Studies that look at gambling in Germany are anything but easy these days: the Gambling Survey in particular was heavily criticised at the end of last year and again at the beginning of 2024 due to possible methodological errors. Now the survey and those responsible for it are once again being criticised - and the gambling atlas is also being criticised. The Bremen FDP doubts that the surveys fulfil their actual claim to independence, as money from the gambling industry has apparently been used.

The Gambling Survey and the Gambling Atlas are two of the most important tools for gathering information on the German gambling landscape. The main aim of the survey is to obtain epidemiological findings on gambling participation and problems in the population and thus improve the corresponding deficits. The atlas sees itself more as a reference work that is intended to provide significant support in understanding the business, comprehending its changes as well as the difficulties and relevance involved and driving the industry forward as a whole. However, epidemiological data is also fundamental here. Both surveys are based on interviews with specific groups of people and are published regularly with updated data in order to make the development of the situation comprehensible.

The usefulness of the gambling survey in particular has been questioned several times in the recent past. The renowned statistician Katharina Schüller criticised the fact that the survey for 2021 had considerable weaknesses in terms of control, methodology and results. She went so far as to deny the survey's suitability as a scientific basis for a political discussion on problem gambling.

The 2023 edition also faced some headwinds. This time, it was the German Vending Machine Industry (DAW) and the German Sports Betting Association (DSWV) who criticised the fact that the apparently unsound methodology was retained. They continue to expect "the publication of the raw data, as transparency in data collection and analysis is of crucial importance for the scientific discourse".

The Bremen FDP is now entering the discourse with a further point. It recently submitted a minor question to the Senate with the subject "Evaluation of the State Treaty on Gambling" (error taken from the FDP's letter), which casts doubt on the independence of both the Gambling Survey and the Gambling Atlas. The FDP essentially refers to the designation of the initiators as "independent scientists" in an earlier correspondence, although financial support from the gambling industry had taken place. In addition, a number of questions raise further points of criticism in this context, some of which have already been criticised in the past.

Are the Gambling Survey and the Gambling Atlas really independent surveys?

The Gambling Atlas and the Gambling Survey are both organised by the University of Bremen. The Gambling Research Unit, headed by Dr Tobias Hayer, is primarily responsible. The Hamburg Institute for Interdisciplinary Addiction and Drug Research (ISD) is also involved.

In its letter, the FDP firstly addresses the broad criticism of the methodology and the handling of the survey data. The figures in the gambling atlas are also said to have been incorrect. These points are addressed in more detail in the questions submitted to the Senate on the subject. These are largely in line with the criticisms of the past and/or continue them.

What is new is the questioning of the person responsible, Dr Hayer, as "provider-independent" and part of "provider-independent addiction research". He was apparently referred to in this way several times in earlier correspondence ("Drucksache 21/290"). This was despite the fact that he was known to have received funding from the Legal Committee of the German Lotto and Totoblock, "which overlapped in time with Dr Hayer's membership of the Advisory Board and which was also correctly declared as a possible conflict of interest on the part of the Gambling Advisory Board". In the same context, the authors Prof. Dr Gerhard Meyer and Dr Jens Kalke and their independence are also criticised.

The FDP's minor question to the Senate contains even more than concrete criticism of the independence of the surveys

Based on the introduction to its letter, the FDP poses specific questions to the Senate to emphasise its point of view. Overall, it calls for a more transparent view of gambling research and its methodology.

The most interesting lines are summarised here:

  • "In the opinion of the Senate, are scientists whose research is funded by the state market participant Lotto 'provider-independent' or 'industry-independent'? Please give reasons."
  • "Is the Senate aware that Dr Tobias Hayer considers a 'gambling monopoly' to be desirable? If so, does the Senate share this objective?"
  • How does the Senate assess the fact that the raw data and questionnaires used in the 2021 Gambling Survey were not published, contrary to the 'Standards of Good Scientific Practice' of the German Research Foundation and the practice of the Federal Centre for Health Education (BZgA), which was previously entrusted with the survey?"
  • "Is the Senate working with the authors of the 2021 Gambling Survey to ensure that the raw data and questionnaires used are published together with the results report to enable an evidence-based debate on gambling regulation, as was the case with the BZgA's predecessor studies? If not, why not?"
  • "Does the Senate believe that the results of the Gambling Survey 2023 can be compared with the results of the Gambling Survey 2021 as long as the data and questionnaires from the Gambling Survey 2021 continue to be kept under lock and key? If so, how does the Senate justify this?"
  • "In view of the financial support for the gambling survey provided by the German Lotto and Totoblock, does the Senate believe that the central study on gambling and gambling addiction prevalence should in future be commissioned by a body that is not itself a participant in the German gambling market (e.g. the Joint Gambling Authority of the federal states)? If not, why not? If yes, are corresponding initiatives planned and is there already a time frame for implementation?"
  • "How does the Senate assess the fact that, according to the annual report of the German Addiction Help Statistics (DSHS), only 11,686 clients with gambling problems took advantage of outpatient addiction help measures nationwide in 2022 and a further almost 400 people took advantage of inpatient addiction help measures, i.e. only around 0.9% of the 1.3 million pathological gamblers in treatment according to the Gambling Atlas?"

Conclusion

A minor interpellation is exactly what the term says: it is about an executive, in this case the Bremen Senate, answering one or a few questions from politicians or parties. Normally, no extensive research is carried out to answer the question and no discussion in parliament is planned. The FDP's criticism is therefore unlikely to have any directly noticeable influence. It should rather be seen as a tool of the opposition to control certain processes that are tolerated by the governing parties and to position itself against them with its own policies. A request for accountability like the one in the letter from the Bremen FDP is typical.

Even if it does not have a direct effect, it can still steer the electorate and then politics in a different direction after the next election - or at least contribute to this. For gambling in Germany and the corresponding surveys, it certainly represents a further opportunity for greater transparency. Furthermore, it should not be underestimated that many political opinions and actions are influenced by the data from the Gambling Atlas and Gambling Survey. If it were to be officially confirmed that there is (was) a lack of independence, this could really shake up previous positions. It can be assumed that the FDP will use the answers as publicly effective as possible for its own purposes.

Image source: https://pixabay.com/photos/euro-gift-hand-keep-give-a-gift-3317432/

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