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Woman has request to see changes made to her own data refused as database 'is blanked every two weeks'

The woman had requested access to her own citizen’s data file under freedom of information.

shutterstock_614157998 Shutterstock / Mantinov Shutterstock / Mantinov / Mantinov

A WOMAN WHO requested information about changes made to her citizen’s data file has had her request refused for the reason that the database holding the information is routinely blanked.

The woman in question initially requested a copy of her own file from the Department of Employment Affairs and Social Protection (DEASP).

Such data is held on a database known as the Single Customer View (SCV), operated and managed on behalf of DEASP by the Department of Public Expenditure and Reform.

The view depicts a person’s PPS number, their date of birth, gender, address, birthplace, and mother’s birth surname – much of the same information that is currently encrypted on the government’s controversial Public Services Card (PSC).

PSC The Public Services Card

The database comprises information from a number of state bodies, including DEASP, the Road Safety Authority, the Revenue Commissioners, and the HSE, to name a few. Collectively, the data is known as a citizen’s Public Service Identity (PSI).

Anyone can obtain a copy of their own file by applying to the Client Identity Services section of DEASP.

Deleted

In this case, the woman was curious as to what changes may have been made to her own data – known as an audit trail (essentially a log of who had accessed her file and of whatever changes may have been made).

She requested an audit of all such changes made to her own file held under the SCV, along with the name and rank of any civil servant who may have made such a change, if any, and a copy of what her file would have looked like at a date in the recent past.

FOI

Click here to view a larger image

The department replied:

“On a fortnightly basis data on the Single Customer View system is deleted and recollected from the data providers.”

There is no archive or audit trail of previous updates.

However, this suggestion appears to contradict the information contained within DEASP’s own recently-produced document, the ‘Comprehensive Guide to SAFE Registration and the Public Services Card’.

That document stresses that:

“The Single Customer View database is stored in a secure government data centre. Access to the data is tightly controlled and restricted to specified bodies on the private Government Network.”

All data access is logged and regularly audited.

DEASP DEASP DEASP

Click here to view a larger image

That document itself was published on 20 October in reaction to the Data Protection Commissioner (DPC) expressing concern in recent times over matters of transparency concerning the PSC and the SCV, with those concerns chiefly resulting from a report by the State auditor, the Office of the Comptroller and Auditor General, which determined that no business case had been put in place with regard to the rollout of the Public Services Card.

The above apparently contradictory statements, meanwhile, raise the question as to whether an approach of blanking such a database, and in doing so removing any evidence of changes that may have been made, is compliant with both existing data protection legislation, and the EU’s forthcoming General Data Protection Regulations, which will come into force in May 2018.

“The Single Customer View is a read-only, periodically updated, consolidated view of Public Service Identity data only. Essentially, it is a mechanism used to enable sharing of the PSI dataset with specified bodies. The Single Customer View is held electronically on secure systems owned by the State in a secure government data centre on the private government network in Ireland,” a DEASP spokesperson said in response to a query from TheJournal.ie regarding the matter.

The PSI data displayed is that obtained by each contributor during their most recent transaction with the customer. The basis data on the SCV system is deleted and recollected from the data providers, generally on a fortnightly basis. There is no record of previous transfers of data held.

“All accesses to the Single Customer View application are logged. Information is logged about what information was accessed, by whom, and when. This log data is retained,” they added.

Security trail

“It’s good practice to keep audit logs of access to this kind of information for the purpose of demonstrating that data is being kept securely,” said Simon McGarr of Data Compliance Europe.

It increases the chances that the department would face compensation claims and other administrative fines in the event of a data breach if they could not demonstrate their own security trail.

TheJournal.ie raised the possibility that the Single Customer View database is routinely wiped with the Office of the DPC.

A spokesperson said: “Matters relating to the security of the data held and shared amongst the bodies involved in the SCV and PSC are currently being examined by the Data Protection Commissioner.”

smcg Simon McGarr Rollingnews.ie Rollingnews.ie

It’s understood that the Data Protection Commissioner submitted as many as 50 questions to DEASP in recent months with regard to issues of transparency with the Public Services Card project and the SCV database, while a full investigation is now under way to determine whether or not those initiatives demonstrate full compliance with Ireland’s data protection acts.

The spokesperson continued:

“Since 2016, the DPC has been seeking clarity and greater transparency to the public on these matters. While the (commissioner) welcomes the greater clarity certain responses bring, engagement with the department is ongoing in relation to matters covered in the guide and in recent Dáil responses to PQs (parliamentary questions) particularly as they relate to biometric data processing and governance and data issues associated with the interplay between the Public Services Card, Public Service Identity set, MyGovID, Single Customer View and Infosys.”

To examine details of the above matters further, the DPC has now commenced an investigation under Section 10 of the Irish Data Protection Acts with a view to establishing whether there is full compliance with the requirements of the Acts.

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    Mute Dec
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    Jun 20th 2020, 7:10 AM

    If the coronavirus hadn’t taken over Brexit is all we’d have been hearing about for the past 3 months……. I’m well aware of the importance of both but I’m sick of Brextit and Covod 19.

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    Mute Michael Kavanagh
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    Jun 20th 2020, 7:29 AM

    @Dec:
    Well – As Leon T said:
    “You may not be interested in war, but war is interested in you”

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    Mute Dec
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    Jun 20th 2020, 11:51 AM

    @Michael Kavanagh: A Trotsky quote to make a point re the advancement of capitalism…. however unlikely it may be it’s an excellent quote and very apt in this instance! It’s the reason we keep reading and commenting on Brexit and other such articles even when we’re completely disillusioned with them all!

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    Mute willow moon
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    Jun 20th 2020, 11:11 AM

    ‘The Duchy of Lancaster’…..God what is it with these people.

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    Mute Heisen berg1
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    Jun 20th 2020, 9:23 AM

    It just showed how much the readers of the journal are interested in brexit, this storey is up 2 hours and only 2 post about it. I got bord after the scend line .

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    Mute John Daly
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    Jun 20th 2020, 10:38 AM

    @Heisen thing is there is nothing to comment on

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    Mute *.stevem.*
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    Jun 20th 2020, 10:05 AM

    “…which was illuminating in showing how little we still don’t know.”

    Do you even read what you write?

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    Mute Gary Kearney
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    Jun 20th 2020, 12:45 PM

    Boris the Bluffer and his cronies have shown themselves up ti be as useless as most people outside the UK saw them to be.
    1000 people a day dying from Covis-19 but they only count hospital deaths! It keeps the numbers low.
    All the lies they told about Brexit are being shown as that

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    Mute Heidi Cain
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    Jun 21st 2020, 2:49 PM

    @Gary Kearney: there are not a thousand dying each day check worlometers

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    Mute Gerry Ryan
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    Jun 20th 2020, 12:32 PM

    When the boy cried wolf he gained a reputation. British Perfidy has been around for hundreds of years. Indeed Stalin refused to believe the British when they warned him of imminent German onslaught. He thought they were lying. That’s what reputation does.

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    Mute Bríann O Connor
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    Jun 20th 2020, 10:56 AM

    Embarrassing shambles, the entire affair. Full of lies and some misplaced Empire nostalgia nonsense. Johnson is a pathological liar and unfit to be the prime minister.

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