Irish data sharing proposals – submission with Castlebridge Associates

DRI has teamed up with the ever knowledgeable data protection and information experts at Castlebridge Associates to agree a joint submission to the Department of Public Expenditure and Reform’s consultation on a proposed Data Sharing and Governance Bill.

There is a detailed summary in the submission itself and on the Castlebridge Associates blog but to distill the submission to its essence, we believe that:

  • The proposals place too much emphasis on data sharing as a cure-all for public sector reform and do not adequately define what is meant by data sharing;
  • The proposals fail to address the criticisms of the outgoing Data Protection Commissioner regarding widespread abuse of personal data held by the public sector;
  • The proposals do not sufficiently consider the need for public sector practices to be reformed in a way which minimises the need to share data;
  • There is a need for greater protection of personal data held by the public sector, in particular by extending the crime of wrongful disclosure from the Revenue only (the current situation) to all public bodies; and
  • The proposals misunderstand the independent role of the Data Protection Commissioner by seeking to involve the DPC too closely in the management of public sector data.

All that said, the proposals offer an opportunity to strengthen privacy in the public sector by developing (for the first time) a comprehensive data governance framework across the public sector and the opportunity to do so should not be missed.

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