Who we are:
The Central Statistics Office (CSO) is Ireland's National Statistical Institute and our purpose is to impartially collect, analyse and make available statistics about Ireland’s people, society and economy.
Specifically, our mandate under the Statistics Act 1993 is "The collection, compilation, extraction and dissemination for statistical purposes of information relating to economic, social and general activities and conditions in the State" (Section 10).
At national level, CSO Official Statistics inform decision making across a range of areas including construction, health, welfare, the environment and the economy. At European level, they provide an accurate picture of Ireland’s economic and social performance and enable comparisons between Ireland and other countries.
The CSO is also responsible for coordinating the Official Statistics of other public authorities.
The CSO is the Data Controller for the Central Credit Register (CCR) data when received from the Central Bank of Ireland (CBI).
Purpose of Processing:
The purpose of processing CCR data is to give effect to the functions of the Central Statistics Office as set out under the Statistics Act 1993 at Section 10, these being to collect, process, analyse and disseminate information relating to economic, social and general activities and conditions of the State.
The Central Credit Register is a database of loans, including consumer loans such as credit cards, mortgages, personal loans and overdrafts and the CSO will receive an extract from this Central Credit Register. As debt is a sizeable factor in the financial wellbeing of households, the availability of accurate data relating to the amount of money owed by borrowers is essential for providing timely statistics about household debt in Ireland.
The CSO will then use the loan information available in the CCR, together with other sources of household income and expenditure data, to produce a complete picture of the financial wellbeing of Irish households – this will include statistics on income, consumption and the wealth of Irish Households. This information is an invaluable resource and will be used by policymakers, decision makers, economists and researchers and is made available on an equal basis to all others who may find it interesting or relevant to their understanding of the profile of the Irish economy and society.
A key statistical motivation for obtaining the CCR administrative data is to reduce respondent burden. The CSO currently undertakes a number of surveys in order to obtain this data. However, access to the CCR extract should enable the CSO to reduce the question content and respondent burden for future rounds of such surveys as well as resulting in an improvement in loan-related data quality, due to the decreasing response rates to surveys, which in turn can create lower quality data outputs.
Legal basis for collection and processing:
Access by the CSO to the proposed subset of the CCR is underpinned and provided for by a written request under Section 30 of the Statistics Act 1993 - ‘Use of Records of Public Authorities for Statistical Purposes’. This provides for cooperation by public authorities with the work of the CSO in granting access to administrative records held by them.
The exercise by the Office of its powers under Section 30 of the Act is undertaken in the context of its legally designated functions, which are set out at Section 10 of the 1993 Act as iterated above.
The legal basis for processing is underpinned by Articles 6 (c) and (e) of the General Data Protection Regulation (GDPR). Article 6 (c) relates to processing necessary for compliance with a legal obligation to which the controller is subject, while Article 6 (e) concerns processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller. In the present use case, the processing is undertaken in the context of producing official statistics for Ireland regarding the incidence and sustainability of consumer debt – deriving from the functions set out under Section 10 of the Statistics Act, 1993 Act.
Processing of CCR data is also permitted under Sections 38 (1)(a), 42 (1)(c) and 54 (c) of the Data Protection Act 2018.
Some examples of relevant EU survey regulations include the following;
Categories of personal data concerned:
Surname
First name
Address
Date of Birth
Gender
Business identifiers such as CRO number.
Who uses the data:
The data is received in the CSO by a dedicated business unit called the Administrative Data Centre (ADC), which is a specialist team responsible for decrypting, processing, pseudonymising and storing records in a format accessible for statistical analysis. In the pseudonymisation process, all direct identifiers such as names and addresses are removed by the CSO. This processing prior to analysis involves removing directly identifiable data and replacing identification numbers with Protected Identifier Keys (PIKs). PIKs are unique, encrypted and non-identifiable numbers which are internal to the CSO that enable safe linking across data sources and over time (linking occurs without revealing any identification details).
Access to the pseudonymised data produced via this process for analysis purposes is then provided to named statisticians within the CSO once a statistical requirement is identified and the necessary governance procedures are followed.
Statisticians who require access to identifiable data for statistical processing purposes must comply with extensive governance procedures and have their business case signed off at management board level.
Pseudonymised versions of the data may subsequently be made available to approved researchers under strict researcher protocols and detailed governance procedures.
Aggregated statistical outputs derived from CCR data will be used by, for example, academics, media, the public, policymakers as well as other national statistical organisations.
The use of CCR data potentially has the benefit of being used as an input in providing various statistical outputs required at EU level, including:
Is your personal data confidential and how long will the data be retained:
Yes, any identifiable data provided to the CSO is considered strictly confidential and may not be shared with any third party. This is underpinned in the Statistics Act, 1993.
The CCR data furnished to the CSO will be retained for a period of seven years. At present, there is insufficient coverage of primary keys/unique identifiers in the CCR dataset to support robust pseudonymised primary keys for longitudinal statistical analysis. Such longitudinal linkage is important for statistical analysis of the evolution of loans, debt and financial stability at an individual level over time. The CSO Income, Consumption and Wealth (ICW) Division operates a panel component in some surveys which report for a period of six years prior to the reference period. Survey on Income and Living Conditions (SILC), for example, reports on the income and living conditions of different types of households in Ireland, in order to derive indicators on poverty, deprivation and social exclusion. This is carried out under EU regulation (Council Reg No 2019/1700). Accordingly, identifiable CCR records must be kept for a 7-year period in order to assure accurate data linkage is possible for longitudinal analysis spanning this period. At the expiry of this retention period, the identifiable microdata will be expunged in line with standard CSO procedures.
Pseudonymised data which has all identifiable information removed (name, address, date of birth rounded to first of the month) will be kept indefinitely for statistical analysis purposes only.
Does CSO share personal data with any third parties:
No.
The CSO will never share any personal data with any third parties – State, commercial or otherwise. In certain specific cases, pseudonymised versions of data may be made available to approved researchers under strict researcher protocols and detailed governance procedures.
One of the core principles governing the operation of National Statistical Institutes is the protection of the confidentiality of all information supplied by data providers. The CSO’s ability to compile Official Statistics is based on the extent to which individuals and companies trust the CSO with sensitive information and the CSO’s guarantee of confidentiality for all data providers is built on the fundamental requirement of non-disclosure of confidential data as set out in national and EU statistical legislation.
What rights do you as the data subject have:
The General Data Protection Regulation (GDPR) confers the following rights on individuals:
However, because your data is processed for statistical purposes, these rights may be limited in accordance with Article 89 of the GDPR. This is due to the fact that the exercise of any of these rights may render impossible, or seriously impair, the achievement of the statistical processing and such restriction maybe necessary for the fulfilment of those purposes. Should you wish to exercise your rights in respect of your CCR data, you may contact the CSO Data Protection Officer on the details set out below.
The sources and categories of your personal data, where the data has not been collected directly from you:
CCR extracts furnished to the CSO are provided by the Central Bank of Ireland.
For further information on this survey, your Data Protection rights and how your data is used, please contact:
Seán O'Connor, Administrative Data Centre, CSO, Skehard Road, Cork T12 X00E.
Tel +353 (21) 453 5295 E-mail: ADC@cso.ie
Right to lodge a complaint to the Supervisory Authority
Under the General Data Protection Regulation, you have a right to lodge a complaint with the Data Protection Commission if you consider that processing of your personal data is contrary to data protection law. The contact details of the Commission are:
By post: Office of the Data Protection Commission, 21 Fitzwilliam Square South, Dublin 2, D02 RD28, Ireland.
By e-mail: info@dataprotection.ie
By phone: 01 7650100 / 1800 437 737
Online: https://www.dataprotection.ie/
Contact details of the Data Protection Officer:
The CSO’s Data Protection Officer (DPO) is responsible for overseeing questions in relation to this Transparency Notice (contact details below). If you have any questions about this statement, including any request to exercise your legal rights, please contact or send them to the CSO DPO:
Data Protection Officer,
Central Statistics Office,
Skehard Road,
T12 X00E
Tel: 021-453 5000
Email: dpo@cso.ie
For further information:
Link below to FAQs in relation to the Central Statistics Office and Access to the Central Credit Register
The Central Statistics Office and the Central Credit Register