#postcode address file

Post: 28 March 2024

New blog post on my website:

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The Imperial Export PAF Top of the Address Finder <\p>

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Bringing to light the Interjection Finder Service <\p>

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The Royal Mail PAF Bourn of the Address Finder <\p>

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Catching the Address Finder Service <\p>

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Why Integrating the Service Has Become Crisis for E-commerce Businesses <\p>

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Post: 12 November 2013

Regular readers will know that I have been trying to persuade Royal Mail to release the Postcode Address File cost stack figures that were redacted from the public review of PAF arrangements carried out by Ofcom earlier this year. Correspondence with Royal Mail (through the request and internal review stages) is covered in my previous posts here and here.

In May I referred this matter to the Information Commissioner's Office as a complaint (with a lot of attachments).

Since then of course Royal Mail has been privatised, which takes the company outside the scope of the Freedom of Information Act.

The Information Commissioner's Office (ICO) has now responded with a brief e-mail that closes my complaint. The gist is as follows:

You may know that the Royal Mail is no longer a public authority since it was privatised and as such the company is no longer subject to the FOIA. Consequently, the Commissioner does not have the power to investigate the company or order disclosure of information that the company may hold. The ICO is seeking further legal opinion on whether any retrospective measures regarding the company’s previous responsibilities under FOIA are in place. If that is the case the ICO will write to you again and your complaint will be re-opened.

Realistically this was the outcome I anticipated. However it does provide an illustration of the threat that privatisation poses to information rights and transparency more generally. The suggestion that there might be "retrospective measures" in place is interesting, but I will be surprised if anything comes of that.

Post: 18 August 2013

Last week the UK's Cabinet Office rather belatedly placed online the minutes of the three most recent meetings of the Public Sector Transparency Board. (I submitted a Freedom of Information request for these minutes last month.)

Then a couple of days ago Cabinet Office swapped out the first version of the June 2013 minutes with a new "final" version containing quite a few revisions.

Some of these revisions are simple corrections or rhetorical flourishes. However there are also some changes of substance that I think provide insight into the fragile state of UK transparency policy.

Presentations from ODI Start-ups

The minutes kick off with notes of presentations from two startups linked to the Open Data Institute. Ian Makgill of Ticon, a management consultancy with particular interest in government procurement, spoke on the subject of how startups use Government data. Jonathan Raper of Placr, a firm that develops with transport data, urged the Government to release several key datasets.

Raper's recommendations are sensible and will resonate with anyone in the open data community who works with transport data. Makgill's are more likely to divide opinion; he wants to remove the minimum threshold for reporting of spending data, wants to discourage Government from developing its own data, and thinks "personal information" is used to block the release of too much data.

(I can't be sure which of these two presenters is more likely to have the ear of Francis Maude. However Ian Makgill is the 14th Viscount of Oxfuird.)

Both versions of the minutes contain a list of "observations and objectives" set by the Transparency Board following the presentations. This is the list from the original version:

Ongoing efforts to extend requirements to publish data to data.gov.uk to local authorities should be completed as soon as possible. Greater concentration of effort towards local authorities.

Follow up HMT lowering of minimum threshold from £25,000 to £10,000 although Ian does not consider that this goes far enough

Standards need to be communicated, understood and implemented more effectively across government departments.

DfT and other data holders should be pushed harder to open up significant data sets. This would drive competition into the market place. He also argued that many of the problems set out in the two presentations would be resolved through more effective engagement with local government.

Necessary to break relationship between departments and preferred developers. We need to release all data and leave it to private developers to work with.

and this is what remains in the final version:

Standards need to be communicated, understood and implemented more effectively across government departments.

Departments should be pushed harder to open up significant data sets. This would drive competition into the market place.

The more specific or potentially tricky objectives have been removed. That could mean the Transparency Board lacked consensus on those objectives, or that Cabinet Office lacks confidence in their achievability, or that the Government doesn't want to draw attention while it works toward them.

Both presentations seem to have identified engagement with local government as a key issue, but that is likely to confound Cabinet Office unless there is a sea change in attitudes at DCLG.

Release of Foreign & Commonwealth Office Data

The following has been removed from the discussion of FCO data: "Andrew Stott argued that we need to track the use of travel advice further." This may have been prompted by developer reaction to the retirement of FCO's RSS feed for travel advisories (as well as of the LOCATE service). However FCO has subsequently launched a new Atom feed for travel advice.

Shakespeare Review, Domestic Strategy and National Action Plan

The final version of the minutes confirms that a member of Cabinet Office's Transparency Team will sit on each departmental Sector Panel, as part of "renewed engagement" with departments. In the earlier version this was only an "aspiration".

This initiative may reflect a recognition that there is a wide variation in practice and output from the Sector Panels. (I've made an attempt at tracking them, but it would help if Cabinet Office actually released an official list of all the Sector Panels and their members.)

European Amendment to the directive on the re-use of Public Sector Information

The Transparency Board's summary of the final text of the revised PSI Directive is rather partial and glosses over the carve-outs for trading funds and other commercial ventures that the UK negotiated in committee. Member states have until summer 2015 to implement the Directive, and it's doubtful whether it will make any material difference to the UK open data agenda.

The earlier version of the minutes records that Francis Maude "commented that it is likely that the UK will have gone beyond the scope of the directive by the time it is published." The final version only records that he "commented on the direction of UK policy and encouraged consideration of options for earlier transposition in the UK."

Postcode Address File

Paul Maltby discussed the Postcode Address File. Both versions of the minutes try to put a brave face on things by presenting Royal Mail's sop to the open data argument as some kind of agreement. However the final version does further note that these measures "have not delivered the result needed to promote growth/innovation or to underpin the National Information Infrastructure."

(Internal review response now received - see updates below.)

Post: 15 March 2013

A brief update on my post of last month, re the key figures redacted from Ofcom's Postcode Address File consultation:

Royal Mail has also rejected my Freedom of Information request for the PAF cost stack figures, on the basis that they are commercially sensitive. RM maintains that on balance "the public interest in protecting the commercial interests of Royal Mail Group outweighs that of disclosure."

Quelle surprise, right?

The Ofcom consultation closes next week. In related developments:

the Open Data Institute has submitted a response urging open data release of PAF as part of a free National Address Dataset,

the Open Data User Group has also submitted a (quite strongly worded) response,

BIS, which is currently the main Royal Mail shareholder, has responded to an Open Rights Group campaign e-mail on the same issue,

the PAF Advisory Board held an open meeting (slides), and

Royal Mail and BIS have announced a new Public Sector Licence for PAF, which rather looks like a spoiler for the Ofcom consultation and/or the open data campaign.

Further update: 18 March 2013

I've now sent a letter to Royal Mail requesting a review of its FOI response, with an argument that it has insufficient grounds for relying on the commercial interests exemption and has also applied the public interest test incorrectly.

Further update: 16 May 2013

Royal Mail has now replied to my request for an internal review of its FOI response. It's quite long but Royal Mail do not seem to have presented any new arguments of substance.

I do hate to trouble the Information Commissioner, but ...

Further update: 12 September 2013

Ofcom has refused my FOI request (submitted in a tweet!) for an unredacted copy of the Postcode Address File consultation document, citing exemptions under Sections 43 and 44 of the Freedom of Information Act.

Section 43 exempts information from disclosure if it would prejudice commercial interests, and Section 44 enables Ofcom to rely on the general restriction on disclosure of information set out in Section 56 of the Postal Services Act 2011.

This refusal is unfortunate but not a surprise. I have no reason to suppose Ofcom has misinterpreted FOIA. The redactions in the consultation document were undoubtably made at the request of Royal Mail, which currently controls the Postcode Address File (PAF).

However it is difficult to understand how the Ofcom consultation process can be credible, without public disclosure of the PAF cost stack figures that have been redacted from the 'non-confidential' version of the consultation document.

As noted in the consultation document, the Open Data User Group (ODUG) has recently published a paper arguing for open data release of PAF as part of an Open National Address Dataset. ODUG is firming up an economic case for this proposal, for submission to the Data Strategy Board. 

The arguments for open data release of PAF are not new; unlocking national address data has long been a central objective of the UK open data movement. However ODUG is also calling for a change in ownership of PAF, to safeguard the dataset against the Government's privatisation plans for Royal Mail.

At the moment Royal Mail has an effective monopoly over creation of key elements of the national address dataset. The PAF cost stack figures are particular to those unique arrangements and it is unlikely that their disclosure would significantly benefit any Royal Mail competitor.