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.
Geocoded version of Leeds address data: updated
In my previous post, I wrote about the publication by Leeds City Council of a 2024 list of Council Tax bands of all properties in Leeds. This publication of address data followed FOI and re-use requests that I submitted last month.
I also made available for download a version of the Leeds address data that I had geocoded by appending coordinates from the September edition of the ONS UPRN Directory (ONSUD).
For reasons explained below, I have deprecated that release and replaced it with a second version.
You can download v2 of the geocoded dataset: LEEDS_CTBANDS_ONSUD_2024v2.zip (14.6 MB zipped). The download includes the data in CSV and GeoJSON formats.
Like the source data, this geocoded dataset is open data and may be re-used under the terms of the Open Government Licence. Please see the ReadMe file for technical notes on data quality and attribution.
In v2 of the geocoded dataset, coordinates have been appended from the October edition of ONSUD. But the main difference in this version is that the postcode field has also been populated by matching the UPRNs (Unique Property Reference Numbers) to ONSUD – instead of with the postcodes provided last month by Leeds City Council.
Following further correspondence, it appears the Council disclosed that postcode data in error. The latest version of the Leeds source data, published a week ago, includes UPRNs but not postcodes.
OS intervention
The day after I wrote my blog post about Leeds City Council's publication of open address data, and circulated it on social media, the Council received an email from Ordnance Survey:
We note that Leeds City Council have recently published a dataset providing the assigned council tax band of every property in Leeds - Council tax bands of all properties in Leeds | Data Mill North and that this is stated to be published on the terms of the Open Government Licence (OGL). It appears this dataset includes the full address of each property, including the Post Code from Royal Mail's Postcode Address File.
Could you confirm please whether
- You've obtained a specific permission directly from Royal Mail to publish the full postcode for all of these properties?
- Whether any part of the address data you've released has been created or maintained in any way using Address data licensed to you under the terms of your licence agreement with Ordnance Survey under the Public Sector Geospatial Agreement (PSGA).
The reason for these questions is that Address data from OS and Royal Mail is only made available under licence conditions, which does not permit open publication, recognising the various copyright and database rights. OS does make a large number of datasets available as open data on the terms of the OGL (including UPRN which is stated to be not included in your dataset) but not Address data.
Depending on your replies to the above questions we may need to have an urgent follow up discussion please about steps to ensure that the appropriate licence terms are in place and intellectual property rights are preserved.
Council actions
Leeds City Council has not disclosed any reply it made to Ordnance Survey, but the published data file was removed from the Data Mill North site almost immediately, and replaced by an Excel workbook containing the same records but without UPRNs or postcodes.
Shortly afterwards I noticed this change and requested clarification from the Council, in the form of a request for internal review of its handling of my FOI and re-use requests. I included a follow-up request for any information the Council held on its handling of my original requests, including internal and external correspondence.
The Council provided its response last week, which included disclosure of the OS email.
You can download my full correspondence with the Council: MP1N2KH76.zip (0.8 MB zipped). I have redacted names of staff, other than that of the Council's Chief Data Officer.
Internal review response
The gist of the internal review response is that the Council thinks the postcodes were disclosed to me in error but that the other Leeds address data, including the UPRN, is still okay to publish and re-use under the Open Government Licence:
Unfortunately, the Council Tax address database with bandings was published with the postcode under OGL Licensing terms in error. Once we were made aware of this, we immediately removed the UPRN and Postcode fields whilst we had further discussions with Ordnance Survey. Following those discussions with Ordnance Survey we have now re-instated the UPRN, but we are not able to publish the postcode as we do not have permission from Royal Mail.
Publication of the UPRNs has been "agreed with Ordnance Survey".
The Council also says:
Please note that, given the above, your rehosting of the previously disclosed and now replaced dataset may infringe on Royal Mail copyright. We would, as such, recommend that you do not continue to do this.
This is a bit rich, given that the Council only notified its licensing error to me more than a month after it knew about it internally, and only did so because I noticed the file change and sought clarification.
Good news or bad?
Mostly good. While ideally the Council would be able to publish the postcodes as well, the important thing is that this episode demonstrates the feasibility of publishing address data from a local government source without infringing third-party rights.
Inclusion of the UPRN is key. Ordnance Survey claims ownership of UPRNs, but since the introduction of OS's Open Identifiers policy in 2019 public authorities have been allowed to append the identifiers to their own open property data, including address lists.
Having the UPRN with the address enables us to add data from other sources, including from ONS's open UPRN products. In the geocoded dataset available for download above, I have added geographic coordinates, statistical codes – and postcodes. Postcodes have been available in ONS UPRN Directories (ONSUD) and National Statistics UPRN Lookups (NSUL) since 2020.
As the postcodes in ONSUD are sourced from OS's AddressBase, filtered using OS Code-Point Open, they may be slightly more accurate than postcodes in local Council Tax records. In my geocoded version of the Leeds address data, 99.8% of the postcodes sourced from ONSUD are the same as those supplied by the Council (and now removed).
There are gaps, however – 0.9% of the address records have no postcode match in ONSUD. I note that the postcode list used in the latest edition of ONSUD is from the May 2023 version of Code-Point Open, i.e. 17 months old. A further line of inquiry, perhaps.
Next steps
The idea of requiring Government to produce an authoritative open list of UK addresses as maintained by local authorities was floated earlier this year by Tim Clement-Jones and other members of the House of Lords, in a proposed amendment to the Data Protection and Digital Information Bill. That Bill failed, but parts of it are now being revived in the Data (Use and Access) Bill.
The previous Government dismissed this idea as impractical, relying mainly on arguments from Royal Mail and findings from rudimentary exploratory work carried out in 2016 towards an Open Address Register.
As far as I know, there have been no clear signals that the new Labour government will take a more supportive approach than past Tory governments to open addresses, or to open data generally. But it would be nice to see the open addresses amendment raised again for debate as part of the DUA Bill.
In the meantime, I will send FOI and re-use requests for address data to a few other councils, to see whether their responses follow those from Leeds City Council.
Previous posts related to the campaign for open address data in the UK
Open address data published by Leeds City Council shows the way to a national open address file (16 October 2024)
Whatever happened to the UK Government's Open Address Register programme? (1 October 2024)
FOI release: Royal Mail's view on a House of Lords proposal for open address data in the UK (15 August 2024)
Open addresses in the House of Lords – what happened? (28 March 2024)
Thoughts on campaigning for open address data in the UK (30 June 2023)
UK address data: a primer and bibliography (last updated 30 November 2022)