Technological University Dublin (Blanchardstown, Dublin City Campus and Tallaght)

Does your organisation use the PPS number at present?

Yes

If so, for what purpose(s)?

Technological University Dublin (TU Dublin) securely holds data on employees and students including PPSNs on our network, and on a range of proprietary management information systems (Finance Administration (Agresso), Student Records system (Banner) and HR and Payroll (CoreHR). The management information systems are hosted and supported by third party companies under a Client Services Agreement with EduCampus Services.

Employees:The PPS number is used in relation to employees for the following operations:

• the management and administration of the university Integrated HR and Payroll System CoreHR database of staff data and information for payroll records, Illness benefit management, taxation, the administration of social welfare entitlements and the administration of pension schemes through the universities
• production of certain pension scheme documentation, for example, Single Pension Scheme Benefit Statements and also in the final payment authorisation to the Pensions paying authority
• administration of redundancy and enhanced redundancy schemes
• PPSNs are also recorded as a unique identifier on the TU Dublin accounting system in relation to sundry payments. These are retained for financial reporting purposes in line with the retention period for financial records
• National Optometry Centre (NOC) uses the PPSNs of patients applying to the Department of Social Protection for optical benefit. We also use the PPSNs of children applying to the Health Services Executive Primary Care reimbursement service for optical benefit. This is in accordance with the agreement that governs these treatment benefit schemes
• Industry Training - participants are asked to fill out and return registration forms for the purpose of admissions and registration on Banner
• New Frontiers - to enable TU Dublin to make payment of New Frontiers scholarship stipend to participants
• Learn + Work - applicants apply to programmes online through our website. They give their PPSN as part of this process. The applications are dealt with directly by the admissions department. As a result Learn + Work student/applicant PPSNs do not come through to the LINC, and we do not collect that information, process that information, or have direct access to it

Students:The PPSN is used for the following operations:

• administration of pay authorisation and identification for payroll purposes in relation to students in receipt of a stipend (post graduate students in receipt of a Strategic Research & Development (SRD) grant payment). Information is passed onto the HR team to process payments. PPSNs are recorded as a unique identifier on the TU Dublin payroll system
• aministration of post graduate student registration forms
• administration of post graduate scholarship exemption declaration forms
• administration of tax relief forms for students who wish to claim tax relief on their student fees
• administration of the student records system (Banner) - PPSNs are collected by the CAO (for all full time students) & SOLAS (in relation to apprentice students) and provided to TU Dublin along with other CAO data. PPSNs of direct entry students are requested directly from the student themselves and are used as a unique identifier on our student records system (Banner) along with date of birth to ensure accuracy of student records and avoid duplication
• administration of the student grant scheme – PPSN is used as a unique identifier to provide SUSI (Central Grant Authorising Authority) with accurate registration and attendance records
• administration of the annual statistical returns of data to the Higher Education Authority (HEA). PPSNs are included in the data on the students that we are obliged to return to the HEA as part of our annual return
• administration of the annual returns to the Department of Social Protection in accordance with the provisions of the Social Welfare Consolidation Act, 2005. TU Dublin provides the PPSN for all registered students as part of returns made on 31 October each year

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

Yes

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

Revenue Commissioners:

• in relation to payroll and taxation affairs of employee/retiree’s as required by the Revenue Commissioners
• for the administration of Professional Services Withholding tax
• where sole trader (low value €) creditors are not registered for VAT, their PPSN is requested and returned as part of the S891b annual return
• weekly/monthly submission files to Revenue; PAYE returns and request from CSO for Employer Identification Inquiry

Department of Social Protection:

• in relation to social welfare entitlements, sick leave benefits/absence payments and pension benefits and related matters
• for verification purposes

Department of Public Expenditure and Reform (DPER):

• the Single Pension Scheme which applies to all new entrants to the Public Sector since 2013. PPSNs are included in the returns to DPER in respect of this scheme
• required under the Part 5 of the Data Sharing and Governance Act 2019 for submitting data to the single scheme databank

Department of Finance, Payroll Shared Services Centre (PSSC) – Paymaster General:

• information pertaining to the award of pension benefits to retired staff members and dependents of deceased staff members and deceased retirees

Higher Education Authority

• quarterly staff statistical returns

Enterprise Ireland

• in relation to the New Frontiers Programme to identify clients/participants

Financial Institutions:

• only on the explicit request of an employee or retiree, or with their consent, would banks and building societies be given details of an employee’s income including their PPSNs

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

Revenue Commissioners:

• to complete tax relief forms for students
• for postgraduate students receiving stipends, TU Dublin, Tallaght liaises with the Revenue Commissioners to ensure that the payment of stipends is compliant with tax legislation. The PPSN is used as a unique identifier for these students
• submission to the Revenue Commissioners of post graduate student Scholarship Exemption declaration forms in relation to PRSI exemptions

Higher Educational Authority (HEA):

• in relation to Annual Statistical Returns - PPSNs are returned as a mandatory requirement in the annual HEA SRS Return for all students and graduates returned within the appropriate statistics for each academic year
• the HEA require PPSNs for every IE domiciled student as part of the biannual SRS returns. Concerns have been raised with the HEA over the legal basis for this, and they have written to us indicating that they have a robust legal justification for collecting it. They have also advised that students whose PPSNs are not returned will not be funded, for example, free fees and should be de-registered

SUSI – (Student Universal Support Ireland) (Central Grant Awarding Authority):

• the university obtains PPSN from SUSI in relation to students who are applying for grant support and their PPSN is used as a unique identifier for these students in the administration of processing grant applications and payments
• the university returns PPSNs to SUSI to verify identity of SUSI grant claimants – SUSI use the PPSN as their unique identifier, and it is the identifier used in the information they send to us on grant eligibility. If a student does not give us their PPSN, they do not get their grant

CAO – (Central Applications Office):

• students applying both directly to TU Dublin and through the CAO are requested to provide their PPSNs on application forms. The number is used as a unique identifier

Department of Social Protection:

• social welfare payments and full -time Student enrolments
• we are required under the Social Welfare Consolidation Act 2005 to return data relating to full-time students to the Department of Social Protection on 31 October each academic year. PPSN form part of that return

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

No.

At this point in time the university has no future plans for uses of PPSN other than for what is stated in this document, however, as a public body, we may become party to shared service arrangements with other bodies as part of the public service reform agenda or in pursuit of efficiencies under the reconfiguration of Higher Education Structures. In addition we may need to outsource certain areas of our activities, to include for example payroll or pensions. In such circumstances the PPSN would be form part of those arrangements.

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 whom 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
• 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

Technological University Dublin complies with its obligations under existing GDPR and Freedom of Information legislation and has appropriate measures in place to ensure compliance with its obligations set out in Article 5(1) and 5(2) of the GDPR.

The university has a framework of measures (policies / procedures, protocols, resources & training) in place to demonstrate compliance with the GDPR principals described in section (v) of the university Data Protection Policy and Records Management Policy / Records Retention Schedules are in place. Access to university systems is restricted to authorised users.

• staff PPSNs are held electronically on our dedicated Payroll/HR system (CORE), access to which is restricted to a limited number of personnel
• staff PPSNs may, in limited cases, be in hardcopy format in their personnel files in the HR office, and in the payroll office. These files are maintained in secured fireproof filing cabinets in the HR/payroll office and access to which is restricted to the staff in the area by means of a swipe card entry system and also in an archived storage area which is locked and secured
• student PPSNs are maintained in electronic format on our dedicated system (Banner) and access to which is restricted to approved university staff. Staff personnel documentation is stored on the secure internal drive which is backed up daily
• hard copies for New Frontiers and Research Administration are kept in locked filing cabinets, soft copies are stored on the secure internal drive, all as per our records retention policy
• data collection notices are available on the university website. This collection notice sets out the reasons the HEA require us to collect personal data from students who register with the college

PPSN Register of Users - Educational Institutions and Education and Training Boards (ETBs).