The Higher Education Authority (An tUdaras um Ard-Oideachas) (Register of Users)

Last updated February 2020

Does your organisation use the PPSN at present?

Yes.

If so, for what purpose?

The HEA uses the PPS No. in respect of payroll returns which are made to the Revenue Commissioners.

The Statistics Unit in the HEA use PPSN as a unique identifier for analytical purposes, e.g. to track students across institutes and determine how many students are in each institute for funding purposes. PPSN is also used to facilitate SUSI data checks against the HEA student database to determine previous attendance in higher education (provided for under the Student Support Act 2011). PPSN is also used to link into other administrative Government datasets, e.g. Revenue and Social Protection data in the CSO (provided for in the Statistics Act 1993).

The Springboard+ programme, which is managed by the Skills and Engagement section of the HEA on behalf of the DES, also use the PPSN as a unique identifier for applicants to Springboard+ programmes. It helps the HEA to track the number of course applications made by individuals and therefore their eligibility for the programme.

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?

• CSO – To conduct analysis on linked administrative datasets, e.g. Revenue and DSP data.
• SUSI – To allow PPSN checks against enrolment records for grant application verification.
• Department of Education & Skills – To allow for transitions analysis from 2nd level and projection of demand for 3rd level.
• SOLAS – To allow for transitions analysis – further education to higher education.
• Under Springboard+ PPSNs are shared with the DES as part of the monitoring and evaluation of the programme.
• Course providers of Springboard+ programmes also have access to PPSNs to ensure that applicants are eligible for the programme.

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

Yes, verification of PPSN data with DSP.

Springboard+ has no plans for the use of PPSN, other than what is outlined above.

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. We have completed a full data protection impact assessment covering our data processes in the Statistics Unit, including collection, storing and use of PPSN data. The DPIA covers the necessity and proportionality of collecting and using PPSN data. IT/database security has been upgraded to ensure safe storage of key data including PPSN. We have signed data sharing agreements with higher education institutions which include our legal basis for collecting and using PPSN data – the 1971 Higher Education Act, Social Welfare Consolidation Act 2005 (HEA and institutions are Schedule 5 bodies) and SI 317 of 2015. A DPO for the HEA has been appointed and deals with all data protection related matters including subject access requests.