Dear Mr Walker

Re: Request for Internal Review

I am writing in response to your email dated 07 July 2009. In your email you requested a review of the decision by Royal Mail to withhold information, under the terms of the Freedom of Information Act. Royal Mail Group's internal review panel has reviewed this decision and I am writing to advise you of their decision. I must apologise for the length of time taken to respond to you in this regard and for any inconvenience that this delay may have caused.

In your request for information dated 29 May 2009 you requested the following information

“…the specification for both the "Tag Code" and the "Route Code" barcodes. By this I mean: details of what data items they contain, how the data items are encoded into the barcode format, etc.”

“Ideally, I would like your answer to my request to describe the "Tag Code" and the "Route Code" barcodes in the same level of detail as you have described the "Customer Barcode (CBC)" and the "RED TAG" barcode.”

The tag code and route code barcodes are orange fluorescent codes that Royal Mail applies to letter mail. There are normally two bar codes printed by Royal Mail in the orange fluorescent ink on the face of letters. The upper row (Tag code) contains data on the machine which first processes the mail item, the day of the month, the 1/2 hr period within the day and the item number within that 1/2 hour period. This data generates a code which is unique within a one month period and enables Royal Mail to associate the delivery information with the correct mail piece during a second stage of processing. The lower row (Route code) contains the delivery Postcode information together with information that represents the actual delivery point.

In relation to “how the data items are encoded into the barcode format” - To decipher the barcodes requires the relevant encoding (and decoding) algorithms which are proprietary to Royal Mail. This information is held by Royal Mail in the form of licensed software. This information was withheld under sections 41(1) and 43(1) - the exemptions for `information provided in confidence' and `commercial interests' respectively. This response should have been issued within 20 working days of receiving your request and I apologise that we failed to comply with section 10(1) of the Act on this occasion.

I can confirm that Royal Mail also holds a detailed code specification document. After reviewing your request, the review panel did not consider that section 41(1) was applicable. However, the panel agreed that the relevant software and specification document constitute a trade secret and are therefore, exempt from disclosure under section 43(1) of the Freedom of Information Act. This is on the basis that disclosure of the information could give an advantage to other postal operators. Royal Mail developed and deployed these mathematical encryption techniques at considerable cost. Other postal operators utilise this concept and suppliers sell solutions in this area. However, these will all differ from Royal Mail's implementation. Our software could therefore benefit competitors in the postal market who do have access to a solution as reliable as that used by Royal Mail.

As you pointed out in your request and your subsequent request for internal review, Royal Mail does publish specification information for Customer Barcodes and RED TAG barcodes. However, it is important to recognise the difference between these and the Tag and Route codes printed by Royal Mail. Royal Mail publishes the specification for these barcodes to enable customers to print barcodes themselves as part of their mailpiece production process. Whilst these codes may look very similar they are much simpler than the fluorescent codes printed by Royal Mail. These barcodes do not require such a sophisticated system as they can be printed with a high quality on a clear background which allows them to be read easily by Royal Mail. The luminescent ink, high performing readers and this special code used by Royal Mail in the Tag and Route codes, allow codes printed on difficult backgrounds to still be read successfully. Consequently, Royal Mail's solution, and the information you have request, would desirable to other postal operators in competition with Royal Mail.

Section 43(1) of the Freedom of Information Act is subject to the `public interest test'. The review panel also considered therefore whether, despite the application of this exemption, the public interest test favours disclosing the requested information. In your request for an Internal Review, you stated that the public interest would be served by the release of this information for two specific reasons:

“…it would allow the public to obtain the date that the letter was sorted by Royal Mail, and hence verify the date on the letter. This would stop companies printing incorrect dates on their letters, and then blaming "delays in the post" when questioned about it.”

“…it would allow the public to obtain the date that a letter was sorted by Royal Mail, and hence calculate how many days it took for Royal Mail to deliver the letter. This would allow for independent calculation of Royal Mail delivery times.”

In relation to the calculation of delivery times, we recognise that there is public interest in the quality of delivery services provided by Royal Mail. However the information recorded in these barcodes documents only the time that the item was first sorted by Royal Mail's machine. This is not a measure of quality of service itself. Royal Mail is regulated by Postcomm and provides detailed quality of service information to monitor performance against service targets agreed by the regulator. This information is published online by Royal Mail. In light of the performance information already published, we do not believe that the requested information would increase openness or the fair measurement of Royal Mail's delivery performance.

In the case of stamped mail items, Royal Mail does print the date that it first handled the mailpiece as part of the cancellation postmark but, this not done for all other mail channels. However, we believe that the legitimate interest in protecting the commercial value of a trade secret outweighs the public interest in disclosure. Royal Mail recognises that this information could be of use in private disputes about the date on which a letter was sent. However, we do not consider that release of this technical information, would inform the public about the effective management or operation of Royal Mail services or in any way increase openness and accountability in public affairs.

I apologise that this response does not provide you with the information you require. As I have stated, it is not possible to provide a means of determining date information included in the fluorescent barcodes without releasing the withheld information. I appreciate that this response may be disappointing but hope that this suitably explains our reasons for withholding information in this case. In the event that you are not satisfied with this reply, you do of course have a right to appeal to the Information Commissioner who can be contacted at:

Information Commissioner's Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Telephone: 01625 545 700

www.informationcommissioner.gov.uk

Cont…

24 September 2009