Owen Boswarva's blog

This is the latest in a series of blog posts about the campaign for open address data in the UK. Previous posts are listed at the bottom.

In this post, I describe a new open address dataset released by Elmbridge Borough Council.

Background

As related in previous posts, I have been requesting Council Tax address datasets from local authorities in England, and asking for permission to re-use the data under the terms of the Open Government Licence.

I have created a landing page on my Datadaptive site with download links and other information about the Council Tax address datasets released as open data so far:

www.datadaptive.com/addr/

Release from Elmbridge Borough Council

The latest council to release its Council Tax address list is Elmbridge Borough Council in the South East region of England.

This case was unusual. Access to the information was straightforward – I submitted my requests in mid-May and the Council disclosed all of the information in early June, without difficulties.

However, I had to chase for a response to my re-use request. In early July the Council's Local Taxation Team advised me that, as Council Tax bands "are set and supplied to billing authorities for the purpose of billing council tax by the Valuation Office, HMRC", I should contact the Valuation Office "for any clarification or enquiries on reuse of their data."

I asked for an internal review. Within a couple of hours I was contacted by another member of staff (with the title of Interim Governance Consultant) who said that they did not accept that I had made a valid re-use request under regulation 6 of the RPSI:

"I consider that your request has not been properly made. Whilst you may consider that you have provided sufficient information, it is not clear to me where this information will be used and how it will be used. Unless the Council can understand how you intend to use the information it cannot assess if the Open Licence is appropriate, whether some other licence is appropriate and whether additional conditions have to be applied by virtue of Regulation 12.

"I would suggest that you outline what your business purpose is and provide links to where you have published other local authority information, and at that point the Council may accept this is a valid request."

We went back and forth in emails for a while, but the upshot was that the Council would not accept my re-use request as originally submitted or handle my complaint.

At the end of July I made a complaint to the ICO, as regulatory authority for the RPSI regulations.

The ICO wrote to the Council at the start of September, asking the Council to respond to my request. However, the Council evidently maintained its position. The ICO told me:

"After we issued our regulation 8 letter to the Council, it replied to us to confirm that it still did not believe your RPSI request was valid. We have since explained why we consider the request valid, however the Council is maintaining its position."

The ICO's had some internal discussions and, early this month, asked the Council again to provide a response to me. The ICO said that if the Council did not do so it would issue a decision notice ordering compliance.

Yesterday the Council emailed me to say it had reconsidered its position, and that the information in the disclosed Council Tax property list could be re-used subject to the terms of the Open Government Licence v3:

"The Council has reconsidered its position and now accepts that you have made a valid application. The information supplied to you in response to this FOI request (2998 -the current list of assigned Council Tax band of every domestic property in Elmbridge Borough Council area) can be reused subject to the Open Government Licence v3."

You can download my correspondence with the Council: CT_address_list_Elmbridge_00002998_[NO_DATA_correspondence_only].zip (1.77 MB).

Thanks to staff at the Council and at the ICO for facilitating the disclosure and open licensing of this data.

Access to this dataset

I am not publishing Elmbridge Borough Council's address dataset here, due to the non-specific but lingering risk of further unsubstantiated claims of infringement from Ordnance Survey and GeoPlace LLP. You can read more about that issue in my blog post from May.

However, there is nothing to stop you asking the Council directly for a copy of the data file. For tips on submitting access to information and re-use requests see this other blog post. My requests to Elmbridge Borough Council were submitted on 18 May 2026 and the Council's reference is /00002998.

More about Elmbridge Borough Council's address dataset

Elmbridge Borough Council has disclosed its Council Tax address dataset to me in the form of an Excel workbook '00002998 Ctax Bands.xlsx' that contains 60,579 records. Each record includes the full address (in four fields), postcode, Council Tax band, local property reference, and Unique Property Reference Number (UPRN) for a domestic property in the Elmbridge Borough Council area.

The information in the list seems well-maintained, with few missing UPRNs. It was possible to match all but 19 of the 60,579 records in the Council Tax list to records in the September 2026 release of Ordnance Survey's OS Open UPRN product. This means nearly all of the property records in the dataset can be geocoded for mapping and geographic analysis of domestic properties in the Elmbridge Borough Council area.