Why. Why is it like this?
"Base registry". "Base registry owner."
The Governance part, one might have thought, is covered by the GDPR & DPAs. But no, it creates a shadow system.
This Bill has external consultant fingerprints all over it.
Why would a public body notify DPER if a citizen makes an SAR?
An auto-deleting backchannel to the Minister?
But this is an advisory board for DPER, not a watchdog.
It needs serious pre-legislative scrutiny and committee work/challenges.
"There are some significant missed opportunities in ... [the] legislation. But the sum of the parts is increasingly disconcerting & suggests that the Irish Government doesn't *get* data protection and data management at a fundamental level."