The Department of Social Protection warned Irish Water at their very first meeting that child benefit details could not be reliably used for the purposes of allocating allowances for water charges.
Tensions between the utility and the department over Irish Water's requests to access citizens' data are evident in email exchanges which were released to The Irish Times under Freedom of Information legislation.
The documents reveal that, despite the department’s warnings, Irish Water continued to plan around getting access to the information, right up until the requirement to provide PPS numbers was dropped when the Government’s new water charges plan was announced in November.
Irish Water has now begun the process of deleting the PPS numbers it captured on the first application forms sent out from September, and said it will "will consult with the office of the Data Protection Commissioner to establish the parameters for independent verification by a third party of the systems put in place to manage the removal of PPS numbers".
Records from June to November reveal frustrations within the department over the water utility’s failure to engage with it.
They indicate clearly that, while Irish Water insisted it needed access to the PPS information in order to validate water allowances, it was not sure how to go about getting the information, what data it really needed, or what it would do with it, if and when it got it.
It was warned by department officials that its plan to base decisions on child water allowances could not be reliably based on decisions the department had made on awarding child benefit.
Documents prepared internally to assess how the department could go about facilitating Irish Water, state it was generally collecting a male householder’s PPS number, whereas child benefit was primarily paid to mothers.
In addition, the method of verifying on an ongoing basis that a child was under 18 (for the purposes of allocating water allowances) would be “onerous and inefficient” for both organisations, the department indicated.
In August, just days before Irish Water began sending out application forms to householders, customer service manager Mike Cody acknowledged there appeared to have been “a vacuum created” in terms of its contact with the department since an earlier informal meeting. He sought to re-engage with it on the exchange of data.
While, in theory, the utility was by then legally allowed to collect PPS numbers (after Tánaiste and Minister for Social Protection Joan Burton made an amendment to the Social Welfare Bill in the summer), it had not agreed any of the protocols required to let it use the information.
Publicly, the Tánaiste and other ministers were insisting the PPS data would only be used by Irish Water to validate allowances and that it, like any other body using the PPS, would face sanctions for its misuse.
However, behind the scenes, it was clear there was concern among department staff.
The Data Protection Commissioner’s office also rang the department on a couple of occasions to indicate it had been dealing with a significant number of queries from the public about the PPS issue.
The department too was fielding calls from citizens concerned their PPS numbers would be handed over, and officials expressed concern they would end up being sucked into arguments about decisions made on water allowances that were nothing to do with them.
One official noted in an email he had not been “in the loop” re Irish Water, adding it was a “lucky escape by all accounts”.
A spokeswoman for the Data Protection Commissioner said it remained in contact with Irish Water in relation to its intention to remove from its systems the PPS numbers it had collected.