Understanding the Limits of Flood Re’s Property Tax Band Data

Under GDPR, the ICO and the VOA classify property tax band information as personal data.

In the world of insurance, access to accurate, property-level data is crucial — not just for risk assessment but increasingly for building richer, more predictive models. One commonly referenced data point is the council tax band, which can help infer property value, size, or socioeconomic context. However, it’s important to understand the limitations around certain sources of this data, particularly those accessed via the UK’s Flood Re scheme.

Recently, Flood Re clarified the restrictions surrounding the use of property tax band data made available through the Property Data Hub (PDH). This data, which originates from the Valuation Office Agency (VOA) and other national bodies, is supplied strictly for use in the context of the Flood Re Scheme — a government-backed initiative designed to make flood insurance more affordable for high-risk households.

All insurers and agents accessing the data through Flood Re must sign legally binding End User Terms (DS1). These agreements explicitly prohibit:

  • Any use of the data outside the scope of the Flood Re Scheme,
  • Manual amendments to the data,
  • Onward disclosure without explicit VOA permission.

Additionally, the General Data Sharing Agreement (DS2) enforces strict rules requiring that all data use must be lawful, proportionate, and in compliance with contractual and regulatory standards.

GDPR Implications: Tax Band Data Is Personal Data

Under GDPR, the ICO and the VOA classify property tax band information as personal data when linked to an identifiable property and owner or resident. This means that re-use or redistribution of this data requires a lawful basis — most often explicit consent from the individual concerned.

This is also why scraping the VOA website for tax band data is not permitted: it bypasses these consent and data protection requirements. Without proper licensing or permissions, such use could constitute a breach of GDPR.

In the case of Flood Re, the sharing and use of tax band data is justified under the public interest and contractual necessity bases, but only for the specific purpose of supporting a government reinsurance programme. It cannot be lawfully repurposed for general insurance modelling, underwriting, or marketing use.

The Challenge for Insurers

For insurance companies looking to leverage tax band data as part of broader property analytics — including pricing models, property characteristics modelling, or socioeconomic segmentation — this presents a clear limitation. Using the Flood Re-supplied tax band data for anything beyond flood risk is not only contractually prohibited, it could also breach data protection laws.

Doorda: A Fully Permissible Alternative

That’s where Doorda comes in. Doorda sources property tax band data independently, ensuring it can be used lawfully for a wide range of insurance modelling purposes — not just flood-related scenarios. Our data is fully compliant with data protection and licensing rules, and is available for integration into underwriting, pricing, and property risk analytics models without the legal restrictions that bind Flood Re data.

If your organisation is relying on Flood Re data to fill gaps in property datasets, it’s vital to reassess its scope and permissible uses. For broader analytics — including the kind of next-generation risk modelling insurers are increasingly deploying — Doorda provides a more flexible, future-ready alternative.

Interested in learning more about our property tax band data and other enriched datasets? Contact us to see how we can help power your models, compliantly.