Ms Helen Dixon:

The report indicates that even today it is not entirely clear what the card represents proof of. Is it definitive proof of address? How can it be if someone has changed address since they completed SAFE 2 registration? In fact, how a person is supposed to change their address is not clear from anything published on SAFE 2 and the public services card, PSC.

The other issue around foreseeability for individuals is that if it is not clear to an individual that procurement of a public services card is to be mandatory to make a school transport appeal, for example, then he or she may at a minimum endure significant inconvenience when he or she discovers at the last minute that this is now a requirement and must submit to having his or her personal data processed in this way. There is a range of issues around transparency concerning what the card is or is not and what it represents proof of. There are even issues with where the card can be presented as an ID card. Section 263 of the Social Welfare Act 2005 provides that any entity which is not a specified body under the legislation cannot have the card presented to it. There seems to be some evidence that individuals are using the card as an ID when they go to the credit union and are required to provide ID. This is prohibited under the Social Welfare Act 2005.

There is a range of issues around foreseeability. I raised a particular issue at paragraph 359 of the report. There has been a lot of talk about how the card allows a "once and done" process. However, paragraph 359 of the report outlines that if I engage with a specified body using my public services card and point out to the specified body that I have since changed address and it records that, I have absolutely no guarantee that the change of address will be transmitted back and recorded on the SAFE 2 register by the Department of Employment Affairs and Social Protection. That does not represent a "once and done" process in those circumstances and it is not foreseeable which address is held by which public sector body. We have identified a range of issues.