Trinity College Dublin (Register of Users)

Does your organisation use the PPSN at present?

Yes. Trinity College Dublin (hereinafter ‘the University’) uses PPS numbers.

If so, for what purpose?

PPS numbers are used by the University as unique identifiers for employees, retirees and students in their dealings with the University. The numbers are used in the payroll, human resources and student registration systems and processes operated by the University.

Does your organisation exchange the PPS number with any other body? If so please name the relevant bodies and the purpose(s) of the exchange.

With respect to current and former employees, PPS numbers are exchanged with the following bodies for the reasons stated below:

• Revenue Commissioners (Income Tax)
• Department of Social Protection (Social Insurance)

With respect to students, PPS numbers are exchanged with the following bodies for the reasons stated below:

• Central Applications Office: students applying both directly to the university and through the CAO (HEAR and QQI schemes) are asked for their PPS number on applications forms. Submission of PPS numbers is required by the CAO for QQI and HEAR applicants and voluntary for all other applicants. The number is used as a unique identifier.
• Department of Social Protection: the university provides PPS numbers to the Department of students who have provided their PPS numbers to the university as part of the returns made in respect of registered students on 31st October each year.
• Higher Education Authority (HEA): where they exist, the university provides PPS numbers to the HEA as part of the Annual Statistical Return. This return covers all registered students on 1st March each year and graduates who have received an award in the preceding year. PPS numbers are also provided to the HEA as part of the First Destination Return of recent graduates. The HEA uses the returns to collate statistics in relation to the higher education sector in Ireland.
• Student Universal Support Ireland (SUSI): the university obtains PPS numbers from SUSI in relation to students who are applying for grant support and the number is used as a unique identifier for these students. The university shares PPS numbers with SUSI in relation to students who are applying for grant support and the number is used as a unique identifier for these students.
• Revenue Commissioners: For postgraduate students receiving stipends the university liaises with the Revenue Commissioners to ensure that the payment of stipends is compliant with tax legislation. PPS numbers are used as unique identifiers for these students.

Does your organisation have any other plans involving the use of the PPS number?

The university has no other plans involving the use of PPS numbers at present.

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 or organisational security measures
• be able to demonstrate your compliance with the above principles
• 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 or collect, whether held in electronic or written format is in line with the GDPR Principles described above?

Yes,

• The university processes PPS numbers by reference to Article 6(1)(c) of the EU GDPR: ‘processing is necessary for compliance with a legal obligation to which the controller is subject.’ The specific statutory provision being relied upon is Section 262(4) of the Social Welfare Consolidation Act 2005 as amended: ‘A person shall give to a specified body his or her personal public service number and the personal public service numbers of his or her spouse and children, where relevant, as required by the body for the purposes of the person's transaction.’
• The secure processing of PPS numbers is outlined in our Privacy Notices and is carried out in compliance with relevant university policies and procedures as is required under data protection legislation. Access is restricted to designated personnel only. Further information is available at privacy notice and from the university data protection website
• PPS numbers are processed only for the purpose for which it has been obtained and is kept accurate and up-to-date at all times.

• PPS numbers are retained for a specific period of time and deleted when no longer required in compliance with the university’s Records Management Policy and Records Retention Schedule

• the university’s Data Protection Policy details the University’s commitment to data protection compliance

• the university’s Data Subject Rights Request Procedure is available at your rights