Ofcom’s opportunity to review UK address data: let them know your views

Contents:

1. Background: the consultation

2. Why does address data matter?

3. Why isn’t it working?

4. How can this consultation help?

5. OK, you’ve convinced me. How do I respond?

The official list of UK addresses is one of our most important public datasets.

This page explains:

• why the lack of reliable, accessible address data in the UK causes harm

• how Ofcom could start to tackle this, by reviewing address data in 2021/22

• how to respond to Ofcom’s consultation to help make this happen.

It should take no more than 10 minutes to write to Ofcom, and the deadline is Friday 5 February 2021.

To respond, just write to planofwork@ofcom.org.uk - we’ve included suggested wording to use, to make it easy.

Ofcom is the UK’s communications regulator, responsible among other things for monitoring the performance of the Royal Mail.

Every two years, Ofcom consults on its plan of work for the next two years. Right now, Ofcom is consulting on its draft plan for 2021/22.

The Royal Mail owns and maintains the official list of postal addresses (‘address data’) for the UK.

This data is vital public infrastructure, but it isn’t working as well as it could be.

We think that Ofcom’s 2021/22 plan could include some activities to make address data function better for citizens.

Address data is vital to support public services, research and innovation. Everything happens somewhere, and address data helps us understand where that is. 

The official public dataset of UK addresses is called the Postcode Address File, or PAF.

In its simplest form, this is just the list of every address and postcode in the UK, and its latitude and longitude.

Reliable, accessible address data is important for delivery services, but also for building geospatial businesses, and doing things like registering to vote.

As services shift online, address data is increasingly important to the future of the UK.

Why is the Royal Mail involved?

When new houses are built, the addresses are created by local authorities, but the postcodes are allocated by Royal Mail.

This work by Royal Mail carries a cost, which has averaged £27.2 million annually over the last five years.

It also creates intellectual property (IP) rights over PAF for the Royal Mail, which means that Royal Mail charge money for the use of address data.

These IP rights for Royal Mail also extend into other valuable public datasets that contain addresses, such as property sales data, and mean that those datasets also cannot be freely reused, even if the government is otherwise happy to release them openly.

These complex IP rights create financial and legal barriers that make it hard for many people to use address data.

Businesses that rely on addresses typically need to pay a third-party address data provider. This data can quickly become out-of-date or unreliable.

And public services may use different versions of the PAF, or other address data sources.

That can lead to gaps in public and private services, with associated social and economic costs.

For example:

• the owners of new houses are sometimes unable to register to vote or receive deliveries, because new-build addresses can take several months to be added to PAF

• civil servants fear that shielding patients may have struggled to access support during the pandemic, because the address data used in different health and social care systems is inconsistent

• innovators struggle to build new services, due to the costs and legal uncertainty around using addresses and derived datasets.

Governance issues

There is also a lack of clarity about how addresses are governed, which means that it is difficult to know who should resolve these problems and what goals they should have in mind.

Ofcom regulates Royal Mail, while the Cabinet Office’s Geospatial Commission is responsible for the broader address data market.

It is not clear how these two roles interrelate, particularly given the widespread influence of the Royal Mail’s IP rights in PAF over geospatial data.

Ofcom has the power to review the costs, licensing and governance of PAF, but the last time it did so was in 2013.

Ofcom’s new work plan creates an opportunity to reassess whether PAF could work better for businesses and citizens.

We think that Ofcom should update its 2021/22 plan to include:

• A review of the costs of PAF

• A review to clarify the governance of PAF.

But Ofcom needs to know that people care about this.

You can respond to Ofcom’s consultation to let them know that these reviews would be a good idea.

Great! Responding is easy.

1. Download the consultation form (.odt file)

2. Explain why PAF matters to you

3. Email your response to planofwork@ofcom.org.uk by Friday 5 February 2021.

Here’s some text you might like to adapt in your response:

We welcome the opportunity to respond to Ofcom’s consultation on its 2021/22 work plan.

We suggest that Ofcom include a review of PAF as part of its work plan. Given the rise of digital services, PAF is increasingly important to the future of the UK.

Ofcom last reviewed PAF in 2013. Since then, the digital landscape has changed significantly.

In its new work plan, Ofcom should review the following:

1. Costs of PAF
   Since 2013, the Royal Mail’s costs for updating PAF have remained relatively static. However, cloud technologies and collaborative editing techniques have seen the costs of delivery drop elsewhere.
   We recommend Ofcom review whether the costs of PAF are still fair and proportionate.

2. Governance of PAF
   PAF has an influence on a broader data market, outside of postal services. Its governance creates legal uncertainty and financial cost for many UK data users.
   We recommend Ofcom review whether PAF’s current governance is appropriate, and how it could be improved while still ensuring that the postal services market operates satisfactorily.

You can also read our longer response - please feel free to re-use as much of this as you like in your own response.

Thank you, and please get in touch if you’d like to discuss anything here.