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A general comment: DEASP are making a great deal of noise about their survey on #PSC. It's mad popular they tell us.
So is not paying taxes. We'd all love not to do that. But if you decide not to pay taxes, no matter how popular that is, Revenue have words. Popular != Legal.
So is not paying taxes. We'd all love not to do that. But if you decide not to pay taxes, no matter how popular that is, Revenue have words. Popular != Legal.
Page 5: Cites some of the history of the card. That's nice. However, the debate (as @ciananbrennan has pointed out) the dail record of the debate is worth reading bit.ly/2LY9F8o
And what the history ignores is that #DataProtection law has evolved since 1998.
And what the history ignores is that #DataProtection law has evolved since 1998.
On page 6, the Dept makes a comment that people have wanted the use of #PSC expanded. Again - perceived popularity != legal basis.
So far what I get is "this might be a good idea with merit that should have been done properly".
So far what I get is "this might be a good idea with merit that should have been done properly".
Page 7, paragraph 5 of the response makes a claim that there has been no hacking of PSC. That's a relief, but was not something that DPC was claiming (they are looking at security overall in Module 2). (But over 20 years in this business has made me superstitious...).
The introductory section also references getting advice from the Attorney General and also that they sought meetings with the DPC after report was received.
Key point: This never happens. Once the Final report is issued, DPC doesn't change things.
Key point: This never happens. Once the Final report is issued, DPC doesn't change things.
The Dept includes a letter dated 9th August 2019 from DPC to Dept in the pack where DPC addresses this point.
It doesn't include the previous letters between the Dept to the DPC that were being responded to (see page 65 of the Dept response document).
It doesn't include the previous letters between the Dept to the DPC that were being responded to (see page 65 of the Dept response document).
The next few pages of the Department's response baffle me a bit. I'll need to address them in a longer format somewhere else. But it largely reads as a complaint that @DPCIreland didn't delay their decision making process to allow for further responses.
The Dept helpfully lists the draft report findings and the final report findings in a comparison table on pgs 14-18. Bear in mind that they are claiming substantial changes and the addition of a new finding in the final report. Let's look at that...
