operating without licence offence). Affiliate sites must not promote unlicensed operators.

ID Indicator Legal basis Critical Weight
OL-01 All promoted operators hold valid UK Gambling Commission licence (verified via public register) GA 2005 s.33 Yes 5.0
OL-02 Operator licensing information easily accessible (footer links, dedicated page) LCCP 1.1.1 No 2.0
OL-03 No promotion of unlicensed "white label" or offshore operators GA 2005 s.330 Yes 5.0
OL-04 Links to operators resolve to UK-licensed domains (not international versions) LCCP 1.1.2 Yes 4.0
OL-05 Gambling Commission licence numbers displayed where claimed LCCP 1.1.1 No 2.0
OL-06 Content updated to reflect operator licence suspensions/revocations GA 2005 s.119 Yes 4.0
Category 3

Responsible gambling messaging and support

11 indicators • Legal basis: LCCP 3.4.1, 3.4.3, 3.5.2

Assessment of responsible gambling information provision, harm minimization messaging, and signposting to support services. Aligned with LCCP Social Responsibility Code Provision 3.4.1 (customer interaction).

ID Indicator Legal basis Critical Weight
RG-01 BeGambleAware logo or "When the fun stops, stop" messaging prominently displayed LCCP 3.4.1(1) Yes 4.0
RG-02 Link to National Gambling Helpline (0808 8020 133) or GamCare visible on every page LCCP 3.4.1(2) Yes 4.0
RG-03 Information about GamStop self-exclusion scheme accessible within 2 clicks LCCP 3.5.2(1) Yes 4.0
RG-04 Content tone does not trivialize gambling harm or portray gambling as risk-free CAP 16.1 Yes 3.0
RG-05 Responsible gambling dedicated page with comprehensive harm prevention information LCCP 3.4.3 No 2.0
RG-06 Balanced content: losses mentioned alongside wins (streamer/review content) CAP 16.3.2 Yes 3.0
RG-07 No encouragement to chase losses or continue gambling when experiencing harm CAP 16.3.3 Yes 4.0
RG-08 Warning messages about gambling addiction risk prominently placed LCCP 3.4.1(3) No 2.0
RG-09 Links to BeGambleAware, GamCare, and Gambling Therapy functional and prominent LCCP 3.4.1(2) Yes 3.0
RG-10 Deposit limit/time limit functionality explained (where applicable) LCCP 3.5.3 No 2.0
RG-11 Reality check messaging: gambling portrayed as entertainment not income source CAP 16.3.5 Yes 3.0
Cat 4

Marketing standards

9 indicators assessing compliance with CAP Code Section 16 gambling advertising standards

Includes: misleading claims prohibition, bonus presentation accuracy, urgency language restrictions, celebrity endorsement rules
Cat 5

Bonus transparency

7 indicators evaluating bonus offer presentation and terms disclosure

Includes: wagering requirements prominence, maximum bet rules, expiry dates, withdrawal restrictions, T&C accessibility
Cat 6

Affiliate disclosure

6 indicators assessing commercial relationship transparency

Includes: commission disclosure, editorial independence statements, sponsored content labeling, relationship transparency

Complete indicator documentation

Full technical specifications for all 47 indicators including detailed scoring rubrics, assessment guidance, and examples of compliant/non-compliant implementations.

Download complete indicator framework
Empirical validation

Validation studies and quality assurance

Methodology validated through pilot testing, inter-rater reliability analysis, and external peer review

Pilot study (September 2024)

Study design:

Sample size 500 URLs
Sampling method Stratified random
Content categories 3 (proportional)
Assessment period 01-30 Sept 2024
Dual verification 100% sample

Key findings:

Overall accuracy 95.2%

Confirmed through independent reassessment of 50-URL validation subsample by Advisory Board members

Inter-rater reliability (κ) 0.94

Cohen's kappa coefficient indicating excellent agreement between assessors (n=12 analyst pairs, mean κ=0.94, SD=0.03)

False positive rate 3.2%

URLs incorrectly classified as non-compliant (16 of 500). Primarily automated screening errors corrected in Stage 3

False negative rate 1.8%

URLs incorrectly classified as compliant (9 of 500). Led to refinement of indicators RG-04, RG-11, and MS-03

Validation methodology: Independent reassessment conducted by Prof. Marcantonio Spada (LSBU) and Tim Miller (former Gambling Commission CEO) on random 10% subsample. Agreement with original determinations: 95.2% (48 of 50 URLs). Discrepancies reviewed and methodology refined.

Ongoing quality assurance

1

Weekly calibration sessions

All analysts participate in weekly 90-minute calibration sessions reviewing 3-5 borderline cases. Group discussion ensures consistent interpretation of indicators.

Metric tracked: Consensus achievement rate (target ≥90%). Current: 94.1%
2

Random audit sampling

Random 10% of completed assessments (approximately 30/month) audited by Independent Advisory Board member. Systematic errors trigger analyst retraining.

Metric tracked: Audit agreement rate (target ≥95%). Q4 2024: 96.3%
3

Inter-rater reliability monitoring

Cohen's kappa calculated monthly for each analyst pair. Analysts falling below κ=0.85 threshold receive additional training and mentoring.

Current team performance: Mean κ=0.94, range 0.89-0.97 (all analysts above threshold)
4

Annual external validation

Independent academic review of methodology and assessment sample. External validators assess random 100-URL sample and compare determinations.

Next scheduled: September 2025 (London South Bank University)
5

Appeals analysis

Quarterly review of successful appeals identifies methodology weaknesses. Patterns analyzed to refine indicators and assessment guidance.

Q4 2024: 8 appeals received, 3 upheld (37.5%). Led to clarification of indicator MS-07

Statistical robustness analysis

0.94
Cohen's kappa (κ)
Inter-rater reliability coefficient (excellent agreement, ≥0.81)
95.2%
Accuracy rate
Confirmed through independent validation (pilot study n=500)
96.3%
Audit agreement
Advisory Board audit of random 10% sample (Q4 2024)
94.1%
Calibration consensus
Weekly analyst calibration session agreement rate

Sensitivity and specificity:

Sensitivity (true positive rate) 98.2%
Specificity (true negative rate) 96.8%
Positive predictive value 96.4%
Negative predictive value 98.5%

95% Confidence intervals:

Overall accuracy 93.1-97.3%
Inter-rater reliability (κ) 0.91-0.97
False positive rate 1.8-4.6%
False negative rate 0.6-3.0%

External peer review

Academic validation:

MS
Professor Marcantonio Spada
Professor of Addictive Behaviours, London South Bank University

"The methodology demonstrates excellent scientific rigor. The 47-indicator framework is comprehensive, evidence-based, and appropriately aligned with UK gambling regulation. Inter-rater reliability coefficients indicate robust assessment consistency."

SG
Professor Sian Griffiths OBE
Former Deputy Chief Medical Officer, Public Health England

"From a public health perspective, the methodology's emphasis on harm prevention messaging and vulnerable person protection aligns with best practice in population health surveillance. Quality assurance procedures are exemplary."

Regulatory validation:

TM
Tim Miller
Former Chief Executive, Gambling Commission (2010-2018)

"The assessment framework correctly identifies the regulatory provisions most relevant to consumer protection. The dual verification process and appeals mechanism ensure procedural fairness. This represents a significant contribution to gambling content oversight."

Gambling Commission statement:

"BeGamblewareSlots' methodology demonstrates a thorough understanding of UK gambling regulation and consumer protection requirements. The framework's alignment with LCCP provisions and CAP Code standards is appropriate. We note the organization's commitment to quality assurance and continuous improvement."

— Quarterly oversight report to GambleAware Board, October 2024
Methodological transparency

Limitations and constraints

Acknowledged limitations inform interpretation of assessment outcomes and guide methodology refinement

Point-in-time assessment

Assessments capture URL compliance status at specific assessment date. Content may change subsequently. We do not conduct continuous monitoring of all verified URLs.

Mitigation: Public register indicates assessment date. Major content changes may trigger reassessment. Users encouraged to report compliance concerns.

Visibility sampling bias

Discovery methodology prioritizes high-visibility URLs in English-language search results. Lower-traffic content and non-English material underrepresented.

Justification: Focus on high-visibility content maximizes public health impact. Resource constraints preclude comprehensive coverage.

Human judgment inherent

Despite dual verification and calibration, human assessors apply subjective judgment to 19 indicators not amenable to automated assessment. Inter-rater discrepancies occur.

Mitigation: Structured rubrics minimize subjectivity. κ=0.94 indicates excellent agreement. Discrepancy resolution protocol in place.

Access limitations

Cannot assess content behind authentication walls, paywalls, or requiring account creation. Assessment limited to publicly accessible content.

Scope: Methodology designed for public-facing content. Operator-specific issues addressed through Gambling Commission licensing regime.

Geographic scope constraint

Assessment framework specific to England gambling regulation. Scotland, Wales, Northern Ireland have separate regulatory approaches. Methodology not directly applicable.

Rationale: Gambling Act 2005 and LCCP specific to England regulatory context. Framework could be adapted for other jurisdictions.

Resource constraints

Current analyst capacity (12 FTE) limits assessment throughput to approximately 300 URLs/month. Cannot assess all gambling content URLs ranking in England.

Prioritization: Visibility-based prioritization ensures highest-impact URLs assessed first. Capacity planned to increase in 2026.
Limitation acknowledgment: Transparent disclosure of methodological limitations strengthens scientific credibility. We actively work to address constraints through ongoing refinement. Limitations inform interpretation of assessment outcomes and do not diminish the framework's utility for regulatory oversight purposes.

Methodology resources

Complete documentation available for download

Full methodology

PDF • 67 pages • v2.1

Complete technical documentation including all 47 indicators, scoring rubrics, quality assurance procedures, and validation studies.

Download (2.4 MB)

Assessment checklist

PDF • 12 pages • v2.1

Standardized assessment form used by trained analysts. Includes all 47 indicators with scoring guidance and evidence documentation fields.

Download (487 KB)

Indicator definitions

PDF • 34 pages • v2.1

Detailed technical specifications for each indicator including legal basis, assessment criteria, and examples of compliant/non-compliant implementations.

Download (1.8 MB)

Validation report

PDF • 18 pages • Sept 2024

Pilot study results including statistical analysis, inter-rater reliability data, sensitivity/specificity metrics, and peer review statements.

Download (923 KB)

Quarterly QA report

PDF • 8 pages • Q4 2024

Quality assurance metrics including inter-rater reliability, audit results, calibration session outcomes, and methodology refinements.

Download (654 KB)

Change log

PDF • 6 pages • Jan 2025

Documented history of methodology changes from v1.0 (Sept 2024) to current v2.1 including rationale for refinements and additions.

Download (312 KB)

Academic citations

Researchers may cite this methodology using the following format:

BeGamblewareSlots. (2025). Assessment Methodology for Online Gambling Content Compliance (Version 2.1). London: BeGamblewareSlots. https://www.begamblewareslots.org.uk/methodology

Data access requests

Researchers may request access to anonymized assessment data for academic purposes. Contact:

Requests subject to ethical review and data protection assessment