Mr. Tim Duggan:

I thank the Chairman for the invitation to appear before the committee today. I have responsibility in the Department of Social Protection for client identity services, which manage the PPS number and associated public services identity dataset, as well as the public services card currently in roll-out. We support the use of all three of these elements across the entire public service. I will briefly describe each of them to the committee, so members can understand them and their relationship with each other. I will then give a brief view on the part they might be able to play in an electoral register.

The PPS number, as members will know, is an individual's unique reference number for all dealings with Government Departments and public bodies. How it is governed is set out in the Social Welfare (Consolidation) Act 2005. Only those Departments or public bodies authorised by that legislation or their agents can use the PPS number as a personal identifier. A body that is so authorised is usually referred to as a specified body.

A PPS number is automatically issued in the case of children born in Ireland. In other cases, PPS numbers are issued in accordance with a controlled procedure following a personal attendance at one of the Department's dedicated PPS number registration centres, submission of a completed application, the capture of a photograph and signature, the submission of appropriate identity documents and proof of address, as well as the capture of additional data such as answers to security questions, which we use subsequently to ensure the future integrity of that data, in other words, that someone else cannot change it. We publish the information on that process in a whole load of places, including our own offices, citizen information centres, embassies, immigration advice centres and so on. As a result, people who attend our offices to get a PPS number are usually well informed and have all the necessary documentation. It is only in very rare circumstances that somebody would have to attend more than once to be allocated a PPS number.

Associated with that number is a full identity dataset, known as the public service identity dataset. That itself is also set out in the Social Welfare (Miscellaneous Provisions) Act, 2002. Currently, that dataset consists of the PPS number, a person's surname, forename, date of birth, place of birth, sex, address, nationality, photograph, signature, any former surnames the person may have had, any former surnames his or her mother may have had, the date of death in the case of a deceased person, and any other information that the Minister may prescribe as necessary to validate and authenticate an identity. That last provision has not been used to date.

In addition to the PPS number and public service identity dataset, there is the public services card, which more and more people getting, particularly if they are customers of any kind of the Department of Social Protection. The purpose of the public services card is to provide people with a robust token of identity to enable them to gain access to public services more efficiently and with a minimum of duplication of effort, while at the same time preserving their privacy to the maximum extent possible. It is designed to replace other cards which people currently use in the public sector, such as the free travel pass and social services card. It has the potential to replace a great number of other cards as well. Those possibilities are currently being examined.

Considerable progress has already been made on the roll-out of the public services card. Over 1.46 million cards have been issued up to yesterday, including 464,000 free travel versions of it. Face to face registration for the card is taking place countrywide in 97 offices of the Department. Some customers whose identities are regularly authenticated in a face to face process can avail of an easier postal registration process. Registration is now required for individual adult applicants for a PPS number and for those applying for or in receipt of social protection payments or benefits. In other words, it is no longer possible to get a PPS number without also registering for a public services card.

In order to ensure that a person receives only one PPS number and the public services card is allocated on the basis of information that is accurate and verified, certain operational procedures are prescribed for registration personnel who are dealing with applications. It is necessary to have effective controls around the process to guard against fraud and protect the integrity of the data. Evidence of identity is a vital element of the process. Once the identity of an individual is verified, his or her relevant identity data is entered on our records and a batch process is run each night to allocate the PPS number itself. A number of system validation checks are part of this process, to prevent multiple numbers being issued to the same person. The accuracy of the information gathered from the individual is therefore critically important.

The face to face process for someone who already has a number involves the capture of his or her photograph and signature, the verification of his or her identity through documentation and checks of back-end databases, and his or her current address through documentation, as well as the capture of some security questions. As part of the roll-out, we have invested in facial recognition software which ensures that multiple or fraudulent identities can be detected at the point of registration. In other words, if someone is already registered and seeks to register again under a different identity set, the facial image recognition technology we use will prevent that from occurring, in the main. During the course of the process, the software searches for photographs which we already have in our database against that scanned in for the individual applicant. Only when all of those checks are completed will a public services card issue to a person. Today, that is the only means by which a PPS number can be issued as well. As a result, a public services card now provides a very substantial assurance of the identity of its holder.

We transfer our identity data to a system called the single customer view, which is operated by the Department of Public Expenditure and Reform on our behalf. This provides a central repository of identity data - that which is in the public service identity dataset - and can be used by other public bodies to do two things. First, it can be used to verify the public service identity data presented by somebody coming to the public body and, second, to provide the public body with assurance on the verification status of a person's identity. I can go into detail on that if the committee wishes.

To sum up, the public services card registration process is by far the most robust system of identity verification in the State today. In this context, we understand the Minister for Foreign Affairs and Trade has decided that, in future, new applicants for passports will have to undergo public services card registration before they can receive a passport. In addition, we understand that the Road Safety Authority is upgrading its national driver licence service application process so that it is compatible with our registration process. Therefore, somebody who applies for and gets a driver's licence will get a public services card as part of the same registration process. The committee may also wish to note that Statutory Instrument No. 35/2014 provides that the public services card is specified as an identification document acceptable in the electoral process. A person can prove his or her identity at a polling station using just a public services card.

On the electoral register, the Department considers that the PPS number, the public services identity dataset and the public services card could have a role to play in the establishment of the electoral register and its subsequent maintenance, and in checking against it.

In that regard, we would be more than willing to discuss the implications of the PPSN being used as the unique identifier for those purposes. If this proposal is being seriously considered there is no point in using the number just for setting up the register. That data would need to be maintained and this would require, in our view, regular exchanges of data, most likely through that single customer view system that I mentioned earlier. Accordingly, the Department's view is that this could best be facilitated through a single register, to avoid duplicate entries across multiple registers, although we take the Data Protection Commissioner's point that there may be an alternative central verification mechanism through which this could be done. In this context, there may be a need to look at the legislation and data protection memorandum of agreement so that data can be legitimately exchanged between the relevant public bodies. The Department would not be in favour of making the PPS number publicly available along with other register data that is made publicly available.

The Department thinks that it may be feasible to consider the public services card as the means by which a person could prove his or her identity at a polling station, as it would provide both a physical check in terms of the name and photograph on the card but also a system check using the PPS number on the card against the register.

It is worth noting that just because a person has a PPS number, that does not confer any rights of any kind on the person. It simply means that the person has registered his or her identity to a very high level with the Department of Social Protection. It confers no right and in particular, does not confer any right to vote.

The Department is clear that the decision on who has the right to vote would be outside its remit in this regard but we are more than happy to discuss this with the relevant Departments if it wishes to explore the issue further. I will do my best to answer any questions from members.