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Purpose
Under Data Protection legislation, individuals have a number of rights in relation to the personal data an organisation holds about them. The purpose of this notice is to inform you, as a Growing Up in Ireland survey participant, about the data processed by the Growing Up in Ireland project, how these data are handled and what your rights are.
Who we are and how to contact us?
The Growing Up in Ireland (GUI) project is funded by the Department of Children, Equality, Disability, Integration and Youth (DCEDIY) and managed by DCEDIY in cooperation with the Central Statistics Office (CSO). GUI is carried out under an arrangement based on section 11 of the Statistics Act 1993, which permits the CSO to make arrangements with other public bodies for the collection, compilation, extraction or dissemination of information for statistical purposes.
DCEDIY and the CSO are joint data controllers responsible for personal data collected by GUI.
DCEDIY is a Government Department which leads the effort to improve the outcomes for children and young people in Ireland. The CSO is Ireland's national statistical office. The work of the CSO is carried out under the Statistics Act 1993 which provides for the collection, compilation and dissemination for statistical purposes of information relating to economic, social and general activities and conditions in the State.
GUI survey data is collected under section 24 of the Statistics Act 1993.
DCEDIY and the CSO Data Protection Officers (DPOs) are responsible for overseeing questions in relation to this Privacy Statement (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 DCEDIY DPO:
Data Protection Officer,
Department of Children, Equality, Disability, Integration and Youth,
Block 1,
Miesian Plaza,
50-58 Baggot Street Lower,
Dublin 2
D02 XWI4, Freepost F5055
Tel: 01-6473000
Email: sar@equality.gov.ie
The contact details for the CSO DPO are:
Ms Maria Hurley,
Data Protection Officer,
Central Statistics Office,
Skehard Road,
Cork
T12 X00E
Tel: 021-4535000
Email: dpo@cso.ie
The Economic and Social Research Institute (ESRI) is also involved in GUI. The ESRI is commissioned by DCEDIY to carry out the GUI survey on the Department’s behalf. The ESRI is a research institute with income from research funded by a number of government departments and agencies, commissioned research projects, competitive research grants and a government grant-in-aid.
The ESRI collects GUI data on behalf of DCEDIY and is the Data Processor under the GUI contract with DCEDIY.
What is Growing Up in Ireland?
Growing Up in Ireland (GUI) is the national longitudinal study of children in Ireland, funded by the DCEDIY. The study is managed and overseen by DCEDIY in cooperation with the CSO. It is carried out by a consortium of researchers led by the Economic and Social Research Institute (ESRI).
All GUI data is collected under section 24 of the Statistics Act, 1993. The Statistics Act protects the confidentiality of the data you provide to the GUI survey and ensures that it can only be used for statistical purposes.
GUI collects data to help inform public policies and services relevant to children, young people and families in areas such as education, childcare, physical and mental health, employment, training and social inclusion. All procedures and protocols adopted in the GUI survey, as well as all questionnaires and tests used, undergo rigorous ethical scrutiny by an independent Research Ethics Committee.
GUI involves collecting data through surveys of children, young people and their parents or guardians. Data about the children are also collected from their school teachers when they are at primary school. Data about the schools which GUI survey participants attend is collected from school Principals. GUI is a longitudinal survey, so the same individuals are contacted on several occasions over time so as to help us understand how the lives of the children and young people are developing and progressing.
There are two groups or cohorts surveyed by the GUI project: Cohort ’98 most of whom were born in 1998 (and their parents/guardians); and Cohort ’08 most of whom were born in 2008 (and their parents/guardians).
Data collection for Cohort ’98 started when the children were 9 years old in 2007/2008 and took place again when they were aged 13, 17 and 20 years old. Data collection for Cohort ’08 started when the children were infants at 9 months old in 2008/2009 and took place again when they were aged 3, 5, 7/8, and 9 years old. Cohort ’08 will be surveyed again in 2021 when the children are 13 years old.
Definitions
Personal data means any information relating to a living individual who can be identified, directly or indirectly. It can include a name, an identification number, location data, an online identifier or one or more factors specific to an individual’s physical, physiological, genetic, mental, economic, cultural or social identity.
Special categories of personal data mean data revealing racial or ethnic origin; political opinions or religious or philosophical beliefs; trade union membership; genetic data; biometric data; data concerning health; individual’s sex life or sexual orientation.
Processing means doing anything with the data, such as storing, accessing, disclosing, destroying or using the data in any way.
What is the purpose and lawful basis for processing personal data from Growing Up in Ireland survey participants?
Article 6 of the EU General Data Protection Regulation (GDPR) sets out the lawful bases under which personal data can be processed. There can be more than one lawful basis for personal data processing. The lawful bases for processing data from GUI come from Article 6 (c) and (e) and are explained below.
Additionally Article 9(2) (j) provides for the processing of special categories of personal data for statistical purposes. This includes data collected in all rounds of the survey on ethnicity, religion, health (including mental health); and data collected in some rounds of the survey on political views, trade union membership, sexual orientation and behaviour. These are further described below under ‘Survey Data’.
The ESRI is a data processor for GUI and processes your personal data and special categories of personal data for statistical purposes in accordance with data protection legislation. In this regard, the results of the GUI study are made public but without identifying individuals, so that they can inform research and policy. GUI survey data can only be used for statistical purposes and personally identifiable data from the survey is not shared by DCEDIY, the CSO or the ESRI with any third parties outside of the GUI project.
In order to make the best possible use of the information provided by survey participants, the Central Statistics Office – operating under the strictest controlled procedures – may link the information from this survey to other types of information held about survey participants or the areas they live in. This would only be done for statistical research purposes under the Statistics Act 1993. Data linkage would be carried out after all identifying information such as name, address, PPSN is removed and replaced by a Protected Identifier Key (PIK). The PIK allows data files to be matched without using directly identifiable information. The PIK would be the only identifier retained on these files and only a limited number of people in CSO would have access to the linked files. The results of the analysis would not include any personal information about participants. For further information on any current CSO data linkage projects see https://www.cso.ie/en/aboutus/lgdp/csodatapolicies/csodataprotocol/csodataprotocolregister/
What personal data do we process on Growing Up in Ireland survey participants?
Contact Details: Since the same individuals and families are contacted over time, the GUI Study Team at the ESRI need to keep contact details for GUI participants, parents and children or young people, in order to conduct the surveys on behalf of DCEDIY. The contact details include: name, address, telephone number, email address, mobile telephone number and the contact details of someone, such as a grandparent, who may be able to help us keep in touch with the family if they move house. GUI also holds data on household GPS and eircode.
CAO number: This information is provided by some survey respondents who agree to give it during the GUI survey. It is used solely for the purpose of matching some of the information provided in their survey interview to the details in their CAO application form for access to further or higher education courses.
PPSN: The PPS number is held for individuals from Cohort ’08 who gave it during the course of the survey for tracing purposes and for the purposes of matching GUI data to other data (e.g. childcare providers).
Survey Data: Information on the child and their parents is collected in the following areas:
Information is also collected from childcare providers, including information about the GUI study child in relation to how long the child has attended the centre, how many hours and days per week they attend and how easy the child is to get on with.
GUI data are mostly collected through survey questionnaires administered by an interviewer using a laptop in the home. Data may also be collected using computer assisted telephone interviews or by the CSO’s online survey systems. However, additional data were collected through personal interviews with 122 parents of Cohort ’08 at nine months old and with 122 Cohort ’98 parents and 122 children at nine years old. These interviews explored the same issues as the GUI survey questionnaire but in more depth.
Full details of the data collected in each wave of GUI can be found in the questionnaires:
https://www.growingup.ie/questionnaires/.
The relevance of the information collected is published in the Design and Instrumentation Reports for the relevant waves of data on the Growing Up in Ireland website:
https://www.growingup.ie/growing-up-in-ireland-publications/
The survey data are stored at the ESRI separately from all identifying information. The survey data are processed internally within the ESRI on behalf of DCEDIY in a pseudonymised form (with all identifying information removed).
These data are processed for statistical purposes under the Statistics Act 1993. Great care is taken to ensure the confidentiality of the data provided. No data are released or published which could identify a particular individual or family.
Under Section 32 of the Statistics Act 1993 all information recorded ‘….shall be used only for statistical compilation and analysis purposes’. Equally, the information recorded in the course of the Growing Up in Ireland Study may not be released in a manner which ‘….can be related to an identifiable person or undertaking …..’ ‘….except with the written consent of that person or undertaking …’ (Section 33, Statistics Act 1993).
Use of the data collected in the course of the Growing Up in Ireland study for any other purpose or release of data in a manner which would allow them to be associated with an identifiable person is an offence under the Statistics Act 1993, and would contravene data protection principles.
Do we share personal data with any third parties?
Personal data collected in the survey is not shared by DCEDIY, the CSO or the ESRI with any third parties outside of the GUI project.
Two types of Growing Up in Ireland datasets which do not contain any directly identifying personal information are made available for legitimate research purposes. The preparation of these datasets is done under the auspices of the CSO and in strict compliance with the Statistics Act 1993 to ensure that the confidentiality of GUI participants is protected.
Currently these datasets are available for data collected from Cohort ‘08 at 9 months, 3 years, 5 years, and 7/8 years; and from Cohort ’98 at 9 years, 13 years and 17/18 years.
Data from Personal Interviews
Datasets based on the additional GUI data collected through qualitative or personal interviews with parents and children in the first waves of Cohort ’98 and Cohort ’08 (at the ages 9 years and 9 months respectively) are also made available for research purposes. These datasets do not contain any identifying information and have been archived at the University of Maynooth, see https://www.maynoothuniversity.ie/iqda
How long will GUI data be stored for?
Growing up in Ireland is a longitudinal project, which involves returning to participants at intervals over several years collecting information about the growth and development of children and young people over time. Given that GUI is longitudinal, it is necessary to retain personal data and sensitive personal data for at least the duration of the relevant participant’s involvement with the GUI project.
Where identifying data are no longer required for the purposes of the survey or where no further data will be collected in relation to a particular participant (e.g. because they have discontinued their participation in the survey or have died), their contact details are deleted to anonymise the data and the anonymised data are retained indefinitely.
What rights do you as the data subject have?
The General Data Protection Regulation (GDPR) confers the following rights on individuals:
Article 89(2) of the General Data Protection Regulation (GDPR) allows derogations from data subject rights where personal data are processed for scientific/historical research or statistical purposes. These apply in respect of your right of access, right to rectification, right to restriction of processing and right to object, but only where the exercise of these rights is likely to render impossible or seriously impair the achievement of the specific statistical purposes.
How can I submit a Subject Access Request?
If you wish to make a Subject Access Request, the most effective way to do so is in writing to the Data Protection Unit at the Department of Children, Equality, Disability, Integration and Youth at the following address:
Department of Children, Equality, Disability, Integration and Youth,
Block 1,
Miesian Plaza,
50-58 Baggot Street Lower,
Dublin 2
D02 XWI4, Freepost F5055
Tel: 01-6473000
Email: sar@equality.gov.ie
You can make a request directly to a member of staff on the Growing Up in Ireland Survey Team. In such instances they will immediately forward the request to the Department’s Data Protection Unit, which will follow up with you on any requirements.
In order to facilitate processing of your request and the timely retrieval of your personal data, you may be asked to provide the following details:
Identification
In order to ensure that personal data are not disclosed to the wrong person, you will need to provide proof of identity before your request can be processed.
If a request is being made on your behalf by a third party such as a solicitor, authority and verification will be sought.
For further information on data protection see http://gdprandyou.ie.
How will the information be provided to you?
Where you make the request by electronic form, where possible the information shall be provided to you by electronic means, unless you request otherwise.
What are the timeframes for dealing with your personal data access requests?
Your request must be responded to within 1 month from the date of validation of the request and your identity. The period may be extended by a further 2 months, where necessary, taking into account the complexity and number of requests. In this case, we will inform you of any extension within 1 month of receipt of the request, and the reasons for the delay.
What are the charges?
There is no charge for your Subject Access Request.
However, if your request is considered ‘manifestly unfounded or excessive’ (for example excessive repeat requests or where the problems associated with identifying you as an individual from a collection of data are too great) we may:
1. Charge a reasonable fee, taking into account the administrative costs of providing the information/taking the action requested; or
2. Refuse to act on your request.
Right to lodge a complaint to the Supervisory Authority
Under data protection legislation 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: 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/