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The Data Protection and Digital Information Bill is currently wending its way through the House of Lords. Yesterday's third day of committee debate included a brief discussion of amendment number 252, a proposal to require the UK Government to regularly publish a list of UK addresses as open data to an approved data standard:

Amendment text

After Clause 142

insert the following new Clause—

"Open address file

(1) The Secretary of State must regularly publish a list of UK addresses as open data to an approved data standard.

(2) "Regularly publish" means on at least a monthly basis.

(3) "UK addresses" means an authoritative list of UK address data as maintained by local authorities including, but not limited to —

(a) building number, name and street address,

(b) geographic coordinates, and

(4) "Open data" means data under a licence whereby any person can freely access, use, modify, and share the data for any purpose, subject, at most, to requirements that preserve provenance and openness.

(5) "Approved data standard" means such written standards, containing technical specifications or other requirements in relation to the data, or in relation to providing or processing the data, as may be published by an appropriate authority from time to time."

Member's explanatory statement

This amendment would require a list of UK addresses to be made freely available for reuse.

Debate on this amendment was mixed up with a lot of back and forth on other amendments to the Bill. I have picked out the relevant contributions and reproduced them below.

Amendment 252 was moved by Lord Clement-Jones (Timothy Francis Clement-Jones, Liberal Democrats):

Amendment 252 would require a list of UK addresses to be made freely available for reuse. Addresses have been identified as a fundamental geospatial dataset by the UN and a high-value dataset by the EU. Address data is used by tens of thousands of UK businesses, including for delivery services and navigation software. Crucially, address data can join together different property-related data, such as energy performance certificates or Land Registry records, without using personal information. This increases the value of other high-value public data.

Addresses are no longer just about sending letters; they are crucial spatial data infrastructure used by tens of thousands of UK businesses. Reliable address data is important for navigation software, such as TomTom or Waze, and successful service provision such as Amazon deliveries. Control of the UK's addresses was sold to Royal Mail when it was privatised in 2013. There is now a complex system for generating and managing UK addresses, where most of the work is done by local authorities but most of the benefits flow to Royal Mail.

If you are in the public sector, you can access address data for free because the Government pay Royal Mail and Ordnance Survey millions of pounds per year for public sector access. If you are a business, however, you have to pay for access, sign licensing agreements and potentially hire lawyers. This is especially burdensome for start-ups and SMEs. The previous Government created the Geospatial Commission to unlock the value of geospatial data, but it has not yet evaluated the arrangements with Royal Mail. The process of creating and managing addresses is slow and complex, with multiple bodies involved.

This all causes a number of problems: it holds back growth and innovation, it holds back emerging technology, it hinders public service delivery, it causes problems for citizens and, increasingly, it makes the UK an outlier among high-income countries. As a result, our address data is expensive, hard to access and unreliable. The Government need to act now to provide a dataset of all UK addresses that is accurate and can be freely used by anyone offering services to UK citizens. This could be implemented by establishing a new body to manage address data or by mandating that Royal Mail makes the data openly available.

Unlike opening up more sensitive datasets, such as personal location, releasing address data—a list of the physical places recognised by the Government—carries few new legal or ethical risks. Many other countries are doing this, including those with a strong privacy regime. The harms created by the lack of access to address data are more pressing. I offer the Netherlands as a good example of somewhere that has already been through this process.

I am grateful for the support of the noble Baroness, Lady Bennett, for this particular amendment, alongside another noble Lord who no doubt will reveal themself when I finally find my way through this list of amendments. In the meantime, I beg to move.

The amendment was supported by Baroness Bennett of Manor Castle (Natalie Bennett, Green Party):

My Lords, I rise with the advantage over the noble Lord, Lord Clement-Jones, in that I will speak to only one amendment in this group; I therefore have the right page in front of me and can note that I will speak to Amendment 252, tabled by the noble Lord, Lord Clement-Jones, and signed by me and the noble Lords, Lord Watson of Wyre Forest and Lord Maude of Horsham.

I apologise that I was not with the Committee earlier today, but I was chairing a meeting about the microbiome, which was curiously related to this Committee. One issue that came up in that meeting was data and data management and the great uncertainties that remain. For example, if a part of your microbiome is sampled and the data is put into a database, who owns that data about your microbiome? In fact, there is no legal framework at the moment to cover this. There is a legal framework about your genome, but not your microbiome. That is a useful illustration of how fast this whole area is moving and how fast technology, science and society are changing. I will actually say that I do not blame the Government for the fact of this gaping hole as it is an international hole. It is a demonstration of how we need to race to catch up as legislators and regulators to deal with the problem.

This relates to Amendment 252 in the sense that perhaps this is an issue that has arisen over time, kind of accidentally. However, I want to credit a number of campaigners, among them James O'Malley, who was the man who draw my attention to this issue, as well as Peter Wells, Anna Powell-Smith and Hadley Beeman. They are people who have seen a really simple and basic problem in the way that regulation is working and are reaching out including, I am sure, to many noble Lords in this Committee. This is a great demonstration of how campaigning has at least gone part of the way to working. I very much hope that, if not today, then some time soon, we can see this working.

What we are talking about here, as the noble Lord, Lord Clement-Jones, said, is the postal address file. It is held as a piece of private property by Royal Mail. It is important to stress that this is not people’s private information or who lives at what address; it is about where the address is. As the noble Lord, Lord Clement-Jones, set out, all kinds of companies have to pay Royal Mail to have access to this basic information about society, basic information that is assembled by society, for society.

The noble Lord mentioned Amazon having to pay for the file. I must admit that I feel absolutely no sympathy there. I am no fan of the great parasite. It is an interesting contrast to think of Amazon paying, but also to think of an innovative new start-up company, which wants to be able to access and reach people to deliver things to their homes. For this company, the cost of acquiring this file could be prohibitive. It could stop it getting started and competing against Amazon.

Baroness Harding of Winscombe (Dido Harding, Conservative Party) also spoke to the amendment:

The second amendment that I speak to is Amendment 252, on the open address file. I will not bore noble Lords with my endless stories about the use of the address file during Covid, but I lived through and experienced the challenges of this. I highlight an important phrase in the amendment. Proposed new subsection (1) says:

"The Secretary of State must regularly publish a list of UK addresses as open data to an approved data standard".

One reason why it is a problem for this address data to be held by an independent private company is that the quality of the data is not good enough. That is a real problem if you are trying to deliver a national service, whether in the public sector or the private sector. If the data quality is not good enough, it leaves us substantially poorer as a country. This is a fundamental asset for the country and a fundamental building block of our geolocation data, as the noble Lord, Lord Clement-Jones, set out. Anybody who has tried to build a service that delivers things to human beings in the physical world knows that errors in the database can cause huge problems. It might not feel like a huge problem if it concerns your latest Amazon delivery but, if it concerns the urgent dispatch of an ambulance, it is life and death. Maintaining the accuracy of the data and holding it close as a national asset is therefore hugely important, which is why I lend my support to this amendment.

Lord Bassam of Brighton (Steve Bassam, Labour Party) commented:

We have an open mind on Amendment 252 because there is a balance to be struck between privacy issues and the need to ensure that service delivery and commercial activity operate on a level playing field. I listened to the passionate argument made by the noble Lord, Lord Clement-Jones, and the noble Baroness, Lady Harding, also made some powerful points on this, but I would like to hear what the Minister has to say because we need to get this right as well. We cannot have a situation where one part of the public service is holding up or getting wrong public service delivery and the operation of physical delivery services to our homes and households. With that, I am content to let the Minister have his say. I hope he gets all our names right.

Viscount Camrose (Jonathan William Berry, Conservative Party), who is a minister in the Department for Science, Innovation and Technology, responded for the Government:

Finally, Amendment 252 would place a legislative obligation on the Secretary of State regularly to publish address data maintained by local authorities under open terms–that is, accessible by anyone for any purpose and for free. High-quality, authoritative address data for the UK is currently used by more than 50,000 public and private sector organisations, which demonstrates that current licensing arrangements are not prohibitive. This data is already accessible for a reasonable fee from local authorities and Royal Mail, with prices starting at 1.68p per address or £95 for national coverage.

Baroness Bennett asked:

Some 50,000 organisations access that information, but does the Government have any data on it? I am not asking for it now, but maybe the Minister could go away and have a look at this. We have heard that other countries have opened up this data. Are they seeing an increase? That is just a number; it does not tell us how many people are denied access to the data.

Viscount Camrose continued:

We have some numbers that I will come to, but I am very happy to share deeper analysis of that with all noble Lords.

There is also free access to this data for developers to innovate in the market. The Government also make this data available for free at the point of use to more than 6,000 public sector organisations, as well as postcode, unique identifier and location data available under open terms. The Government explored opening address data in 2016. At that time, it became clear that the Government would have to pay to make this data available openly or to recreate it. That was previously attempted, and the resulting dataset had, I am afraid, critical quality issues. As such, it was determined at that time that the changes would result in significant additional cost to taxpayers and represent low value for money, given the current widespread accessibility of the data. For the reasons I have set out, I hope that the noble Lords will withdraw their amendments.

Lord Clement-Jones said further:

I come back to the open address issue, I am grateful for what the noble Baronesses, Lady Bennett and Lady Harding, had to say on this subject. The noble Baroness, Lady Bennett, was absolutely right to credit the PAF campaigners for their work on this matter. There are many different ways in which the Government can do this–as the noble Baroness said, we are not predicating exactly how they will go about it–so it was rather disappointing to hear what the Minister had to say, given that the Government extol the virtues of data and growth being linked. This is a clear example of where growth and business are being held back. It sounds as though the Government do not want to take on the cost of making sure that this data is freely available; that could be the bottom line here. I am sure that they will keep up the pressure to find a solution in this area; I very much hope that they will do that. In the meantime, I beg leave to withdraw Amendment 74.

A few comments from me:

I assume Amendment 252 has now been withdrawn, although I cannot actually see that in the Hansard account. If so, that doesn't come as any surprise – backbench amendments that do not have the support of the Government or the Opposition front bench do not generally make it out of committee. The main benefit of an amendment like this is that it builds awareness of the issue – in this case, the open data community's longstanding campaign to unlock open addresses for the UK.
Many of the points in the above debate concern Royal Mail's Postcode Address File (PAF) in particular. However, it's worth noting that the amendment itself does not mention the PAF. Releasing PAF as open data would not fulfill the minimum requirements of the proposal, as PAF is not a full list of UK addresses and does not contain geographic coordinates (or the UPRN, an identifier required to link addresses to existing open coordinate data).
The Government's response is the usual stuff. See my June 2023 post for more detailed coverage of the issues underlying the campaign for open addresses.