Dr. Fred Logue:

In principle, it can be both. If powers exist to make regulations which facilitate data processing, this can be done under the 2018 Act. Things like CCTV will probably need their own sectoral legislation. The use of CCTV is pretty limited at the moment under the Garda Síochána Act 2005 and this does not really work for the enforcement of legislation regarding traffic or litter. It was really meant only to allow for An Garda to carry out public order investigations. When passing legislation for sectors, the procedure does not involve checking to see whether specific data processing provisions are required. I am not sure how it works, but it would be beneficial if a recommendation was made to build into parliamentary procedures a requirement to check at an early stage whether such provisions should be included rather than finding out when something goes wrong after the legislation has been passed.