Income and Expenditure for PAF and PostZon datasets

Dear Sir or Madam,

Under the Freedom of Information Act, I would like to obtain
information about the costs to the Royal Mail of maintaining the
Postcode Address File (PAF) and the geographic coordinates of each
code as contained in the PostZon product.

I would like a detailed breakdown of the annual costs to maintain
both sets of data (ideally separated between the two) for a
suitable recent period. Where staffing costs are included, I would
like descriptions of the activities/roles involved and the numbers
of staff assigned to each. Where computing/IT costs are included I
would like a breakdown in terms of capital expenditure, software
licenses, consultancy fees, etc.

I would also like details of the income generated from these data
sets over the same period, from selling licences and any other
sources.

Additionally, I would like to know if the data in these two
datasets is all generated by the work of Royal Mail employees, or
if some of it is supplied by outside bodies. If the latter, then
does Royal Mail have to pay for any of the provision, and under
what licensing terms is the data supplied? Are either the costs or
licensing terms here regulated by legislation?

Many thanks for your help,

Robert J Whittaker

Dear Sir or Madam,

I am writing in relation to my request under the Freedom of
Information Act of 15 October 2009, entitled 'Income and
Expenditure for PAF and PostZon datasets'.

Please pass this message on to the person who answered my original
request and also to the person who conducts Freedom of Information
reviews.

A full history of my FOI request and all correspondence is
available on the Internet at this address:
http://www.whatdotheyknow.com/request/in...

The way I read the response I received today, it appears to be
justifying with-holding the data contained in the PAF and PostZone
products themselves. This was not what I was asking for -- as you
would see by re-reading my request. I was instead asking for
information about the costs and processes of maintaining these
data-sets.

The Royal mail has to maintain these sets by law, and it would not
be commercially viable for anyone else to attempt to maintain a
competing dataset. There is therefore little (if any) commercial
value in knowing the costs involved. Since the maintenance involves
the expenditure of public money, it is very much in the public
interest for this information to be released. It is also essential
to know the costs involved in maintaining the datasets, in order to
judge whether the license fees charged by Royal Mail are in fact
'reasonable' -- as required by legislation.

I understand that some outline costs from a previous year are
already available, having been presented in a PostComm report. At
the very least your reply should have included those.

I therefore do not regard your current reply as an adequate
response under the Freedom of Information Act: it does not appear
address the question I asked, and does not provide sufficient
justification for not disclosing the information requested. Since
this appears to have been caused by a failure on your part to read
the original request properly, I do not expect to have to wait more
than a couple of days for a proper response to my original request.
(You have already used up all of the 20 days allowed under the
Act.)

If you are able to provide a proper reply in this timespan, there
will be no need for a formal internal review at this point. If you
are unable to do so, then I must request a full internal review.
Please re-consider your justification for withholding the
information, and also why you failed to tell me about partial
information that it already in the public domain. If a public
interest test is to be applied, I believe it should be applied to
each element of my request individually, and also to any redacted
or summary data that it may be possible to compile.

Yours faithfully,

Robert Whittaker

Dear Royal Mail Group,

By my calculation, you have now taken more than twenty working days
considering the "internal review" of your response to my original
request. Perhaps you could let me know why things are taking so
long, and when I might expect to receive a full reply.

Yours faithfully,

Robert Whittaker

Dear Royal Mail Group,

I believe that it has now been 40 working days since you
acknowledged my request for an internal review. In that
acknowledgement you stated that your reply would "usually be within
20 working days and in any case no later than 40 days from receipt
of the appeal." I have heard nothing from you since then.

If I don't receive a response from you by the end of this week, I'm
afraid I shall be forced to refer this matter to the Information
Commissioner.

Yours faithfully,

Robert Whittaker

Dear Royal Mail Group,

I am afraid I am still not satisfied with your reply. I am prepared
to give you another week to reconsider your position. Unless
further information (or a promise thereof) is forthcoming in that
time, I shall be writing to the Information Commissioner.

The financial breakdown for the PAF product you have provided can
hardly be called "detailed". The details of precisely what comes
under each heading and how the amount breaks down between those
items, have not been given. I'm afraid I don't see any
justification in your reply for withholding further the detail
here.

In the case of the IT costs, you say that further breakdown cannot
be provided as it is "an allocated figure from the Royal Mail IT
Group programme". I find this a little odd, as the PAF activities
are supposed to be ring-fenced. But that being the case, I would
have thought it obvious that you should instead provide the
basis/justification for this allocation, and details of the
equipment / services actually used in PAF maintenance activities.

As regards data sources, I can understand (though don't agree with)
your reluctance to go in the details of the contract terms.
However, given my original request, I believe you should at least
provide me with a list of suppliers for the PAF data, and the
nature of the data that each one supplies. You have also failed to
answer my question as to whether any of this supply is regulated by
legislation.

Finally, when considering the public interest test, your reply
fails to make any mention of the public interest in favour of
disclosure, including transparency and accountability. I accept
that there is some interest in withholding some of the information,
but by not considering the case in favour of disclosure at all, I
believe you have failed to properly apply the public interest test.

While the AMU may be self-funding, any profit or loss will be
transferred to Royal Mail Group, making it very much public money
that is being spent / received. I would guess that a significant
amount of PAF income comes from other public bodies, and that which
doesn't will still come from the public in the end, who pay for
services from PAF-using businesses. There is therefore a strong
public interest in the transparency and accountability of the Royal
Mail's PAF maintenance activities.

Yours faithfully,

Robert Whittaker

Dear Royal Mail Group,

Thank you very much for the information you have now provided.
However, I am still not completely happy with your response.

I do not agree with your assessment that "a breakdown of the AMU's
revenue by customer, sector or product type" is "commercially
sensitive" and the balance of public interest is against
disclosure. However I accept this is your assessment, and so will
be taking this point to the Information Commissioner.

On many of the other matters, I still don't believe you have gone
far enough either in providing the requested information or
providing a proper justification for with-holding it.

You claim that many of the AMU's costs are the result of
outsourcing, and so refuse to disclose any further details. In this
case, I would expect a detailed list of exactly what services are
outsourced (and to whom) and also details of the costs of items
that are not outsourced.

With respect to the IT costs, I'm afraid your most recent answer in
no way addresses my question. It was already obvious from your
previous answer that the IT cost would be somehow "based on the
proportion of Royal Mail's total costs which the AMU's activity
accounts for". What I am after is details of the basis on which
this is worked out. So I presumably require the total IT costs to
the whole Royal Mail Group, and the details and amounts in the
calculation that determines the percentage allocation.

You have also not provided the information I was after concerning
the "details of the equipment / services actually used in PAF
maintenance activities" -- I was looking for a list of hardware,
software licenses, and service provision that would justify the
claimed expenditure. Apologies if I was unclear here. Given that
the IT costs have apparently increased by 70% in the last three
years, it is clearly in the public interest to ensure that the
amount AMU is charged for these accurately reflects the actual
costs, and this information is required in order to do so.

With respect to those supplying the data used in the PAF, you have
provided a list of suppliers, but not described the precise nature
of the data supplied by each, nor whether it is supplied under
contract and/or in return for any payment. This could clearly be
done without disclosing the details of the contract terms or
payment amounts, which appears to be the only justification you
have offered for not disclosing this information. For providers who
are themselves public bodies and have a monopoly on the data
supplied, I see no reason on commercial grounds for not disclosing
further details of the contracts and payments.

Yours faithfully,

Robert Whittaker