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...