Postbox Data in Central Collections Management Database

Dear Royal Mail Group,

In response to FOI requests, you have previously supplied data on
postboxes, including their location descriptions, postcodes, and
collection times. From your reply to my recent FOI request [1] I
believe that this information has been taken from your "Final Plate
Database". Analysis I've done with this data indicates there are a
number of missing and/or duplicated boxes in this data, as well as
other errors.

However, your reply to my request [1] suggests that there may be
similar information on postboxes contained within your "Central
Collections Management Database". If this is used to record actual
collections, I'm thinking that the data that it contains may well
be more accurate.

I'd therefore like to know whether your "Central Collections
Management Database" does include information about each postbox,
and exactly what information about each box is stored there.

If it does, I would like an extract from this database listing each
postbox, with whatever of the following is held there: it's number,
location description, postcode, and last collection times. For each
box, I'd also like whatever location coordinates / data is used to
calculate the "Position of Box on an electronic map" (as mentioned
in your reply to [1]).

I would like this postbox data in electronic form, in a format
allows it to be easily parsed programmatically. My preferred format
would be 'tab-separated values' (TSV), but any other delimited
plain text format, or even an MS Excel spreadsheet would be
acceptable. What I want to avoid is the data being in a PDF file
that's only any good for viewing and printing.

Many thanks,

Robert Whittaker

[1] FOI Request for "Information on Postbox Data" -- full
correspondence available at
http://www.whatdotheyknow.com/request/in...

Dear Royal Mail Group,

Thank you for your reply, but I'm afraid I must request an internal
review of your decision to withhold the postbox list and location
data. When conducting the review, please consider the following
points:

* It is appropriate to apply the "commercial interests" exemption
to information relating to post-box provision.

The ICO document "Freedom of Information Act Awareness Guidance No
5" [1] states that "Where a company enjoys a monopoly over the
provision of the goods or services in question it is less likely
that releasing the information will have a prejudicial impact on
that company." In the case of posting boxes, Royal Mail has an
effective monopoly on their provision in most parts of the country.
It is also hard to see how some outdated information about postbox
locations is likely to lead to an actual loss of business for Royal
Mail.

* Concern about datedness and misunderstandings of the released
data itself can be eliminated by Royal Mail

If Royal Mail is worried about the information released being
misinterpreted or mis-used by primary users, then it can ensure
that it is presented in an appropriate fashion, with whatever
warnings and caveats deemed necessary. Any worries about it
becoming out of date can be addressed by ensuring the information
is dated. Royal Mail is of course free to supply updated copies as
and when they feel it would be appropriate.

* It is inappropriate to apply the exemption relating to possible
downstream mis-use of the data.

Supplying information under the Freedom of Information Act does not
require the public authority to relinquish any copyright or
database rights they have in the information. In this particular
case, the Royal Mail's database right would protect the data from
being copied and distributed outside of Royal Mail's control. I
therefore do not feel that it is appropriate to apply the exemption
to how the information may be mis-used by third parties once it has
been published. A restriction could easily be imposed Royal Mail
that any downstream users must make it clear that the data is their
responsibility, not Royal Mail's.

* Releasing the data will actually improve the quality of publicly
available information in relation to post-box locations

Postbox locations are already being recorded in two crowd-sourced
open-data projects [2,3], which between them have locations stored
for around 1/3 of all Royal Mail boxes. Some of those locations are
likely to be inaccurate / outdated, so the public may already be
being misled. I am sure that both these projects will use any
additional data responsibly, to ensure that it improves the
accuracy of their existing offerings. These offering will continue
whether or not you provide the data, but will be more inaccurate
without it.

In particular, OpenStreetMap will not be able to import the
lat/long positions of boxes directly, as they would be tainted by
Royal Mail' Database rights, and possibly Ordnance Survey IP rights
too. Instead, the new location data would be used to identify boxes
that are missing from the map or may be inaccurately mapped, in
order to allow mappers to conduct their own survey.

Therefore the released data will actually be used to improve the
quality of publicly available information in relation to post-box
locations, rather than simply providing a single imperfect source.
Therefore if Royal Mail's commercial interests are affected in any
way by the release of this data -- as claimed by Royal Mail -- then
it will in fact be to help them.

* Relationship to previous requests

There have been several previous requests for information relating
to postbox locations and information. Royal Mail has had no problem
supplying the information previously (despite it containing
numerous errors and omissions), though precise location details
were not included then. I therefore assume that it is only the
location coordinates that are causing the problem this time. That
being the case, I would ask for immediate disclosure of the
remaining information on each postbox in the Central Collections
Database, or an explanation of which FOI exemption applies to this
data that did not apply previously.

To pre-empt a possible argument that the data is already available
from the Final Plate Database [4], I would point to the various
errors and duplicates in that data. I would specifically like to
know about the information stored in the Collections Management
Database, in order to compare it with that from the Final Plate
Database. Unless you can certify that the two datasets are
identical, there is information in the former that is not contained
in the latter.

Regards,

Robert Whittaker

PS: I also note in passing that Royal Mail has previously denied
holding any coordinate location data for postboxes [5], and has not
mentioned the existence of this data in follow-up requests for
up-to-date copies of that data. It is rather annoying to now find
that such data does now indeed exist. If the coordinate data
existed at the time of the original request [5], then Royal Mail
provided an inaccurate response, and I hope they will now be
offering a formal apology for their error.

[1]
http://www.ico.gov.uk/upload/documents/l...
[2] OpenStreetMap: http://www.openstreetmap.org/
[3] Dracos Postbox Locator:
http://www.dracos.co.uk/play/locating-po...
[4] http://www.whatdotheyknow.com/request/po...
[5]
http://www.whatdotheyknow.com/request/lo...