The Department of Education are requesting that data on all primary school children be captured into a Primary Online Database. The list of data they are asking for is comprehensive. It includes PPSN numbers.
This is what we know
A new database of primary school students will gather personal information, including PPS numbers, information on ethnic and cultural background and religion. Some details will be kept for up to 30 years (Irish Times)
List of data includes:
• First and second names
• PPS number
• Mother’s maiden name
• Date of Birth and gender
• Full address
• Mother tongue
• Irish language exemptions
• Enrolment date, teacher / class details
• Previous school / pre-primary education
• Learning support details
There is also a free text box for “Notes about a pupil”. The Departments reference manual on the Database states
Notes about a pupil may be entered into the ‘Notes’ tab. At present, notes entered here can be seen by Department of Education staff but this is to be changed so that only the school user may see the notes.
The Department is also claiming that
it is compulsory for parents to register their children. In the event a PPS number is not available for a student, the Department will use the mother’s maiden name to look up Department of Social Protection records.
The Department also reports that only information on ethnic and religious background requires the consent of a parent of guardian.
The data to be captured on the system may be captured on esinet.ie or an excel spreadsheet or on a schools own system.
It is not clear that the data is safe or secure or how it is being protected by the Department of Education or the Schools.
Simon McGarr has pointed out “The Department of Education data protection notice explicitly refers to kids’ PPS Numbers as non sensitive data.”
The Department of Education PPSN use case statement hasn’t been notified or approved by the Department of Welfare (via Simon McGarr)
The Department of Education claims support of the INTO and the National Parents Council. Speaking to one principal of a school it appears to be very controversial, not least of all because of the huge administration workload it puts on the schools including the school being asked to retain the data for 30 years.
One member of board of the National Parents Council (Primary) wasn’t even aware of the existence of the Primary Online Database.
I’m going to copy Simon McGarr’s tweets on this
A single database of everyone under 30, including religion, ethnicity is a major change in relationship between state & citizen. This isn’t he census- where strong legislative protections are given to the privacy of individuals. This will be a honeypot for datamining. The data is being used for a purpose other than that for which it was obtained. Storing all details of a primary school pupil until they’re 30 is excessive data retention.
The Department of Education is acting ultra vires (beyond their powers) in demanding the information.
As a parent you can write to the school and the Board of Management and inform them that
The Department is acting beyond its power. The Department of Welfare hasn’t been informed or consented to the use of PPSN. They are breaching data protection legislation by using data for a purpose other than which it was obtained and by planning to retain that information for an excessive period of time.
Schools and boards should be aware they are personally responsible as data controllers to ensure that the data they hold is not used for a purpose other than that for which is was obtained and they are personally on risk if the department has acted ultra vires in demanding this data.
You can tell them explicitly that you don’t consent to giving them this data or to them transferring the data outside the school.
As Gavin Sheridan pointed out
the only other database I can think of that is similar is PRIS. For the prison system
Credit for most of the points here go to Simon McGarr. Image credit to Søren Mørk Petersen Human Barcode on Flickr shared under Creative Commons.