Owen Boswarva's blog

This is the latest in an occasional 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 highlight an email and guidance note sent to me this week on behalf of Ordnance Survey and GeoPlace LLP.

I recommend reading this material if you plan to make any significant re-use of the open address datasets listed at www.datadaptive.com/addr/.

Background

Ordnance Survey (OS) is the national mapping agency for Great Britain. GeoPlace LLP is a public partnership, majority controlled by OS, that oversees the production and maintenance of national address and street gazetteers based on inputs from UK local authorities.

OS markets a range of data products on commercial terms including AddressBase, a geocoded product that combines Royal Mail postal addresses with identifiers called Unique Property Reference Numbers (UPRNs). OS also supplies AddressBase to local authorities and other public bodies under the centrally funded Public Sector Geospatial Agreement.

As described in previous posts, I have recently been requesting Council Tax address datasets from a number of local authorities, mainly 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/

Currently 34 local authorities in England, and one in Wales, have released their Council Tax lists under the OGL.

Email from Legal Services at Ordnance Survey

Last month I sent a request to OS and GeoPlace for permission to re-use a list of UPRNs that had been disclosed by City of Edinburgh Council. Yesterday I received a reply from a solicitor in Legal Services at Ordnance Survey, on behalf of both OS and GeoPlace.

You can read the email: 20260122 EMF OS re open CT lists.pdf (280 KB)

(Please disregard the subject line; the OS email deals only briefly with my re-use request. I have redacted the content of my request email, as my correspondence with Edinburgh is ongoing.)

Most of the email sets out the position of Ordnance Survey and GeoPlace with regard to "the large number of FOI requests for Council Tax data, including addresses and UPRNs" and in particular the open datasets listed on my Datadaptive page. The email says, "We have also consulted, and obtained approval from, the Department for Science, Innovation and Technology (DSIT), on the content of this response."

Key points in the OS/GeoPlace position

OS thinks most Council Tax address datasets will contain third-party IP that the local authority isn't entitled to license under the OGL:

"Our working assumption is that the vast majority of Council tax address datasets will contain the intellectual property rights of Ordnance Survey, GeoPlace and Royal Mail. This will certainly be the case where the Local Authority has an integrated address management system, with the Local Land and Property (LLPG) at the centre, since LLPGs were created, and are updated and maintained, using data from Ordnance Survey, GeoPlace (since its creation in 2011) and Royal Mail, under the PSGA, and its predecessor agreements going back to at least the early 2000s."

But a "small number" of Council Tax address lists may be Authority Owned Data:

"Having said that, we do of course acknowledge that there may be a small number of Local Authorities that have address lists which are comprised wholly of Authority Owned Data. … Whether address data is Authority Owned Data is a decision for each Local Authority to make; the Authority would need to be confident that it has created/maintained all the house names, numbers, street names and localities without any reference to address data licensed through the PSGA Member Licence (or a previous agreement) or data supplied to the Local Authority under the DCA.

The dataset published by Leeds City Council in 2024 is one such exception:

"We expect that Leeds is likely to be the exception rather than the rule in this respect. We have not had such conversations with other Local Authorities, and unfortunately suspect that a significant number of those who have disclosed addresses following the FOI request may have done so in error."

OS/GeoPlace will be making inquiries with local authorities that have released their Council Tax lists as open data:

Separately, Ordnance Survey/GeoPlace will be following up individually with all the Local Authorities who have released their Council Tax addresses, as listed on datadaptive.com, to ensure that they understand the intellectual property and licensing position, and have not released the data in error.

Guidance for local authorities on KHub

The OS solicitor has also provided a copy of guidance for local authorities in England and Wales on handling FOI requests for Council Tax lists: Addressing FOIs - Guidance and Reactive Comms - 22.1.26.pdf (113 KB)

This document appears to combine guidance distributed previously to local authorities via a private forum on KHub with additional draft guidance on actions to take if they have mistakenly disclosed address data:

Indeed, following the publication of guidance by GeoPlace in relation to the FOI for Council Tax data (see attached document, for your information), a number of Local Authorities contacted GeoPlace/OrdnanceSurvey acknowledging their mistaken disclosure, and requesting guidance as to what they should do now. OS and GeoPlace has now drafted further guidance on this point (see the same attached document, for your information).

Most of the guidance consists of blocks of standard text that local authorities can copy and paste into their communications with requesters.

Comments

Nothing in the email and guidance from OS and GeoPlace changes my current understanding of the licensing status of any of the Council Tax datasets listed on my Datadaptive page. OS and GeoPlace have not communicated any specific claims of IP infringement. So far, none of the listed local authorities have contacted me to withdraw OGL permission or tell me that the disclosed information contains third-party rights that the authority did not have permission to license.

I will update the information at www.datadaptive.com/addr/ and in the relevant blog posts if I receive any correspondence that changes my understanding of any licensing positions.

All of my re-use requests for Council Tax address datasets included the following:

If any third party owns intellectual property rights in any of the above requested information, which the Council is not authorised to license as requested, please specify the relevant information and the name of the third party.

It is not clear how OS and GeoPlace have formed their "working assumption" that the vast majority of Council tax address datasets contain their intellectual property, given that the email says they have not had discussions with other authorities similar to that with Leeds City Council.

My own impression is that local authorities quite commonly maintain their Council Tax property lists separately from their LLPGs – that's one of the reasons I have focused my requests on Council Tax lists rather than LLPG records. I am not a licensee of AddressBase or Royal Mail's Postcode Address File myself, so am not in a position to make detailed comparisons, but the quality of the address data in the Council Tax datasets that have been disclosed to me seems quite variable.

The guidance issued to local authorities is very one-sided in favour of the commercial interests of Ordnance Survey and GeoPlace, and does not leave much space for authorities who may not be well-versed in intellectual property issues to make their own judgements on handling of FOI and re-use requests for Council Tax address data. I am concerned that some local authorities may be intimidated by the language of the guidance into following the OS/GeoPlace line because they are reliant on OS/GeoPlace to provide expert advice and guidance on address data and licensing.

This attempt to second-guess the decisions of dozens of UK local authorities, who have unlocked a total of more than six million open address records over the past year, highlights the fundamental conflict between the commercial interests of OS and GeoPlace and their responsibilities, as public bodies, for the stewardship of the nation's address data infrastructure.

Further reading

If some of the terms and references in the above are unclear, you may wish to review GeoPlace's Data Co-operation Agreement. Under the DCA local authorities effectively lose control of how they can share their own address data, if they use AddressBase to cleanse or correct that data or otherwise mix it up with the IP of OS/GeoPlace and other third parties.

Previous posts related to the campaign for open address data in the UK

Newham Council has released its Council Tax address list as open data (22 January 2025)

Somerset Council has released its Council Tax address list as open data (21 January 2025)

Rhondda Cynon Taf has released its Council Tax address list as open data (9 January 2025)

Royal Borough of Greenwich has released its Council Tax address list as open data (9 January 2025)

Ealing Council has released its Council Tax address list as open data (8 January 2025)

Isle of Wight Council has released its Council Tax address list as open data (6 January 2025)

Northumberland County Council has released its Council Tax address list as open data (6 January 2025)

Newcastle City Council has released its Council Tax address list as open data (31 December 2025)

Plymouth City Council has released its Council Tax address list as open data (23 December 2025)

Stockport Metropolitan Borough Council has released its Council Tax address list as open data (22 December 2025)

Southwark Council has released its Council Tax address list as open data (19 December 2025)