https://data.blog.gov.uk/2014/04/28/odug-response-to-paf-advisory-board-response/

ODUG response to PAF Advisory Board response

ODUG response to PAF Advisory Board response to the Public Administration Select Committee report on Statistics and Open Data

April 2014

Introduction

The Open Data User Group (ODUG) is an independent advisory body appointed by the Chair of the Group and the Minster for the Cabinet Office. It receives some administrative support from staff in the Cabinet Office, but speaks independently.

We note the Postcode Address File Advisory Board (PAB) response, through its Chairman, to the House of Commons (HoC) Public Administration Committee Select Committee (PASC) Report on Statistics and Open Data which described the sale of the Postcode Address File (PAF) with Royal Mail as a “mistake” and said that “Public access to public sector data must never be sold or given away again”.

ODUG agrees fully with the conclusion of the HoC PASC Report.

Royal Mail Statement in response to PASC Report

ODUG finds Royal Mail’s statement concerning PAF disingenuous. The revised PAF licencing proposed by the Royal Mail changes little from the previously established PAF business model and the concessions to micro-businesses, small charities and the public are overstated.

The micro business concession appears to offer little more than the current developer licences. This is merely a try before you buy concession which soon places micro-businesses on the same terms as existing PAF re-sellers.

The concession to ‘small’ charities, offers some organisations, who are not currently licencing PAF, some access, which probably offers them no more than the enhanced terms for the public (an increase from 15 to 50 searches per day). Almost all significant charitable organisations such as Housing Associations and schools appear to be excluded under these terms.

The public use of PAF by entering up to 50 interactive searches per day, is little better than the 15 searches offered previously because of the very tight restrictions on the way in which the results of these searches can be used.

Royal Mail assures users, in its statement, that it remains committed to making PAF available at a ‘fair’ price. However, as all cost information related to PAF is deemed to be commercially confidential and was redacted from the PAF consultation document issued by Ofcom, we are expected to take this on trust. ODUG has long argued that the cost of maintaining the PAF should be considered as a cost of Royal Mail’s core business (deliveries) and has previously received evidence from a wide range of organisations which all feel that the annual £24.5 million of cost Royal Mail allocates to PAF is excessive, unreasonable and unfair. Royal Mail has released no evidence to counter this allegation. By comparison Ordnance Survey’s operational costs for a far larger and more complex set of data sets and products are approximately £105 million per annum.

PAF Advisory Board (PAB) Commitments

ODUG welcomes the PAB commitments to PAF licence simplification, however we fear that these will not go far enough. We would invite PAB to investigate the annual remuneration that Royal Mail would require to issue PAF under an Open Licence.

ODUG also welcomes PAB’s commitment to quality assurance for PAF data. However PAF is a difficult data set to quality assure as it is designed and maintained to satisfy Royal Mail operational requirements, which are not publicly documented, rather than as a general purpose dataset. In 2001 shortcomings in PAF, reprocessed by Ordnance Survey as AddressPoint, led to it being found unfit for the purpose of enumerating the occupants/residents in every dwelling in England and Wales. It is also unfortunate that the results of the most comprehensive assessment of PAF quality, its use in the ONS Address Register for the 2011 Census, were suppressed under the terms of the licence for PAF for that project.

It is ODUG’s view that PAF is only truly fit for the confirmation of mailing addresses and the administration of bulk mailing discounts, the sectors of the market Royal Mail’s own business focuses on, their having taken little account of the potential wider uses of the PAF in the recent work on PAF licensing. Worse still the need to licence PAF as a component of more comprehensive address registers, with the associated licencing complexity and cost will make it difficult to build a cost effective National Address Register or to issue one as Open Data.

This is likely, as stated by the National Statistician in evidence to the PASC, to lead to a fragmentation of address registers in the UK as users not willing to pay the excessive price demanded for PAF seek alternatives. This will not be in the national interest, or, in the longer term, in the interests of the Royal Mail itself, since a new de-facto standard address file is highly likely to emerge.

ODUG’s view is that a separate Public Sector PAF licence divides address users artificially, leading to more fragmentation in the area of address data and restrictions in the extent to which data checked or related to PAF addresses can be fully shared, defeating much of the object of a public sector licence. ODUG is also concerned that the price negotiated for the Public Sector licence has not been made public. ODUG would have preferred terms to have been negotiated which would have allowed PAF to be released as Open Data for all rather than restricted to the Public Sector.

Conclusion

ODUG fully concurs with PASC that the sale of PAF with Royal Mail was a “mistake”. Rather than restricting our view to that of PASC, that this mistake should not be repeated, we call on Royal Mail to reverse this error by negotiating “fee for service” terms for maintaining and delivering PAF as Open Data.

Presumably, as the maximum allowable revenue from PAF is being restricted to the existing £27m revenue deemed “reasonable” by Ofcom, if Royal Mail was offered an inflation protected annual payment of £27m there would be no incentive or need to charge for PAF and it could be released as Open Data. Also the costs currently allocated to PAF to support licencing, invoicing and use audit activities, would cease to be necessary and could be removed from the annual fee for providing an Open PAF. It would be helpful if PAB, and or, Royal Mail, could identify the annual cost of Royal Mail delivering PAF as Open Data.

Such an arrangement would ensure that PAF remained the postal addressing standard, and that its use was maximised for social and economic benefit across the wider economy. It would also comply with the government’s Open Government Partnership commitments and the Universal Postal Union aspiration that addresses should become a universal public good for the benefit of citizens.

Heather Savory

Chair Open Data User Group

April 2014

1 comment

  1. Comment by Owen Boswarva posted on

    For reference, here's a link to the full RM/PAFAB response mentioned above:

    18.03.2014 - Royal Mail and the PAB chairman respond to Open Data report

    -- Owen Boswarva, 28/04/2014

    Reply

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