I received the following reply to my email complaint in relation to the Primary Online Database (POD). Link takes you to the full letter. The fundamental questions still remain unanswered.
My comments are interspaced with text from the Ministers letter
On retention of data
The current retention policy for Primary Online Database (POD) data is for records to be maintained for the longer of either the period up to the pupil’s 30th Birthday or for a period of ten years since the student was last enrolled in a primary school
The Department’s retention policy is for audit and accounting purposes as pupil’s data is used in the allocation of teaching posts and funding to schools. The policy also serves to trace retention trends in the education system, is important for longitudinal research and policy formation, as well as being an important statistical indicator nationally and internationally.
Aggregate and not individual data is used for the majority of these purposes
This reads to me as “we’ll hold data until the kids are 30 even though we only need aggregate information for statistical purposes.”
There is a clear conflict in need between aggregate information, information for allocation of resources while children are in school and holding detailed information until the children are 30 (or possibly longer given we don’t know what processes will be in place to remove the information in 18 years time).
On the racist nature of the cultural/ethnic categories
We are committed to reviewing the questions asked in POD. As part of this we have reviewed our question in POD on the collection of information on Ethnic or Cultural Background. We feel that the question used to collect data on ethnic or cultural background should be harmonised across all the education partners and other bodies who collect this type of information. As the CSO is the National Statistical Office, we are taking our lead from them. However, while the question asked in POD is not the exact same as the question asked in the Census of Population, it is based on the question.
I’d describe this as “some of the questions we asked were a bit racist so we’re changing the question and taking our lead from the CSO”. It’s important to note that the CSO’s questions is problematic
In this regard the Statistics Section of the Department met with the CSO’s Census of Population Division to discuss concerns such as yours. They too accept that the variant of the ethnicity question on the 2016 census may fall short of what could be expected in today’s multi-racial Ireland. Unfortunately, given the no-change’ census approach being adopted for Census of Population 2016 it is not possible to change the CSO question at this stage. However the CSO has indicated that it is considering holding a seminar to examine how the data in this area can be improved from the point of view of maximising the number of write-in responses to increase the variety of ethnic description captured,
As pointed out on Twitter the Religion question on the Census is also problematic and the CSO don’t appear to be anxious to change it. The Religion question in the POD is similarly problematic.
In terms of the complaints (in italics) I made to the Minister and the Department this is how I’d summarise it
1. Excessive retention of data. The retention of data until Children are 30 years of age is clearly excessive.
Not addressed.
2. Not using data for the purpose it was collected. I shared data with my school for very specific purposes. I have not consented to transferring this information to the Department. As it is not clear why some of this information is being collected at all the is a clear lack of purpose in collection of the data
Not addressed. The answer here seems to be we’ll decide what is appropriate even if we clearly don’t understand why we’re collecting the information.
3. Collection of unnecessary highly sensitive information. Some of the data being requested is highly sensitive (medical, psychological data) and there is no clear grounds for collecting this information
Not addressed at all
4. Lack of appropriate security and safeguards around the data (including transmission of the data between schools and the department) It is not clear how or where the data is being retained and stored. And the proposed mechanisms for transmission of data are hard to implement and easy to make mistakes around
Partly addressed in terms of storage of data but not addressed in terms of either access to information or in terms of transmission of data to schools and retention in schools.
5. Data is supposed to be accurate. There will be an inability to contain accurate information in light of free format text data and any information can be held in these fields.
Partially and poorly addressed.
The “Notes” area is for schools’ use only, it will only be accessible to the school where the child is currently enrolled, and will not be transferable from one school to the next if the child is moving school. It is intended to keep administrative information which is required at school level only.
Its not clear why this data field is here and why if data for schools use only is being held in a central database and will be held until the child is 30.
6. The categorisation of the data on ethnic and cultural grounds is clearly racist and undermines the ability to store accurate information. The usage of the data for state purposes is also undermined by the racist classification scheme.
Partially addressed as discussed above.
7. The Department is acting beyond its power. The Department of Welfare hasn’t been informed or consented to the use of PPSN
Addressed in terms of the formal right to use the information through Dept of Social Welfare. Not addressed in terms of retention of the data.
