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Irish Water, PPSNs and the missing Minister’s agreement

When challenged on how it has the right to ask for people’s PPS numbers, Irish Water has said that it is a specified body under statute. This is a reference to Section 20 of the Social Welfare and Pensions Act 2014.

This section did add Irish Water to the list of specified bodies set out in Social Welfare Consolidation Act 2005.

S 262(4) and Sec 262(6) of the same Act are the ones which control what a specified body may do with a PPS number to verify a person’s identity with the Minister for Social Protection. Irish Water have said that this is the sole purpose for which PPS numbers are being collected.

This use is subject to prior agreement with Minister for Social Protection.

The Minister must be shown and must agree with the proposal for use and processing of the PPS number, on the basis (amongst other things) that it is necessary and proportionate under the general principles of data protection.

If the minister does agree that standard has been met then a specified body may then collect and process PPS Numbers-solely in line with that agreement.

No such agreement between the Minister for Social Protection and Irish Water is anywhere shown on the Irish Water website or on the Department of Social Protection website.

However, the Department of Social Protection has published a statement from Irish Water on its website saying that the agreement is still not in place, as of September 2014.

“This arrangement has not been finalized at this time but we are engaging with the DSP”

If there is no agreement in place with the Minister, on what statutory basis is the collection and processing of PPS numbers taking place?

Credit to Damien McCallig, who spotted this issue.


  1. But the link to shows that the agreement is in place – it has been there since late sept. Unless I’m missing something – this article would have been true a month ago but not anymore.

  2. ignore that last comment – I see the sentence you refer to now .

  3. Very interesting – where in legislation is the requirement for agreement with the Minister set out?