Digital Rights Ireland has also rejected a Department of Communications official’s claim that the group is “broadly satisfied” with Eircode, the second time the department’s submission to an Oireachtas committee has been questioned.
In a letter to Mr White, Antoin O’Lachtnain of Digital Rights Ireland said the group is “puzzled as to how the firmly conveyed views of the Data Protection Commissioner about individual house coding were put to one side when the requirements for the code were totally revised without consultation in 2010”.
Eircode proposes a seven-digit postcode for every address in the country. While the first three digits will refer to a wider geographical region, the final four identify unique addresses and are randomised.
The Data Protection Commissioner has long advised the Government against introducing unique codes for every house in the country for privacy reasons, and reiterated this stance in its recent annual report.
Mr O’Lachtnain’s letter on behalf of Digital Rights Ireland was sent following an appearance by Department of Communication officials before Joint Oireachtas Committee on Transport and Communications on November 19 last.
During the submission, Patricia Cronin, head of the Department of Communications’ postcodes division, implied the group was satisfied with the privacy aspects of the code’s design.
“We have spoken to the National Consumer Agency, logistics companies and Digital Rights Ireland, with which we have had an indepth conversation to see if there is anything in the proposal that might be considered to have an impact on anyone’s privacy. Broadly, they are satisfied with what we are doing,” Ms Cronin told the committee.
However in his letter, Mr O’Lachtnain said the group “want to state clearly that we are not at all ‘satisfied’ with the postcode that has been designed or the implementation proposals”.
It is the second time comments made by a department official at the meeting has come into question. Eamon Molloy, assistant secretary at the department, told the committee that a European Commission’s file on a complaint about the tendering process for Eircode was closed.
However, speaking after the meeting a spokesperson for the commission said it only received information from the department on the measures it would adopt to avoid future errors on October 30, and that the communication was still “under assessment”.
In his letter, Mr O’Lachtnain outlined to Mr White the concerns Digital Rights Ireland had communicated to the department.
“To reiterate, we see a great deal of uncertainty and dangerous ‘downside’ in relation to privacy arising from the particular design which has been chosen. These are completely uncharted waters and so it is really impossible to say how great the privacy impact will be,” the letter further warned.