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.

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” 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 would prefer if Ronan Mullen lost his NUI Senate seat.

For that to happen, approx 7000 more NUI grads (UCD, UCC, Maynooth, NUIG, etc) would need to vote.

Here’s the form- you can email it in to elections@nui.ie

Tell your friends.

nui.ie/elections/docs…

https://twitter.com/ronanmullen/status/1026204265268883456

I have blocked the Senator, previously. But this statement- attempting to defend a Bishop’s earlier statement by asserting not all unwanted sex is rape- is sufficiently telling to be worth spreading, as an example of why registering to vote is worthwhile.

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. 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)

The Government has just lost on an amendment in Seanad proposed by @aliceeire to Data Protection Bill. They've called for a walk through vote. The amendment would limit the powers of Ministers to act, by ensuring doing so would only be where it was necessary and proportionate Nope, reversed after a whip around of extra senators by the Gov side, and with the casting vote of the Chair.

Today, on and off, I have been reading the newly published Data Protection Bill, which is 132 pages long, being introduced via the Seanad, and needs amendments submitted by next Tuesday.

Unfortunately you can’t table an amendment that says “this is terrible”.

It is the worst. I’m going to have to blog it over the weekend.

I think Section 54(3) a list of made up exemptions for the state not in the EU law that the State wishes had been in the Regulation *might* be the worst.

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… 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.

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 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.