Department of Trust
Department of Trust, a trading name of 122 Ideas Ltd, supplies financial-risk and affordability assessment software for gambling operators. This role is distinct from behavioral gambling-risk detection: it evaluates financial and identity data rather than gameplay patterns.
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Department of Trust is the trading name of active UK company 122 Ideas Ltd, company 12979583 and the registered ICO controller. Charles Cohen holds more than 25% but no more than 50% of shares and voting rights. The controlling parent and complete ownership table are undisclosed.
Buyer decision brief
Use this summary to decide whether the offer belongs on your shortlist and which terms need a written answer.
Fit and use case
Current review scopeDepartment of Trust, a trading name of 122 Ideas Ltd, supplies financial-risk and affordability assessment software for gambling operators.
Primary offer: DoTrust Complete Financial Risk Assessments
Primary offer delivery
- API
- iFrame
Integration boundary: An operator configures its assessment methodology, calls DoTrust Complete through REST endpoints, and can embed a consented bank-data journey for deeper analysis.
Critical contract questions
Start with unresolved terms, negotiated terms, and dependencies that need a named owner.
Resolve before shortlist
No usable standard answer is available on the public terms.
- Assessment error and manual-review baselineNot disclosed
- DoTrust Complete Financial Risk Assessments · Operations and service
- Security, incident, and retention termsNot disclosed
- DoTrust Complete Financial Risk Assessments · Operations and service
- Check and bank-journey pricingNot disclosed
- DoTrust Complete Financial Risk Assessments · Commercial terms
- Assessment and bank-data portabilityNot disclosed
- DoTrust Complete Financial Risk Assessments · Exit and portability
Fix in the signed order
The answer changes by operator, market, package, or negotiated order.
4 of 5 shown- Jurisdiction and data availabilitySet in contract
- DoTrust Complete Financial Risk Assessments · Market and approvals
- Financial-risk check scopeSet in contract
- DoTrust Complete Financial Risk Assessments · Contract and supplier
- Controller and processor allocationSet in contract
- DoTrust Complete Financial Risk Assessments · Operating responsibilities
- External financial-data providersSet in contract
- DoTrust Complete Financial Risk Assessments · Operating responsibilities
Next buyer step
Ask Department of Trust to resolve “Assessment error and manual-review baseline” and “Security, incident, and retention terms” before moving DoTrust Complete Financial Risk Assessments to a commercial shortlist. Then compare the answer with the complete product record below.
Confirm every selected term in the proposal and signed order. No price, market approval, availability, or contracting entity is implied unless it is stated above.
What this provider offers
1 offering- TypeResponsible Gambling · Multi ProductOwnership and packagingMixed · StandaloneDeliveryAPI, iFrameCompare in
- iGaming Compliance Providers · Technology Owner
- Responsible Gambling Software Providers · Technology Owner
DoTrust Complete Financial Risk Assessments
Multi ProductMixedAvailability: StandaloneDepartment of Trust, a trading name of 122 Ideas Ltd, supplies financial-risk and affordability assessment software for gambling operators. This role is distinct from behavioral gambling-risk detection: it evaluates financial and identity data rather than gameplay patterns.
DoTrust owns the API, embedded journey, configuration, and assessment workflow. External banking, credit, identity, and other providers can supply the underlying data, leaving those inputs outside DoTrust's ownership.
Operators configure their own risk methodology and receive only the information requested by that setup. Department of Trust does not assume the operator's player-protection decision or regulatory responsibility.
Products
Integration: An operator configures its assessment methodology, calls DoTrust Complete through REST endpoints, and can embed a consented bank-data journey for deeper analysis. The operator is responsible for submitted data and returned sensitive information. Controller allocation, final decision rules, jurisdiction fit, implementation time, and price remain deployment-specific.
Delivery options
API
Delivery modelREST API access to the financial-risk and related checks selected in the operator configuration.
- Operator license
- Operator
- Merchant of record
- Operator
- Player data controller
- Unknown
Included
- + Configured identity, income, affordability, and financial-risk checks
- + Assessment results and data fields selected by the operator
- + Access to contracted external data connectors
Not included
- ! Gambling license
- ! Behavioral gambling-risk monitoring
- ! A universal operator decision policy
- ! Guaranteed approval in an unspecified jurisdiction
- ! Publicly fixed commercial terms
iFrame
Delivery modelEmbedded player-consent journey for obtaining the bank data requested by the operator's configured assessment.
- Operator license
- Operator
- Merchant of record
- Operator
- Player data controller
- Unknown
Included
- + Embedded bank connection and consent flow
- + Operator-selected bank-data period and disclosure depth
- + Return of the contracted assessment data to the operator
Not included
- ! Gambling account operation
- ! Behavioral risk scoring
- ! A transfer of the operator's final player-protection decision
- ! Universal market or bank coverage
Procurement record
Current product boundaries and the terms that still have to be fixed in the signed order or service agreement.
Known is usable now. Contract specific changes by order or market. Not disclosed has no usable standard term. Unknown remains unresolved. Outside provider scope is handled by the operator or another supplier.
Contract and supplier
- Department of Trust legal counterpartyKnown
- Department of Trust is the trading name of active UK company 122 Ideas Ltd, company 12979583. The operator agreement must use the legal company and identify the invoice, processor, support, and data-provider parties.
- Financial-risk check scopeContract specific
- DoTrust Complete supports configured identity, income, affordability, and financial-risk checks, with an optional consented bank-data journey. Behavioral risk monitoring, cases, self-exclusion, device blocking, messaging, and operator account controls remain outside this module.
Implementation
- REST and embedded bank journeyContract specific
- The operator calls REST endpoints and can embed a player-consent flow for a selected period and depth of bank data. The plan must define fields, consent evidence, retries, expiry, callback behavior, decision mapping, and fallback.
Operating responsibilities
- Operator methodology and final actionKnown
- The operator configures its assessment methodology and is responsible for submitted and returned sensitive information. It owns thresholds, manual review, customer contact, affordability or risk conclusions, account action, record keeping, and regulatory justification.
- Controller and processor allocationContract specific
- 122 Ideas Ltd is an ICO-registered controller, but deployment roles remain purpose-specific. The DPA must allocate operator data, consented bank data, derived indicators, support access, analytics, retention, rights handling, and any model-improvement use.
- External financial-data providersContract specific
- Identity, income, affordability, and bank-data checks can depend on external providers. The contract must name each provider, licensed purpose, territories, consent route, refresh timing, result fields, outage fallback, and replacement rights.
Operations and service
- Assessment error and manual-review baselineNot disclosed
- Comparable match errors, income errors, stale-data rates, false positives, false negatives, inconclusive results, consent drop-off, manual-review workload, and response latency are not established for a gambling population.
- Security, incident, and retention termsNot disclosed
- A product DPA, subprocessor schedule, hosting and transfer map, bank-data retention, incident notice, recovery objectives, security audit package, result export, and deletion commitment are not established in this module.
Commercial terms
- Check and bank-journey pricingNot disclosed
- Implementation, API, identity, income, affordability, bank-data, consent-journey, result, minimum, overage, environment, support, and professional-service charges are not established.
Market and approval scope
- Jurisdiction and data availabilityContract specific
- Financial-data access, consent rules, identity and income coverage, permitted gambling purpose, affordability framework, regulator expectations, and automated-decision limits vary by market and require a signed launch schedule.
Exit and portability
- Assessment and bank-data portabilityNot disclosed
- Input, consent, result, derived-indicator, decision, and audit records lack an established complete export, including provider-right survival, transition help, post-termination access, deletion timing, and deletion evidence.
Strengths
- + Operators can configure the risk methodology used for each assessment.
- + The product supports a lower-friction API path and a separately consented embedded bank-data path.
What to verify in procurement
- ! Financial-risk and affordability checks are not substitutes for behavioral risk monitoring, case management, self-exclusion, or device blocking.
- ! Inputs can come from external data providers; the agreement must define availability, permitted use, and source ownership.
- ! Controller roles, final decision authority, jurisdiction fit, implementation time, and price remain unresolved.
- ! FCA registration is unavailable and remains outside this module.
Reference documents7
Key public documents supporting the company identity, primary offer, delivery route, and highest-priority questions above.
- DocumentUK Information Commissioner's Office — ico.org.uk / RegistrationCertificate / ZB312025
- DocumentUK Companies House — find-and-update.company-information.service.gov.uk / company / 12979583
- DocumentUK Companies House — find-and-update.company-information.service.gov.uk / 12979583 / persons with significant control
- DocumentDepartment of Trust — docs.dotrust.co.uk
- DocumentDepartment of Trust — docs.dotrust.co.uk / user guide / embedded bank data journeys
- DocumentDepartment of Trust — dotrust.co.uk / research / reportJan24
- DocumentUK Gambling Commission — gamblingcommission.gov.uk / person / charles cohen
