The context for this processing operation is heavily influenced by the emergency nature of the present public health crisis. Data for analysis and decision making is required to be processed swiftly and as efficiently as possible, whilst remaining compliant with law, including in respect of the necessity and proportionality of the processing.
In processing administrative data , the CSO acts under Article 6(e) of GDPR - task carried out in the public interest or in the exercise of official authority vested in the Controller (Statistics Act, 1993), while in respect of special category data such as applicable here, it is acting under Article 9(2)(i) – public interest in the area of public health and Article 9(2)(j) – processing is necessary for statistical purposes in accordance with Article 89(1) of GDPR. No alternative sources of this data are available and the data is available only in the current format, due to the ongoing operational emergency.
The CSO is currently engaged with all registered users of this data to compile a detailed Data Necessity and Proportionality Assessment (DNPA). This exercise will identify which specific datasets within each data flow are being actively used by each user and whether any, on balance and having regard to the rights of data subjects, may be deemed either not necessary or proportionate. At a later stage, this exercise will be repeated at a variable level. It is expected that this will be completed within a year. For completeness, we are including all COVID-19 data flows in this exercise, including those which do not contain personal data. In the interim, any direct personal identifiers received are securely pseudonymised on receipt as described previously in this DPIA and none is ever available for statistical analysis.
All CSO activities are undertaken in the context of the Statistics Act, 1993. All staff dealing with the health data are appointed as Officers of Statistics under Section 20 of this Act and operate under strict obligations of confidentiality, including signing the Declaration of Secrecy specified under Section 21 of the Statistics Act, 1993.
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