Serious concern has been expressed by the Data Protection Commissioner about the privacy impacts of the proposed new postcodes to be introduced in the State early next year.
Publishing his annual report for 2013, Billy Hawkes said he was concerned about the potential uses of the code, including its potential to be used along with other data to identify specific areas that had patterns of crime or illness.
His office was unaware as to how the consortium licensed to manage the postcode system, in conjunction with the Department of Communications, would ensure “that the individual citizen’s fundamental right to data protection (and privacy) will be safeguarded into the future by the use of this postcode”.
He was particularly concerned whether these safeguards would be statutorily ring-fenced from, for example, the unique seven-digit medical identifiers proposed by the Government, “or how both public and private bodies will be in compliance with the Data Protection Act in the use of this postcode”.
“We have made enquires from the Department to this effect and will continue to do so pending complete clarification as to the manner in which the postcode system will operate in compliance with the Data Protection Acts,” he said.
In his report, the commissioner said the unique seven-digit postcode “goes beyond what an ‘address’ is because, through the use of modern technology and ‘Big Data’, it can be easily assimilated into any sort of electronic device or dataset which could in turn be used for any purpose, ranging from State services to commercial exploitation”.
“In this regard, we expressed the concern that such datasets which would be verified by this postcode could have the potential for the ready identification of sensitive information about individuals, examples of which would be to identify specific localities that have patterns of crime or illness.
Speaking to The Irish Times, Mr Hawkes said he had been consulted on the issue as far back as 2006 when the then Postcodes Board was dealing with the issue.
“I made clear that whereas an area-based postcode it would not necessarily raise major data protection issue, one that went down to the level of an individual dwelling would raise such issues.”
The State, he said, had now proposed to move “precisely to that in a way that is unprecedented anywhere in the world”.
“No privacy impact assessment has been carried out and I continue to be deeply concerned about the implications of this and the fact that they have not in fact been properly examined.”
He said the move from the original proposal for an area-based code to an individual code was “apparently driven by commercial pressures” without any assessment of the privacy impact of this scheme.
An Post and Minister for Communications Pat Rabbitte recently said the new system run by Capita Ireland would make postal deliveries faster and more efficient.
He admitted the system would make it easier for Government agencies such as Revenue to collect charges.