The Co-op’s response to the Government consultation on Land Registry – a follow up

At the Co-op, we’re passionate about how we use data for the good of our members, and believe that, more broadly, the UK economy stands to benefit from new services that are built on data.

That’s why in May we published our concerns about the Government’s proposals to move Land Registry operations to the private sector. We weren’t alone, with 65 MPs from all sides of the House of Commons joining David Lammy in urging the government to reconsider its plans.

So it’s a good signal that there was no mention of plans in the Neighbourhood Planning and Infrastructure Bill that went before the Commons at the end of last week.

Let’s hope that the government has listened to all those who share our view that a commitment to open data has the potential to stimulate growth, ingenuity and innovation which are vital to the Co-op’s Rebuild and the future success of the 21st century British economy.

It’s important to us that our members voices are heard in policy debates, and that’s why we’re working on a way to make that easier in the future.

Mike Bracken
Chief Digital Officer

Paul Morris is moving on

I’d like to say a big thanks to Paul, who has helped create a great digital team here at the Co-op. He and his team have pioneered much of our work on social, design and digital marketing. Much of our reputation for specialist digital marketing is down to his enthusiasm and hard work.
Picture of Paul Morris
Paul Morris
Paul played an important part in the Co-ops recent history, giving us the foundation of a digital team in Manchester and supporting all our businesses online.

He’s off to take a global position, one which we couldn’t match. Not only do we wish him the best, but as a model co-operator we hope to work with him again.

Thanks Paul.

Mike Bracken
Chief Digital Officer

Appointment of Chief Membership Officer

We’re delighted to let you know that Rufus Olins will be joining us in October as Chief Membership Officer. This is a new role created on the Group Executive to develop and deliver our new Membership.

With just a few weeks until we launch new Membership to our members there really couldn’t be a more important time to make sure we’re all focused on delivering an engaging, compelling and unique membership offer. Having Rufus in the team will help us achieve this.

Rufus is currently Chief Executive of Newsworks where he has been leading the transformation of that organisation into a digitally enabled membership body representing an important part of our daily lives.

Rufus has also been a senior business correspondent at the Sunday Times, Editor of Management Today and run a series of businesses.

Rufus will work closely with the Member Council to ensure that their role as guardians of Co-operative values and principles is properly reflected in our Membership activities. Russell Gill will report to Rufus, who will also take sponsorship of the Meaningful Membership programme as Alyson Chadwick transitions this into our businesses.

Rufus will have responsibility on the Group Executive for the Communications, Public Affairs and Policy activities overseen by Jon Church and Paul Gerrard, and work closely with the Marketing teams.

He will report to Mike, with a dotted-line to Richard. We’re also recruiting a Digital Membership Services Director, who will work with Rufus, and together these two roles will cover all our Membership activity beyond the governance aspects dealt with through our Group and Council Secretariats.

Welcome Rufus.

Richard Pennycook
Group Chief Executive

Mike Bracken
Chief Digital Officer


Gender diversity at conferences & events

There’s not enough women working in digital. Without gender-balanced teams digital services and platforms will be less diverse, inclusive, and not as good as they could be. Mike Bracken our Chief Digital Officer reminded us of many other good reasons to make sure that we address the gender imbalance when we screened CodeGirl at 1 Angel Square in February.

Picture of the panel at the recent Ladies that UX event held at 1 Angel Square

Conferences and events are a great way to share knowledge, but too often they’re dominated by all male speakers. By not trying harder to hear from women who are experts we won’t ever be able to fix the gender imbalance in the digital industry.

This is why we signed up to Owen Barder’s pledge along with Design Manchester for DM16, and is why in future no one from CoopDigital will speak at events or be part of panel discussions of two or more people unless there is at least one woman speaking or part of the panel, not including the chair. We’ll make sure that we do exactly the same for events that we hold both internally and externally as well.

Gail Lyon

We’re currently looking to recruit talented digital engineers/developers to support the growth of our unique business. We need people at all levels, with all kinds of skills and experience. If you’d like to be part of our digital revolution, find out more here.

Emer Coleman joins CoopDigital

Emer Coleman joined CoopDigital this week.

A major part of our digital strategy is opening up to the digital economy, especially in the North-West. Working with our partners in the NOMA project, we’re creating shared spaces for digital collaboration and product delivery. Emer will be helping us to open this up for other businesses and organisations, as well as helping us find the best way for CoopDigital to support and be part of the growing digital community in the North West.

Emer has a huge amount of experience in leading digital transformation in both the public and private sector. She’s Chair of the Open Data Governance Board Ireland, and was part of the team that built  TransportAPI into a successful and sustainable transport data company. More recently Emer has been lecturing and writing on Techno Ethics and the need for new ethical approaches in the digital economy.  Her recent talk We Need To Talk About Ethics is worth taking a look at.

Picture of Emer Coleman
Emer Coleman

I know she’ll want to consult as widely as possible so that she can reflect the views of the community back to us here in CoopDigital. So get in touch with her. She’s not hard to find. She’s on the internet here and here @emercoleman

Welcome Emer.

Mike Bracken
Chief Digital Officer


Testing Co-op Membership

To continue in the spirit of the changes being made to membership and with our renewed focus on better meeting our users needs, it’s been another exciting week for us. We’ve just given 800 colleagues in our support centre at 1 Angel Square , Manchester access to the new Co-op Membership service.

Richard Pennycook (Group Chief Executive) announced the changes at the 2016 Co-op AGM (Annual General Meeting). I’m part of the team ensuring membership is focussed on the needs of its users and we’re testing our updated service with colleagues first to make sure it’s right for when we release to all of our members.

Picture of the new Co-op Membership landing page.
The new Co-op Membership site

The service aims to make it easy for members to:

  • Choose a local charity to support
  • Make the most of their rewards
  • Manage their details
  • Register transactions
  • Order a replacement card
  • Get involved with the Co-op

By only asking for the necessary information to create a membership share account, we’ve also reduced the amount of data a user has to enter to become a Co-op member. This is one step towards Mike Bracken’s (Chief Digital Officer) goal of making Co-op trusted with data.

We found during our research that users are becoming more reluctant to share their data with companies and question how their data is being used. We aim to be completely transparent at Co-op and by listening to and acting on our users feedback this demonstrates that commitment.

User research drives continuous improvement

We’ve been designing the new service with our members, customers and colleagues, holding regular research sessions to gain feedback and insight on early prototypes and ideas. This combined with data from our existing websites enables us to better understand our users, helping to prioritise the next round of development and continue to improve the service.

Picture of Co-op team members carry out user research in Ewloe’s Co-op
Team members carry out user research in Ewloe’s Co-op

We test our designs as early as possible, sometimes we use interactive prototypes, other times we’re simply testing a sketch on a post-it note.

Sometimes, the medium you use to test a design doesn’t matter; the key thing is that you’re testing with real users, to understand what works.

In the lab or In-store

Most of our user research has taken place in controlled environments with pre-screened participants (lab user testing), which has been great for gaining qualitative insight and we continue to research in this way.

Sometimes though, we need instant insight into our designs, so we use guerrilla user testing methods as well. Guerrilla testing is a lean, low cost way of carrying out user research, almost anywhere, any time. We’ve tested our designs in-store, in coffee shops and even in the street, gaining new insight each time.

We’ll continue to test and learn with our colleagues over the next few months with the aim of releasing to all members in the autumn.

In the meantime you might just catch us in your local Co-op testing out some new designs. Or if you are a colleague or a council member and want to find out more you can join us at our regular show and tell which is every Thursday 9.30 – 10.00 on the 13th Floor of 1 Angel Square.
Jack Fletcher

What we mean when we say “digital”

At the AGM one of the things I talked about was how digital doesn’t just mean changing the logo on the website and making some apps. ‘Digital’ when done well, means fundamentally redesigning the services we deliver, it means changing the way we work.

Here at the Co-op, when we say ‘digital’ we mean:

“Applying the culture, practices, processes & technologies of the Internet-era to respond to people’s raised expectations.”

Graphic with the text - Applying the culture, practices, processes & technologies of the Internet era to respond to people's raised expectations

Becoming a digital organisation means redesigning your services and your organisation, embracing ways of working that have long been second-nature to the best internet-era businesses.

It’s that simple – and that hard.

Mike Bracken
Chief Digital Officer

Catherine Brien joins as Data Science Director

I’m delighted to welcome Catherine Brien who will be joining CoopDigital as Data Science Director in July. At the AGM I talked about making the Co-op trusted with data, Catherine will be vital in making that a reality.

Catherine joins us from Oliver Wyman where she is a partner as well as global leader of their women’s network, founding member of the inclusion council, and the lead for their social impact model.  Keep an eye on the blog as Catherine will write about the progress we’re making.

Image of Catherine Brien
Catherine Brien

One more thing, as you may have read in Martha’s blog  Russell Davies our Director of Digital Strategy is also going to be working for Doteveryone as Interim CEO, you can read a little more about this news from Russell.

Good luck Russell and welcome Catherine.

Mike Bracken
Chief Digital Officer

The Co-op’s response to the Government consultation on Land Registry

The UK Government published a consultation in March on moving Land Registry operations to the private sector.

The Co-op believes that the UK economy will benefit from new services built on data. What the Government is proposing could make it harder to access and use data relating to land and property. In the future, the Co-op may want to build services for our members based on the data that Land Registry produces. We don’t want the Government to make it more difficult for organisations like ours to innovate.

We’re worried that the Government’s plans might make contracts and deals relating to property slower and more difficult. We know about this because Co-op Legal Services works with the Land Registry on behalf of members and customers. The Co-operative Group also deals with the Land Registry because we own lots of properties, including food stores and funeral homes.

The Co-op has sent in a response to the consultation to explain the reasons why we’re worried. We’re publishing it here in full so you can read it too.

Mike Bracken
Chief Digital Officer



Co-operative Group Response to the consultation on moving Land Registry operations to the private sector

This document is for public sharing and the Co-operative Group waives any rights to confidentiality. It contains answers to all the questions set out in the official response form.
Name:                      Richard Pennycook, CEO

Organisation:         The Co-operative Group

Address:                  1 Angel Square, Manchester, M60 0AG

Respondent Type: Large Business


The Co-operative Group, one of the world’s largest consumer co-operatives, with interests across food, funerals, insurance, electrical and legal services, has a clear purpose of championing a better way of doing business for you and your communities.  Owned by millions of UK consumers, The Co-operative Group operates a total of 3,750 trading outlets, with more than 70,000 colleagues and an annual turnover of £10 billion.

The Co-operative Group welcomes the opportunity to respond to this consultation by the Department for Business, Innovation and Skills on options of moving Land Registry operations to the private sector.

As a business that has significant land and property interests, both leasehold and freehold, with thousands of its own land titles and also given our client-facing conveyancing work through Co-op Legal Services, The Co-operative Group has direct engagement with Land Registry and a clear interest in the efficiency and effectiveness of how this register of UK land and property assets operates.

As a member-owned business, we are very well aware of the importance of establishing and maintaining trust with our members.   Openness and honesty should underpin all that we do.  In turn, we welcome the principles set out by the Government in its Open Data White Paper of 2012, and believe that access to data, including sharing of data-sets held by government departments and agencies, has the potential to stimulate growth, ingenuity and innovation which are vital to the future success of the British economy in the 21st century.


  1. Do you agree that the ownership of the Registers should remain in government?

Co-operative Group Response – Yes


The Co-operative Group believes that an efficient, well-regulated Land Registry is essential to the health of British business, and ultimately to the state of our economy and the size of our national debt. This is for reasons both timeless and novel.We will start with the timeless argument.

The Co-operative Group believes that the role of the state is to provide certain guarantees of rights that no private organisation, even one as large as the Co-operative Group, can provide. Amongst the most fundamental of those rights is the right to property, a right that is as essential to businesses as it is to individuals. We believe that there is a reason why protection of property, as described in Magna Carta, have been legal foundations of Britain for nearly a thousand years.  A country that cannot protect the right to property is one that will not sustain healthy economic growth, or quality of life for its citizens.

The registers that the Land Registry holds in relation to property and land in the UK are an essential part of the largest asset market in the UK. Their centrality in underpinning contracts and commercial deals cannot be over-stated – they are one of the reasons that Britain is a good place to do business.

The Co-operative Group fears that either the removal from public ownership of this data  or an attempt to regulate it in private hands threatens to gum up the works of British market capitalism, and a threat to Britons’ property rights, and thus to the welfare of our economy and nation. We therefore oppose any wholesale privatisation of the Land Registry or its assets.

Furthermore, we make an argument that is based on novel concerns, unique to the 21st century.

The Co-operative Group believes that the future of the British economy will be heavily driven by organisations and individuals that can seize a competitive advantage based on their skills at extracting value from data.

Crucial to this process is the business of connecting datasets together. Often this connecting process requires using key public data sets as a form of glue, such as lists of addresses, land parcels, transport infrastructure or weather. The more difficult and expensive it is for innovators to gather these connective datasets, the less we can expect modern British data businesses to thrive.

We are concerned that the proposed privatisation of Land Registry, as currently envisaged, risks raising barriers to future innovation and business growth, instead of lowering them.  The proposals appear counter to the principles set out in the 2012 White Paper on Open Data. In particular, the potential emergence of a monopoly competitor, with unique access to the most valuable data, makes the flourishing of a wide, competitive market seem extremely unlikely. The Co-operative Group may wish to compete in these new data service markets, and we are worried that they will be closed to us (and others) before we can even start to establish new businesses and provide new value-added services for the benefit of our members.

  1. What steps should government take and what safeguards should it put in place to ensure continued and improved access to high-quality and reliable Land Registry data?

We agree that digital transformation within Land Registry has the potential to better serve the needs of its users, including individuals and organisations.  But we are not convinced that this will be met by a move into private ownership.

Instead, we believe a better a better course of action is:

  1. Rather than pressing ahead with options to move Land Registry operations to the private sector, we suggest a strategic review of Land Registry in the first instance. Such as strategic review should be conducted by a Review Board composed of a range of stakeholders from inside and outside of Government. The mission, legislative constraints and current capability and capacity of Land Registry should also be reviewed.


  1. We also believe that, given the strategic importance of data held by Land Registry, the Competition and Markets Authority (CMA) should be asked to review of how to shape an appropriate regulatory framework that ensures adequate consumer safeguards of data, and equality of access to data in a market economy.


  1. After the reports from both the Review Board and the CMA are published, develop a new plan for the mission and governance of the Land Registry, delivered if necessary through amended legislation.




  1. How could government use this opportunity to improve the quality and accessibility of data produced by Land Registry for all sectors of the economy?
  2. The Co-operative Group believes that all non-personal and non-secret government data should be Open Data, freely licensed for re-use, and correctly formatted to make such re-use economically viable for businesses and innovators in the UK. We would therefore recommend that Land Registry adapts its current policies of selling some parts of its data in favour of making all of its data freely available, shifting the operating costs to the registration side of the business.


  1. We believe that the digital transformation that has been seen at its best in certain parts of central government has not yet arrived at Land Registry. We encourage a comprehensive programme of replacing current digital systems with ones built in accordance with the government’s own Service Design Manual, both as a way of improving quality, and as a way of reducing operating costs.


  1. The Cabinet Office has recently been promoting the idea that modern government registers are the backbone of 21st century government infrastructure. We agree with this design philosophy.  We believe that there is an opportunity now to ensure that Land Registry is part of this infrastructure of modern data registers.


  1. On what basis should government manage the relationship with a privately owned Land Registry to ensure Land Registry meets, as far as is reasonable, the data quality and availability requirements of all stakeholders?


If the Government does pursue the course of privatising all or part of the Land Registry, it is vital that a full independent economic regulator is put in place, rather than simply a contractual relationship with government. A contract would only ensure that the Land Registry fulfilled the needs of the parent department, whereas the Land Registry impacts on the activities of the whole economy.

Even if such an independent economic regulator is set up, we believe that the quality of data within the register will suffer because the fundamental economic incentives of a monopoly provider will be to minimise expenditure on data quality whilst maximising the value extracted from it. No amount of regulation can change the basic logic behind the financial incentives for any monopoly data provider.

As a business with thousands of properties in our estate we fear that this lowered data quality will lead to more legal disputes over property related ambiguity, which could hit our profitability and slow down our ability to respond to market conditions. We encourage the government not to create this business risk for us, and other British businesses with large property estates.


  1. Do you agree that the suggested safeguards should be included in any model?

Co-operative Group response: Not sure

The safeguards set out in the consultation document are thin on detail.

If the government does proceed with moving the operations to the private sector, it is vital that detailed safeguards are published for consultation in advance of any ultimate decision.

  1. Are there any other safeguards that you think should be included?

X Yes                       ☐No                ☐ Not sure

As previously set out, we believe the ownership of the Registers should remain public. However, if the government does pursue options to move Land Registry options to the private sector, we consider vital the following safeguards:

  1. All prices for data and services sold by the NewCo must be set by the regulator, not by NewCo itself, which will have standard monopoly incentives to extract the entire consumer surplus.


  1. All calculations about the cost of data and the sale price of data must be revealed publicly, and ‘commercial confidentiality’ must be excluded as a reason to conceal data on the cost and price of sale calculations. The Government’s contractual relationship with any buyer must make this explicit prior to sale of the government assets.


  1. The terms of use and details of any contracts between ‘NewCo’ and data consumers must be approved by the regulator.


  1. The regulator must be given a clear mandate to reduce the year-on-year costs of data, in the manner of the original ‘RPI-X cost’ reduction model imposed by early UK telecoms regulators. Ideally the regulator would require the price of data publications to fall to zero within a short time-frame.


  1. The exact technical requirements for data published, and the quality-levels must be set by the regulator, not by NewCo. Furthermore, the regulator should have adequate resources to regularly audit the data to make sure that it is compliant with the regulations in both technical terms and quality terms.


  1. Given that technology and data processing is evolving very quickly, the regulator should publish, consult and impose a revised set of standards covering the nature of data gathered and published, the technical and quality standards for that data, and the price of data, at least every 12 months. A refresh once every ten years is no longer acceptable for modern data businesses.



  1. Do you agree with the preferred option?

Co-operative Group response: No

For more detail, see answer to question 8.


  1. What are your reasons for your answer to question 7?

We do not believe that it is possible for any government to establish a regulator powerful or skilled enough to prevent the owner of ‘NewCo’ from abusing the resources of the land registry in a way that is detrimental to either individuals or to other businesses in the UK, including The Co-operative Group.

In particular we agree with the Competition and Markets authority who argue that:

there is a significant risk that a vertically-integrated, privatised NewCo engaged in both the supply of monopoly data and the supply of commercial products (which use the monopoly data as an input) would not maintain or improve access to the monopoly data…rather, despite price-regulation on its monopoly activities, NewCo may degrade the terms of access to its monopoly data in order to weaken competition to its own commercial products.

Consequently we have two fears:

1.That the estate management of several thousand co-operative properties will become slower, more expensive and more prone to error and fraud.


2.That the pace of digital innovation in the UK will slow, and that The Co-operative Group will be kept out of markets where we could otherwise compete for the benefit of our members.

These fears will unfortunately more likely to be realised as:

  1. Data prices rise, as well as the cost of other land registry services
  2. The quality of data and services fall, as the new monopoly embarks of a process of extracting value


  1. Do you think an alternative model would be better and why?

Co-operative Group response: Yes

It is clear that the Land Registry does need digital modernisation, and an overhaul of its licensing regime.

We would endorse a review of Land Registry operating principles and management structures, to lead to a new charging model based on much greater provision of open data, and a model based on a comprehensive overhaul of internal processes, based on modern digital management techniques. All this can be done without privatising the core of the service.


  1. Are there other key costs and benefits that you think we might have missed?

Co-operative Group response: Yes

The current proposal does not make any attempt to model the overall impact on the UK economy of the introduction of a significant new private monopoly as a gatekeeper within the single highest capitalised part of the entire UK economy.

We believe, along with the Competition and Markets Authority that such a monopoly is not going to be possible to regulate properly. Given this it would be appropriate to model the impact on UK economic growth, and the size and growth of individual business sectors in particular, especially the digital services sector, and the land and property sector. We believe the dent in growth to these two sectors that will emerge from such a modelling exercise is likely to dwarf the short term revenue boost, by some distance.

We therefore request that the Government commissions an independent modelling firm to assess the likely impact of privatisation on the size of related parts of the UK economy, an overall economic growth, and the size of the national debt.


Final Questions from BIS

Do you have any other comments that might aid the consultation process as a whole?




Please use this space for any general comments that you may have, comments on the layout of this consultation would also be welcomed.



Thank you for taking the time to let us have your views. We do not intend to acknowledge receipt of individual responses unless you tick the box below.

Please acknowledge this reply ☐

At BIS we carry out our research on many different topics and consultations. As your views are valuable to us, would it be okay if we were to contact you again from time to time either for research or to send through consultation documents?




Working with the Members’ Council

On Sunday, I was happy to have an opportunity to discuss our digital strategy with the Members’ Council. The best way to bring that to life was to show some of the things we’re working on for Funeralcare and wills.

Andy Pipes, one of our product managers, showed members the alphas we’ve built. These are early versions of digital products. We test them with stakeholders and get feedback to shape how they develop.

Andy talked through the team’s work on arranging a funeral and preparing a will. Making these services easier and clearer helps customers and colleagues to know what is happening and to keep in touch. We’ll be sharing more about these alphas on the blog this week and next.

What the Member Council told us

We’re on the right track. Council members liked the clarity, tone of voice and sense of engagement with customers.

They asked great questions and tested out some of our thinking on:

  • the alpha products
  • our place in the market
  • our plans for helping members to communicate
  • our approach to managing and using data

Some members were concerned about the experience visually impaired or dyslexic people might have when they use our prototypes. They were pleased to hear that we’re working with Leonie Watson, chair of the British Computer Association of the Blind, to make sure we do the right thing.

Engaging with members

We’ll be working with the Council as we go on developing our digital services. I’m looking forward to Council members getting more involved and helping us to keep our focus on delivering what’s right.

Thank you to those who jumped straight in with an offer to help test our beta products. You’ll be hearing more from us as they start to develop. In the meantime, we’ll be sharing what we’re doing through this blog.

On Friday, we’ll start to publish a weekly newsletter. It will let you know about some of the things that are happening in digital businesses elsewhere and why they’re important for the Co-op and our members.

Mike Bracken
Chief Digital Officer