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Thought I’d give you a quick round up of where we are with the Public Services Card scheme. Because these things go in months or years long arcs, it can be helpful to take stock. #PSC
The #PSC project sees the Dept of Social Protection (DEASP) acting as joint Data Controller with the Department of Public Expenditure and Reform (DPER) over a database of citizen’s identity, called the Single Customer View.
The PSC is the card attached to that database.
The PSC is the card attached to that database.
At some point in the past, DPER decided it wanted a single ID card and database which would be used throughout the public service to gain access to services- and they preferred to call it a “Public Services Card”, instead of, you know, an ID Card.
Today’s Sunday Times (um, [insert link to print paper]) reports that the DPC’s #PSC investigation report has found @welfare_ie’s claimed legislative power
“does not provide a sound legal basis to compel people to have a card to access other public services”
“does not provide a sound legal basis to compel people to have a card to access other public services”
As the state cannot rely on consent (as any consent could not meet the requirement for being freely given, given the power imbalance), this- if it stands- would mean that all of the processing done without another legal basis would be in breach.
I gave evidence to the Joint Oireachtas Committee on Social Protection on 8th February this year, trying to warn of this self inflicted crisis.
kildarestreet.com/committees/?id…
kildarestreet.com/committees/?id…
Neither the Minister for Employment and Social Protection, nor- it seems- the Secretary General of the Department appear to know what Biometric Data is.
This is concerning as the Dept is the largest processor of biometric data in the State, thanks to the #PSC card database.
This is concerning as the Dept is the largest processor of biometric data in the State, thanks to the #PSC card database.
What we can infer is that the Depts new Data Protection Officer (whoever she or he is) *does* know the definition of Biometric Data and so they put it in the Privacy Notice that they were processing it.
(That’s a thing you have to do now, per GDPR)
(That’s a thing you have to do now, per GDPR)
We know the Minister has asserted that the Dept of Employment and Social Protection doesn’t collect biometric data. At all. (Small video of just the most recent of those statements)
The State continues to be, imo, entirely disingenuous about the #psc rollout and is still pushing it through without proper legal basis or authority so that it reaches critical mass.
One thing is clear: they are avoiding any binding decisions on the PSC. #thread
📷: @DRIalerts
One thing is clear: they are avoiding any binding decisions on the PSC. #thread
📷: @DRIalerts
You might recall that, since @RSAIreland backtracked on requiring #PSC for driving licences, passports are effectively the last non-social welfare holdout on mandatory/compulsory use.
This type of requirement is what takes it from mere "token" to de facto ID card.
This type of requirement is what takes it from mere "token" to de facto ID card.
At every step along the way over the past 12 months or so, in my experience, the authorities have backed down when challenged. The difficulty is that they find a different, non-PSC, reason to back down.
If I might seek to provide some light relief from #GE17 snow clouds,
I FOI’d the Ministerial Agreement On Data Processing underpinning the #PSC and.. um, it was never signed by or on behalf of the Ministers.
And it also may have lapsed in Feb 2016.
mcgarrsolicitors.ie/2017/11/27/dat…
I FOI’d the Ministerial Agreement On Data Processing underpinning the #PSC and.. um, it was never signed by or on behalf of the Ministers.
And it also may have lapsed in Feb 2016.
mcgarrsolicitors.ie/2017/11/27/dat…
This is quite significant. Irish Water relied on their Schedule 5 status to collect PPS Numbers. (the same basis @welfare_ie used to justify DPER Processing data on their behalf.)
Then they had to destroy all those records when they couldn’t produce a Ministerial Agreement.
Then they had to destroy all those records when they couldn’t produce a Ministerial Agreement.
The 2014 Agreement starts off as an Agreement between Ministers (as you might expect).
I’ve received a copy of the Data Processor agreement between the Minister for Social Protection and the Minister for Public Expenditure and Reform. Dated 17th Feb 2014
#PSC
#PSC
The first surprising thing is that it is neither signed by either Minister nor for and on their behalf. It’s signed for and on behalf of the Departments, by officials.
The major surprise comes when you see what the Agreement actually covers. The use the Minister for Public Expenditure and Reform may put the Data is very minimal.
Solely to produce “data quality reports”.
Solely to produce “data quality reports”.
