Response to Royal Mail PAF licensing consultation

The Royal Mail’s consultation document, which gives details of the proposals, is available from the Royal Mail website. 

Question 1: Do you agree with the principles underpinning PAF® Licence simplification?

The principles should not include protecting IP or revenue for Royal Mail, instead they should reflect the wider benefits for society and the public interest.

There are some good reasons to make PAF more usable through simplification and modifications to the licenses might be useful. But the proposed changes do not go far enough towards making PAF as widely available and useful as possible.

First, under the currently proposals it is unclear whether exceptions will apply to charities, non-profits and micro- or small businesses. Charities, non-profit organisations and microbusinesses should be exempt.

However, better licensing alone is not good enough.

We maintain that PAF should be available under the OGL or another open license. This is something that has been proposed by the Open Data Users group and the ODI. PAF should be considered part of the National Information Infrastructure (NII), and as such should be seen as a resource that can stimulate competition and economic growth. It measures up when considered against the key NII criteria.

Publishing the PAF under the OGL or another open license will help stimulate competition and growth by lowering entrance costs and making a valuable and useful resource available to more people. If the PAF is not published under the OGL or another open license, then we stress that at the very least charities, micro-businesses and non-profit organisations should be exempt from the licensing.

Currently the position these organisations will find themselves in is not clear, and this needs attention. For micro-businesses the availability of the exemption should not be limited by time but size. Providing an exemption that lasts a year, as is currently outlined, is an arbitrary timeline to give an organisation to establish itself. The licensing framework should be encouraging new entrants to emerge and grow. The threshold should be based on the size of the organisation.

We would like to emphasise that we believe that the PAF should be published as open data under the OGL or other open license, and that exemptions for specific categories of organisation is a far less favourable option.