Free Our Data: the blog

A Guardian Technology campaign for free public access to data about the UK and its citizens

Archive for the 'Financial analysis' Category

Revealed: how profitable Royal Mail’s Postcode Address File (PAF) really is

Thursday, April 26th, 2007

The Royal Mail’s Postcode Address File (PAF) is pretty much indispensable for anyone doing direct marketing work. Now the Postcomm report on PAF that we mentioned last week has come up with something not seen before, at least outside RM: the profit and loss accounts for PAF. (Postcomm is the postal regulator, independent of RM.)

Turns out that PAF makes a profit of £1.58m on revenues of £18.36m, an 8.6% return on revenue. Most of the revenues come from PAF resellers (£14.9m). You’ll have to read to Annex 5 of the Postcomm report.

But we’ve looked at what this means in The Guardian. PAF underpins billions of pounds of the Royal Mail’s business, the direct marketing business, and the burgeoning market for satellite navigation (from memory, worth about £400m last year – corrections welcomed).

The price however is without any payment to local authorities, who have been cutting up rough about having no intellectual property rights embedded as suppliers of new address data. (There’s no information from Postcomm about how much PAF revenue comes from the public sector, which would be a useful figure. Royal Mail was chary about providing any information on PAF, one discovers on reading the report.)

RM told us it is “confident” about reaching a settlement. But isn’t this just more of a money-go-round, if they’re paid for supplying data to a product they then buy? Wouldn’t it make more sense to have PAF centrally funded, ringfenced by Postcomm’s recommendations and available for free to all? You might even encourage people to offer updates directly – which would cut the cost of maintenance, which at £9m or so comprises more than half the cost of running PAF for RM.

Postcomm makes recommendations on future of Postcode Address File: it should make a profit

Thursday, April 19th, 2007

Postcomm, the postal regulator, has come up with its recommendations on what should happen with the Postcode Address File (PAF) – that valuable item owned by the Post Office/Royal Mail.

Postcomm calls them “new safeguards for the future management of the postcode and address data contained in Royal Mail’s Postcode Address File”, which you can see at the Postcomm announcement on PAF:

The four key issues covered in today’s document – “Royal Mail’s future management of PAF” (pdf, 604KB)– are:

  • The definition of PAF – what information should Royal Mail be obliged to supply? Postcomm considers that ‘PAF data’ is not only made up of postcode details, but also includes other information needed to allow users to identify specific addresses.

  • The creation of an advisory board. Royal Mail has agreed to set up an advisory board to represent the views of PAF users, and has already started the recruitment process for the board’s independent chairman.
  • Ringfencing of PAF. As competition develops in the mail market – and also with other suppliers of similar address data – it is crucial that Royal Mail ringfences PAF from its other activities, in order to avoid potential conflicts of interest.
  • Profits. There is increasing demand for PAF data from a wide range of organisations, which rely very heavily on the information it provides. This puts Royal Mail in a very powerful position where setting prices is concerned. Although PAF does not fall within the ‘price control’ that Postcomm uses to set a pricing and service quality framework for Royal Mail, the company has agreed to aim for an operating profit margin in the range of 8-10%. If profits exceed this range, the excess would be either returned to customers or reinvested in PAF.
  • The linked PDF is a sprightly 92 pages, and I’m working my way through it. The questions that spring to mind for me are: why 8-10%? I suppose that’s a typical operating profit in the private sector – but it’s interesting that there’s not been the application of, say, “return on capital employed” (used in trading funds) which would give a much lower price for PAF.

    Secondly, how can PAF truly be ringfenced?

    We’re interested to hear your views – particularly if you’ve managed to reach page 92 first.

    In The Guardian: a year of Free Our Data campaigning: why is the Office for National Statistics free?

    Thursday, March 22nd, 2007

    And what have we got? You might ask. Plenty of interesting points that there wasn’t enough room to fit in print, in fact (we didn’t get into the matters of other countries which don’t charge for their mapping).

    Among a list of “interesting things we’ve learnt in the past year” in A few victories, but the battle goes on in today’s Guardian is one that has been intriguing me ever since the NCeSS event last week.

    It’s this: the ONS makes its data available for free. The Ordnance Survey doesn’t. But they’re both dealing with data that are constantly changing.

    As the story puts it:

    • Despite being in effect half taxpayer-funded, OS’s position as a trading fund protects it from financial neglect by the Treasury, according to advocates of the model. They argue that OS has to collect data about a constantly changing landscape, and that making it fully taxpayer-funded would put it at the mercy of central funding, which could wane (as happened between the two world wars).
    • The Office for National Statistics, which collects data about constantly changing social elements such as internet use, labour, manufacturing output and so on, is not a trading fund, and makes the majority of its statistics – including demographic data from the 2001 Census – available for free via its website.

    So here’s the question: why isn’t ONS a trading fund, if it’s such an effective model?

    Your questions please for Baroness Ashton – and a question for you, the reader

    Tuesday, March 20th, 2007

    Baroness Ashton, of the Department of Constitutional Affairs, and about as close as the government gets to being a minister for public sector information, has agreed to give us an interview meet us, off the record, next week. She would like to “hear our concerns”.

    So, what questions would you like us to ask her? Reasonable ones, please.

    And (since I’ve linked to theyworkforyou): Tom Steinberg, one of the people behiind MySociety, asked a key question about the realpolitik of the campaign:

    “What single piece of evidence would you put forward to the Treasury that would convince them that it is worth spending tens of millions of pounds to make this data free?”

    In other words, where’s the proof that this move to free data would really bring economic benefit?

    Your submissions please. Links to papers (even very geeky economic ones) for, and against it you like.

    ‘What happens at the next Lockerbie?’ – the risks of killing NIMSA

    Tuesday, March 20th, 2007

    One of the points that I made during the Open Knowledge Foundation meeting in London last week was that the Ordnance Survey knows when everything changes. It has a mission to map the UK, and pretty much anything the size of a garden shed will get noticed by its overflights. (Wouldn’t local authorities love to know about changes in their areas that conformed or didn’t to planning permission? How much do they have to pay if they do?)

    I’ve been to OS – which apparently six of the eight past ministers in charge of OS haven’t – and seen the work they do loading the overflight data onto the MasterMap. It’s impressive. The OS target is to get 99.6% of changes in the database within six months.

    However the end of the National Interest Mapping Services Agreement (NIMSA) last year means that the OS gets no subsidy to map areas that are out of the way. If it’s having to compete with a growing number of commercial services (apparently the latest one Vanessa Lawrence is concerned about is China’s mapping agency), how can it justify mapping remote areas at that speed?

    Ed Parsons, former chief technology officer at Ordnance Survey, says that it won’t. “Areas in cities will get updated, but in Scotland your new garden shed might not be noticed for five years.” Nice for your garden shed – but what happens when a plane or a tanker or some other disaster happens in that remote area that has been neglected because of the death of NIMSA?

    That is why the Free Our Data campaign says that Ordnance Survey is valuable – and that the government has a responsibility to citizens to make sure the UK is well mapped, within the public sector. Duncan Shiell of OS, who spoke at the NCeSS event, said that between the wars, councils did a lot of the mapping – but that when the OS was re-funded back to strength and took it over, it discovered that many of the maps didn’t join up across county boundaries... explains what happened between the wars in the comments (Any errors are mine, from misremembering.)

    We think the point remains though. That’s why you need a well-funded – taxpayer-funded, not privatised – OS.

    Free our address data – or at least get them to stop charging each other: the petition

    Tuesday, March 13th, 2007

    As noted in this comment elsewhere on the blog, there’s now a No.10 petition to stop the address madness:

    We the undersigned petition the Prime Minister to stop the expensive and damaging address ownership conflict currently existing between Royal Mail, Ordnance Survey and Local Government by definitively establishing that the intellectual property input of all three parties into derived address products such as PAF, AddressPoint, NLPG and NSG is equal in scope and value. Consequently, in the public interest, none of the three parties should charge either of the other parties for use of these products.

    While we’re sceptical of the power of these petitions to change anything, they’re a good meeting point to indicate strengths of feeling.

    So – sign it and then meet back here to work out what financial impact this would actually have – especially since local authorities are meant to be planning how much to charge for searches relating to homes (link to Yvette Cooper MP dithering on the matter earlier this month).

    If they didn’t have to pay for that part, would searches be cheaper?

    In The Guardian: how and why South Africa set its data free

    Thursday, March 8th, 2007

    Following on from our earlier post about South Africa’s free mapping data, we got in touch with Derek Clarke, head of the CDSM (South Africa’s mapping agency) to ask him what effect the imposition of zero costs – a corollary of the 2000 Promotion of Access to Information Act. (That’s a Google cache link, in HTML.)

    In South Africa’s freedom includes its data, we ask whether the move from a charging system, which used to bring in 5% of the budget, has brought any benefits – either in reducing waste, or expanding use, or both.

    Derek Clarke, head of the agency, says yes to both: most of the clients for the CDSM’s mapping data before were government agencies, and in Clarke’s pithy words “government paying itself makes no sense but causes administrative waste.” And has use grown? Yes, by 500% (we make that sixfold), he says.

    Is it a model for others? Clarke again:

    “This model should be applicable to all developing countries where the government must play a developmental role. The same situation does not apply to developed countries with mature markets. However, governments of developed countries should evaluate the opportunity cost of geospatial data – it may be more beneficial to make data free.”

    We’ve put the questions and answers from Mr Clarke online already, but the article aims to deal with the critiques we know will follow from any suggestion that the UK might have something to learn from South Africa…

    South Africa: mapping is free (and so is other government information)

    Sunday, March 4th, 2007

    The opening of the South African government’s Freedom of Information Act 2000 states its position bluntly:

    • the system of government in South Africa before 27 April 1994, amongst others, resulted in a secretive and unresponsive culture in public and private bodies which often led to an abuse of power and human rights violations;
    • section 8 of the Constitution provides for the horizontal application of the rights in the Bill of Rights to juristic persons to the extent required by the nature of the rights and the nature of those juristic persons;
    • section 32(1)(a) of the Constitution provides that everyone has the right of access to any information held by the State;
    • section 32(1)(h) of the Constitution provides for the horizontal application of the right of access to information held by another person to everyone when that information is required for the exercise or protection of any rights;

    ..and the upshot: maps of South Africa are free. Have a look at the maps pricing page: the only charge is for postage and packing. Which on the digital products is zero, though with the proviso that the supply of digital information not contained in the off-the-shelf products and/or required in any other format, an hourly rate will apply to prepare such information: Provided further that the Chief Director of Surveys and Mapping can provide the data in the required format.

    Questions we’d like to know the answers to:

    • how much does it cost to do this?
    • is the mapping agency’s budget assured, and if so, how?
    • how is the quality of the mapping data assured? (We can have a guess at this from the fact that there’s a network of GPS stations, whose locations are available for download, for free)
    • Has this led to any measurable increase in mapping services in the private sector?
    • Has it had any negative or beneficial effect on mapping suppliers – including the government mapping agency?

    We’ll be trying to contact the SAMA, but if anyone has any pointers to answers to these questions, we’d be grateful for the information.

    Who owns Scotland? Now without maps!

    Friday, February 23rd, 2007

    The owner of the Who Owns Scotland site, which aims to document the ownership of the land in Scotland (durr), gets in touch to tell us about how the Ordnance Survey (sorry, yes, them again) kept switching its position on whether and how or even if he could use its maps on his site.

    As this page he outlines his problems:

    All Ordnance Survey (OS) digital mapping was removed from this website on 23 February 2007. This was due to the unilateral termination of my contract by OS in October 2005 and my unwillingness to accept the new terms that were being proposed by them due to excessive costs, continuing contractual uncertainty and a breakdown of trust.

    The problem arose because depending who he spoke to in OS, he either was allowed or wasn’t allowed to use their maps on his site. Eventually, just as he was trying to decide whether to renew his licence (he was paying, like a good protesting but law-abiding citizen) to use the maps, the OS told him that it had summarily ended the contract about six months earlier.

    It was recently established that OS has “no more than sewven lawyers, amounting to 6.2 full-time equivalents”. One feels that they’re spending time undoing each others’ work. Now, if there weren’t any copyright issues…

    Internal transfer pricing: the justification for OS charging. But is it right?

    Wednesday, February 7th, 2007

    Steven Feldman has put up a new post at his Giscussions blog, where he’s pulling together a series of comments he and I left about the FOD concept, and particularly the Ordnance Survey role in it.

    As he notes, some good economists would be useful. You can comment here or there.

    Steven writes, at his blog:

    Lots of organisations in the commercial sector use internal transfer pricing mechanisms between divisions. Sometimes this is to allocate revenue between tax jurisdictions (can be tax avoidance but can be legitimate and reasonable) and in other circumstances transfer pricing ensures sensible investment and commercial strategies, good rates of return and avoids waste and inefficiency. OS charging public sector clients for the use of its data is just a form of transfer pricing within the public sector, there are loads of other examples. Describing it as a money-go-round is overly simplifying the topic.

    In theory (and I stress the word theory) the endeavour to establish a market price for the supply and maintenance of the national map will help to ensure that the public sector achieves best value from its expenditure. With the private sector snapping at OS heels there will be some limited pressure on pricing although I recognise that scale prevents any serious competition at the moment. Perhaps some company will decide to take OS on head to head, then we might see an interesting tussle – but no free data.

    As Pete commented the concept of treasury funding to OS took a bit of a bashing with the withdrawal of the NIMSA. I cannot see how anyone who cares about the quality and currency of the national map could advocate placing the whole lot at the whim of a treasury mandarin in a budget crisis.

    Are we talking our way into a sell off? Would that matter?

    In order, my responses: internal transfer pricing can be justified as “putting a commercial value on something internal”. That’s what the BBC did with “Producer Choice”. It wasn’t popular, but equally some of the things it did – like getting internal BBC divisions to compete directly against outside ones – did focus the mind. OS though is intimately tied to the public sector. Are there many other organisations out there offering what it does? Does the MOD call up Google or TeleAtlas for some maps?

    Placing OS at the whim of a Treasury mandarin – well, that’s the point about ring-fencing. I’m sure it’s how we’ve ended up with the situation we have at present, where OS is a trading fund so that it very specifically doesn’t trouble the Treasury when spending rounds come, er, around. And OS works very hard – driven by Vanessa Lawrence, who saw all this rapidly on joining (to give her her due: she’s evidently an able political animal, in the best sense) – to stay out of the Treasury’s way.

    But while that’s convenient for the Treasury, and for Gordon Brown in the short term, it’s not to everyone’s benefit overall. It’s rather like health insurance vs universal health care. Why don’t we pay directly for health care, as in the US? Because we’ve judged that it actually has effects we don’t like.

    As for talking our way into a selloff – I think Vanessa Lawrence would lobby very hard against that, and would probably get backing in that view from DCA (Dept for Constitutional Affairs), which wouldn’t want the vast hassle and distraction of readying a privatisation. Notice how OS didn’t put the National Geographic Database into the National Asset Register that Treasury has just drawn up. Nice way to stay out of the spotlight, again. (Of course, the NGD doesn’t appear in the OS accounts, so it’s the most intangible of intangible assets.)

    Equally I think there is some gradual movement within government towards cheaper data. Quite how one squares that circle with the OS being a self-sufficient body is tough. I agree. There aren’t easy answers. But there are better ones.

    The money-go-round, and the truth about Ordnance Survey funding

    Tuesday, February 6th, 2007

    Wonderful what a bit of careful watching of the theyworkforyou site (which slices and dices the doings of Parliament into usable form) can do.

    For instance, revealed through a series of questions posed by Derek Wyatt (who chaired the RSA’s Free Our Data debate) is the fact that more than half of the Ordnance Survey’s funding for the financial year 2004-5 came from the public sector, because while it’s happy to say its figures are only 47%, that doesn’t include NIMSA funding.

    In fact, Nimsa contributed £13.2m to OS that year while “turnover from operating activities” was £114.7m. Nimsa was thus more than 10% of OS revenues that year. (The reports don’t seem to distinguish between NIMSA revenue and trading revenue.)

    Here’s the question.

    In Bureaucratic nonsense of the government’s money-go-round we point out that a lot of the Ordnance Survey’s revenues are part of a carousel – upheld by lawyers (it’s got six, and spent more than half a million on outside legal fees) – in which money travels around the public sector.

    And it’s not the only one:

    Meanwhile, defence minister Derek Twigg shed some light on the extent to which another successful trading fund depends on government support. Answering a question from Conservative MP Mark Lancaster, Twigg said that of the Meteorological Office’s revenues of £170m in 2005-06, 36% came from central and local government. The scale of such payments being made between different arms of the state calls into question the government’s claim that its mapping and meteorological agencies operate on a commercial basis.

    The issue of freeing data, and whether it’s a good idea or a middling one or a bad one, or even a good one that would be confounded by a Treasury keen to cut funding for any agency, is one I’ve been discussing quietly with Steven Feldman (who often contributes in the comments here) over at his Giscussions blog. You’re welcome to comment here or there.

    But a key point is this: the Treasury hasn’t looked into the cost/benefit of making more data free of charges and of copyright restrictions. The Office of Fair Trading has at least made a beginning. We think it looks better than the Treasury allows.

    How OS costs hold back local authorities housing associations: the view from the ground

    Monday, January 15th, 2007

    An interesting post that we came across by letting Blogdigger trawl the web for mentions of “Ordnance Survey”. Extract:

    In the field I work in housing (asset management) the use of maps would be particularly beneficial. On top of this, I also help manage some patch related data for our housing management team. Being able to link all this into some automapping system would make many tasks I perform so much easier. In addition, visual tools are staggeringly useful when persuading people or explaining things to a new audience.

    Being able to show a map which outlined that 80% of our Decent Homes failures are in one half of our stock would be a lot more powerful when persuading our board to release extra funds, for instance. The human mind responds strongly to visual stimuli, and maps in particular plug straight into a particular part of the brain.

    Of course, to do all this, we need a certain amount of geographical data. There’s the maps themselves and then there’s geocoding our properties. Which leads to enquiries like the above. No doubt we could afford that, but in good conscience can we really spend £16k on what is effectively a glorified A to Z? £16k after all could supply brand new kitchens to four families, or ensure 8 homes have brand new central heating systems which will cut fuel bills and keep people warm should the weather change. We have to consider the opportunity costs.

    As the post title says, this isn’t the ‘tragedy of the commons’ (where making something free means it gets abused, as in email carriage and spam). It’s the opposite: by enclosing the land, you keep out precisely the people who could make the best use of it. It’s like having farmland and then charging anyone who’s a farmer or wants to learn thousands of pounds to work it.

    The writer concludes:

    And so what will we do? As is often the case, my answer is DIY : We’ll collect the data ourselves. As ridiculous as it sounds, because of the restrictions on the data we’ll be much better off simply collecting the information ourselves and using any one of a number of open source applications simply generate the maps ourselves. Or so is my intention.

    GPS equipment is now within the reach of the average citizen and a procedure for geocoding our properties could easily be included within our stock condition procedure or even included in with caretaker duties or a void routine.

    But…isn’t this a bit ridiculous? Aren’t we going against a sensible division of labour? Instead of information being collected by experts en masse, we’re going to be taking a piecemeal amateur approach.

    Yes, that’s how creating an ‘internal market’ generates inefficiencies. The council’s data might not be as good as the OS’s, and you’ll have duplicated work. Stupid.

    Postcode charges threatens split between councils and Post Office

    Thursday, November 16th, 2006

    Worryingly, the government’s insistence that every chunk of data somehow be turned into an asset in itself – rather than an asset to whoever uses it – is creating fissures between councils, which generate addresses, and the Post Office, which charges them for using postcodes.

    Read more at A one-way street to postcode madness in today’s Guardian:

    Councils say they provide lists of street names and numbers for free – but Ordnance Survey and Royal Mail treat their data as a commercial asset and charge other public bodies to make it available to the wider public.

    …Royal Mail says that the sums are tiny: authorities pay 0.5p a click, or a flat fee per domain. However, councils, under constant pressure to meet new centrally set financial targets, have little slack in their budgets. The final straw is that from October next year, the charge will double. Jennie Longden, head of address management at Royal Mail, says that these are the first price increases since 1995.

    The result, though, could be a grassroots rebellion. David Heyes, address manager at Wigan metropolitan borough council, Greater Manchester, says he is “very uncomfortable” with the click fee.

    ….Datastandard, a web community for professionals, has suggested charging Royal Mail between £250 and £1,000 for notifications of changes to local gazetteers. “I suggest Royal Mail pass on some of their costs to Ordnance Survey, but that’s for them to sort out,” said Robert Kimber, of Luton council.

    Would that be good for free data? No – it’s moving in the opposite direction. What’s needed is a minister or two to bang some heads together. Unfortunately it seems the heads that need banging are within government – possibly inside the Treasury – to stop this madness.

    NIMSA is dead: bad news for Ordnance Survey – and free data?

    Thursday, November 2nd, 2006

    A terse announcement from the new Department for Communities and Local Government (DCLG) says that the National Interest Mapping Services Agreement (NIMSA), which “funds mapping services which are in the national interest, but would not otherwise be provided by the market as they are not economically viable”, is not going to be renewed when its seven-year term expires at the end of 2006.


    DCLG considers that: (a) it is appropriate for some of the services which have been supported by NIMSA, to be procured directly by those public sector bodies who require them, either individually or collaboratively; and 

    (b) it is appropriate for DCLG to continue supporting some national interest geographic activities but on a much smaller scale than previously.

    And the effects on users?

    Ordnance Survey has already indicated to DCLG that they are willing to continue to provide a ‘Mapping for Emergencies’ helpline service and national interest coastal survey work. Ordnance Survey will separately be advising users of any impacts of the decisions made by DCLG. 

    We’d like to know what OS thinks those effects will be. (They’re welcome to say here in the comments, anonymously or not.) For OS, NIMSA might not have been a huge part of its income (anyone have a number?) but it did prove that it was worth having, because the market wouldn’t do it. (And we’ve heard a lot about market failure having extremely large knock-on effects recently.)

    What’s faintly worrying about this is that it implies that DCLG doesn’t see OS as an important organisation. The Free Our Data contention is that OS is important, and that mapping everywhere, not just the bits that the market today thinks are important, matters. What we disagree about is the funding model.

    OPSI finds against OS in row over AddressPoint licensing

    Tuesday, July 18th, 2006

    [Update: if you’ve come here via the Guardian article on spam, then first, apologies; secondly, the location you actually want to go to is – and that will tell you what IP address you’re on. Again, sorry for the error, which was introduced during editing.]

    We’ve seen the OPSI report into Intelligent Addressing’s complaint (148K PDF) about the lack of transparency in the AddressPoint licensing terms.

    Essentially, Intelligent Addressing (hereafter IA) says that OS seems to have a different licencing regime internally than externally: that a company outside OS can’t get access to AddressPoint on anything more than one-year contracts, whereas OS can use AddressPoint indefinitely. That puts external organisations like IA, which wants to license AddressPoint in order to compile the National Land and Property Gazeteer (NLPG), at a disadvantage.

    And OPSI agreed.

    Para 35:

    In addition, the Complainant alleges that the lack of transparency extends to the website in that it is not clear how the Framework
    Agreement interacts with the specific use contracts. Furthermore, the
    Complainant states that there are few published details about the
    partner licensing options.

    Para 37:

    The PSIH states that the website contains significant openly accessible
    information, but does not publish the licensing options as the majority of
    partners have actively managed accounts, and the PSIH works closely
    with them to discuss their tailored licensing solutions.

    The PSI Regulations also state that “Where conditions are imposed they
    shall not unnecessarily restrict (a) the way in which a document can be re
    -used or (b) competition? (Regulation (12) (1)). It appears to OPSI that the
    terms of the licence unnecessarily restrict the way in which AddressPoint
    can be re-used and unnecessarily restrict competition since such terms
    are unnecessarily prescriptive. Some conditions imposed by the PSIH
    restrict the way in which AddressPoint can be used and this restricts
    competition between the Complainant and the PSIH since it immediately
    puts the Complainant’s products which use AddressPoint at a
    disadvantage to those of the PSIH. One such condition relates to time, as
    the PSIH can grant licences with a longer term to end-users than others
    such as the Complainant, who is limited to twelve month end-user
    licences as licensees want more security in the length of time they are
    able to use the information. This means that the Complainant is at an unfair disadvantage. Another example is cost as the Complainant has
    to pay a higher licence fee for the use of AddressPoint. OPSI does not
    consider that such restrictions are necessary.

    You can read the full complaint and response. But here’s OS’s response, hot off the press:

    “On the OPSI report, as Carol Tullo [head of OPSI] was saying last night [at the RSA/Free Our Data debate], it was only published last Thursday and so we still need to discuss it with OPSI in the context of the points we are already exploring from the reverification process you reported on in March.

    That said, we do have a number of concerns around matters of fact and law in the report and are considering the options open to us including our right of appeal to the Advisory Panel on Public Sector Information (APPSI). The report purports to make wide-ranging recommendations regarding our licensing policy on the basis of a narrow investigation of a single, and atypical, set of circumstances.

    Please be aware also that although they have a right to make a complaint to OPSI, Intelligent Addressing are not a licensee of Ordnance Survey information; they are a contractor to Local Government Information House, who are the licensee. We believe that OPSI’s interpretation of some of the concepts, terminology and clauses within Public Sector Information regulations could make it difficult for us to properly differentiate between the terms and conditions used for products and services licensed directly to end users for their internal business operations, from those applying to partners who generate commercial revenue by exploiting the data in their own products and services (often by adding value to our data); for example, a direct utility customer using the data to manage multi-million pound assets of pipes and cables would have to be licensed in a similar way to a small publisher using the data to produce consumer products retailing at a few pounds.

    OPSI also appear to ignore the fact that third party data plays an increasingly important role in the content of our products and services, bringing added value and benefit to users. Royal Mail has a significant IPR interest in the products involved in the complaint. OPSI’s reading of relevant PSI regulation clauses could result in us having to implement pricing and licensing terms and conditions that would undermine the commercial interests of these third parties. This could in turn discourage them from offering their data into collaborative products and inhibit our ability to produce marketable data or to generate adequate revenue for reinvestment.

    Our adoption of specific use contracts followed wide consultation with licensed partners from whom it gained broadly-based support. It enables pricing of data to be varied according to end-user perceptions of value for clearly identifiable areas of use. With this mechanism in place it guarantees that competing partners licensing products into the same market have paid similar licensing costs to us. The model assists in creating competitive markets among partners providing similar products and services and also enables users with specific needs to acquire their information at appropriate prices. Introducing a “one size fits all? approach may also be anti-competitive where others have already entered high cost/high value markets, and it may unreasonably inhibit more from doing so.

    We are committed to honouring our full obligations as a Trading Fund with delegated authority to protect and exploit Crown Copyright and in so doing we are required to operate on a commercial agenda. We are proud to be accredited under the Information Fair Trader Scheme and are working with OPSI to ensure our licence terms and conditions remain open, transparent and fair.”