Mr. Dermot Woods:

I might add something that could be helpful to note. I am not particularly involved in the development of the legislative proposals on the GDPR and the directive but, as a matter of course, the Data Protection Commissioner will have a role in respect of, for example, a given service provider in terms of the latter's general compliance with the GDPR. The arrangements that will be put in place in that regard, reflecting in more detail what is in the current data protection Acts, require service providers and other private corporations to have in place arrangements of a particular standard for the protection of personal data. In that regard, the Data Protection Commissioner will have a power of enforcement and investigation in respect of that for telephony service providers as she will for any other private corporation.

In addition, there are the layers of judicial supervision at District, Circuit and High Court levels. It is due to the specific nature of the data that are held and processed, for example, in respect of members of a criminal gang or people who carry out criminal offences, that we think it is important to retain the independent scrutiny at a judicial level. All of that is in addition to the general scrutiny that would be available in law anyway to the Data Protection Commissioner. The general data protection regulation, GDPR, will not take away that role from her in respect of the investigation and oversight of data controllers' management of personal data.