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Transparency Notice – Pensions Authority Data

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 datasets received from the Pensions Authority.

Purpose of Processing:

The purpose of processing administrative data that is collected by other Government Departments and Agencies for their own purposes, which is then used by CSO to efficiently accomplish its mandated objectives, 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.

Legal basis for collection and processing:

Access by the CSO to the Pensions Authority data is underpinned and provided for by 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 (1) (c) (for certain variables/outputs) and 6 (1) (e) of the General Data Protection Regulation (GDPR). Article 6 (1) (c) relates to processing necessary for compliance with a legal obligation to which the controller is subject, while Article 6 (1) (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 enhanced data cooperation between the CSO and the Pensions Authority with a view to utilising the statistical potential of data in various public administration systems to inform policy. This will contribute to enhanced statistical outputs by the Office and to a reduction in the response burdens arising from CSO surveys– deriving from the functions set out under Section 10 of the Statistics Act, 1993 Act.

Processing of the Pensions Authority data is also permitted under Sections 38 (1)(a), 42 (1)(c) and 54 (c) of the Data Protection Act 2018.

Categories of personal data concerned for the Pensions Authority data:

i) Registered Administrator Identification Number

Who uses the data:

The data is received in the CSO by a dedicated business unit called the Administrative Data Centre (ADC) using secure transmission methods.  The ADC is a specialist team responsible for ingesting, processing, transforming, pseudonymising and storing records in a format accessible for statistical analysis. In the pseudonymisation process, all personal identifiers are removed by the ADC. Additionally, once in receipt of the Pensions Authority data, the ADC converts the identifier numbers in each dataset that remain to a Protected Identifier Key (PIK). PIKs are a unique and non-identifiable number which is internal to the CSO. Using PIKs enables the CSO and approved researchers to link to other pseudonymised data and analyse data for statistical purposes, while protecting the security and confidentiality of the individual data.

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 variables may feature in research microdata files, made available to specified researchers, under strict protocols and detailed governance procedures. 

Aggregated statistical outputs derived from the Pensions Authority data will be used by, for example, academics, media, the public, policymakers as well as other national statistical organisations.

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.

At this time, the Pensions Authority data is being retained to ensure that statistics can be replicated over time, to facilitate longitudinal studies and time series analysis and to ensure historic statistics can be generated for new data needs as they arise.

The CSO is continuously evaluating the statistical requirements to balance the interests of data subjects with the requirements for official statistics and retention periods. As part of this evaluation, recommendations may be made during periodic reviews in relation to the retention of data. 

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: 

  1. The right to be informed
  2. The right of access
  3. The right to rectification
  4. The right to erasure
  5. The right to restrict processing
  6. The right to object to processing of personal data

An individual right of access to the personal data furnished by a Public Service Bodies (PSB) is possible. Data Subjects seeking to exercise GDPR rights over their personal data may wish to engage with the source PSB as the controller of first instance.

Should you wish to exercise these rights directly via the CSO, because your data is processed for statistical purposes, certain limitations in accordance with Article 89 of the GDPR may apply.  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 the Pensions Authority data, you may contact the CSO Data Protection Officer on the details set out below. Applications for access will be assessed on a case-by-case basis. It is the intention of the Office to vindicate these rights wherever possible.

The sources and categories of your personal data, where the data has not been collected directly from you:

Pensions Authority

Examples of variables being received by the CSO are outlined under categories of personal data above.

For further information on this survey, your Data Protection rights and how your data is used, please contact:

Gavin Kelly, Statistician, Administrative Data Governance & Analysis, Central Statistics Office, Skehard Road, Cork T12 X00E

Tel +353 (21) 453 5077 Email:

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 email:  

By phone:            01 7650100 / 1800 437 737


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


For further information: