Residential Tenancies Board (Register of Users)

Last updated March 2020

Does your organisation use the PPS Number at present?

Yes.

For what purposes?

• The RTB is a statutory body responsible for (but not limited to) the operation of a national registration system for all residential tenancies, the operation of a dispute resolution service, the provision of both information and policy advice, and completion of research regarding the rental sector.
• PPS Numbers are used as reliable identifiers in the course of carrying out the RTB’s statutory functions under Section 151 of the Residential Tenancies Act 2014 - 2019 and associated enquires and in the context of the bringing of proceedings relating to under residential tenancies legislation and the enforcement of determinations made in relation to these proceedings. PPS Numbers are used for identification and verification of service-users on our internal systems and are also used to identify duplicate records. PPS Numbers are subject to verification at various stages of the RTB’s processes.

The principal functions of the Board include:

• Tenancy Registrations
• Landlords are required to register tenancies with the RTB, Section 136 of the Act specifies that the registration must include the PPSN of the landlord; the PPSN of the agent (where applicable); the PPSN of the tenant/s (unless it cannot be ascertained by reasonable inquiry).

Registration Enforcement

Landlords who fail to register their tenancies can be prosecuted under Section 144 of the Act. The RTB uses PPS Numbers on a case by case basis to obtain current contact details from the Department of Social Protection for parties on whom it wishes to serve correspondence (e.g. enforcement letters).

Dispute Resolution and Enforcement of Determination Orders

PPS Numbers are used to obtain current contact details for parties on whom it wishes to serve correspondence, e.g. Notices of Adjudication and/or Mediation Hearings, Notifications of Tenancy Tribunals; the resulting reports arising from these hearings and/or Tribunals, legally binding Determination Orders, letters pertaining to the enforcement of these orders, Notices of legal proceedings, etc. This information is obtained in accordance with Section 146(2) of the Act.

Investigations and Sanctions

PPSNs are used to investigate potential breaches of rental law by a landlord in relation to section 7a of the Residential Tenancies Act 2004 – 2019. The RTB uses PPS Numbers on a case by case basis to identify records internally and/or obtain current contact details from the Department of Social Protection for parties on whom it wishes to serve correspondence

Administrative purposes

The RTB also uses the PPS number for employee record purposes within the HR and Finance units. This includes (but not limited to) employment record, pensions, transactions and communications with shared services.

Does the board exchange the PPS Number with any external body? If so, please name the relevant bodies and state the purpose(s) of the exchange

The Department of Social Protection

The Department of Social Protection receives an extract of the RTB's register of tenancies for the purpose of identifying suspect activity and target reviews of social welfare claims that may result in savings to the exchequer.

The RTB receive files from the Department of Social Protection of tenancies approved for rent supplement allowance, our system uses the PPSN as a unique identifier for matching against registered tenancies.

The RTB uses PPS Numbers on a case by case basis to obtain current contact details from the Department of Social Protection for parties on whom it wishes to serve correspondence (e.g. Notices of Adjudication and/or Mediation Hearings, Notifications of Tenancy Tribunals; the resulting reports arising from these hearings and/or Tribunals, legally binding Determination Orders, enforcement letters, Notices of legal proceedings, etc.).

Local Authorities

The RTB receive files on a quarterly basis from Local Authorites of tenancies approved Housing Assistance Payments, our system uses the PPSN as a unique identifier for matching against registered tenancies.

Revenue Commissioners

The RTB may make enquiries on a case by case basis to Revenue, providing the name and PPSN of the person in question, and seek a response from Revenue under sections 8(b), 8(d) and 8(e) of the Data Protection Act, 1988.

Information is supplied to the Revenue Commissioners in accordance with Section 147A and Section 148 of the Residential Tenancies Act 2004 to 2016.

Central Statistics Office

The CSO may obtain administrative records from the RTB, for statistical use, under Section 30 of the Statistics Act, 1993.

What future plans has the Board for the use of the PPS Number?

It is intended to use a Public Service PPS number validation system in the RTB’s new Tenancy Management System. RTB360

There is a duty to ensure compliance with the principles of processing personal data which are set out in Article 5(1) and 5(2) of the GDPR. These principles are summarised as follows

• Process it lawfully, fairly, and in a transparent manner;
• Collect it only for one or more specified, explicit and legitimate purposes, and do not otherwise use it in a way that is incompatible with those purposes;
• Ensure it is adequate, relevant and limited to what is necessary for the purpose it is processed;
• Keep it accurate and up-to-date and erase or rectify any inaccurate data without delay;
• Where it is kept in a way that allows you to identify who the data is about, retain it for no longer than is necessary;
• Keep it secure by using appropriate technical and/or organisational security measures;
• Be able to demonstrate your compliance with the above principles; and
• Respond to requests by individuals seeking to exercise their data protection rights (for example the right of access

Have you measures in place to ensure that the Public Service Identity data you hold/collect whether in electronic or written format is in line with the GDPR Principles described above?

Yes. The RTB have a variety of data protection policies and procedures to ensure compliance with data protection legislation. The RTB is registered with the Data Protection Commission and takes all reasonable steps to ensure the security of all data, including PPS Numbers. Staff are trained in data protection and a Data Protection Officer is appointed in line with our obligations, who continuously reviews all processes to ensure best practice privacy protection.