Mr. Finbarr Heslin:

I thank the Chairman for the invitation to speak on the topic of verification systems used in online sales of pets, namely, pet dogs, subsequent to the introduction of the Animal Health and Welfare (Sale or Supply of Pet Animals) Regulations 2019. Fido is one of four databases approved by the Minister under the Microchipping of Dogs Regulations 2015 for the registration and storage of the details of dogs, their owners and the identifying microchips of those dogs in Ireland. Fido’s work in this area predates the 2015 regulations by over a decade, and in almost 20 years of work, we have registered and stored the details of almost 1 million pets.

MODR 2015 is viewed across Europe as an excellent example of how mandatory identification and registration can be legislated for. Several components of the regulations have made it a robust statute. The absence of self-certification, the requirement of the database to time-stamp each transaction and record the details of the person entering the details, the requirement for photo ID and proof of address, and the fact that most data are veterinary certified have all contributed to high-quality data being collected. Every year, thousands of dogs are reunited with their owners when they get lost because of microchips.

Fido has always worked extensively with animal welfare groups and charities. As far back as 2013, we wrote the IT code for a system to provide for independent verification of advertised pets, as we were aware of the massive issues associated with the illegal puppy trade. In the intervening years, and especially during Covid, these problems have got worse, with the cost of pups making puppy production incredibly lucrative. Our verification system was presented to the Irish Pet Advertising Advisory Group, IPAAG, as far back as 2016, but none of the online advertising platforms introduced the system. After the Animal Health and Welfare (Sale or Supply of Pet Animals) Regulations were introduced in 2019, the major online pet advertiser withdrew from the market. Since then, Fido has collaborated with the current main online pet marketplace, Dogs.ie, to introduce the verification system. As Mr. Savage said, it went live in November 2021.

Ireland is in a unique position in that we are the first country in Europe to have a statutory requirement for verification of the details of a dog being advertised for sale or supply. There are several requirements now for advertising animals, but Fido's sole competency in this area is the verification of the microchip number, as Regulation 8(c) states that in the case of a dog, the unique code of the microchip implanted into the animal must be shown.

When the regulations were introduced, many advertisers simply put in fake microchip numbers, adding no improved traceability or transparency to the ads and doing little to improve consumer protection. The Fido PetSAFE system had been developed to overcome this practice.

Anyone who has purchased anything online will most likely have used a two-step authentication system to pay for it. This is where the purchaser's bank sends a verification link to the mobile phone number associated with the credit card account used to ensure that no fraud is being committed. Veripet is a similar technology. With the Veripet application programming interface, API, only the registered owner of a dog is allowed to advertise the dog for sale. The registered owner's details have been independently verified and his or her proof of identity and proof of address have been seen, in most cases by a veterinary surgeon, and certified in the database. When placing an advertisement on a participating classified ad site, the seller will need to provide the dog's microchip number along with his or her mobile phone number or email address. The Veripet API will then carry out an automatic check with the pet registration database that the details match. If they do, a one-time code will be sent to the registered owner of the dog and that code will need to be added to the advertisement in order for it to go live.

As for the detailed steps of how the technical system works, the pet owner or breeder registers the dog on a Department-approved database. The pet owner visits a classified ad site, enters the microchip ID for the dog into the relevant field on the classified ad site, the microchip number for the dog is checked against the information on the database, and a one-time passcode is sent to the telephone number of the pet owner on the database. The IT system developed by Fido has now been integrated into Europetnet to give a federated system across Europe. This will go live in Switzerland in the coming months, with France, Norway and the UK also looking to implement it on the basis of its success in Ireland.

We have been presented with many reasons not to introduce this system by advertisers, but the technical solution provided by Fido has been extensively trialled live in the marketplace and is proven to work, with several thousand ads having now been verified. GDPR concerns are dealt with at the advertisement platform level, which allows for the independently verified details stored on the database to be released to the new owner if there are problems with the pup and the new owner cannot contact the vendor.

Since implementation of the system, some issues have arisen. First, there is little or no recognition by the public of the difference between a verified ad and a non-verified ad. Second, no prominence is given to verified ads on sites, and there is little explanation of what this verification means and how it improves customer protection. Third, Fido is the only database using this system, and that invariably leads to rogue breeders using other databases as it is easier to get their dogs posted on ad sites. Fourth, some quality-of-data issues have been observed. If the person registering the pup's details initially enters incorrect data such as an incorrect mobile phone number, the owner cannot receive the one-time passcode to allow the ad to be posted. Fifth, other verification systems for non-Veripet verification are not robust. They are subject to fraud, altered certs, old certs, reused certs and fake certs. Sixth, other databases are not on board, and there appears to be no incentive to be on board the system. In reality, there is no advantage to Fido in being on board. Seventh, if there are different "levels" of verification available to prospective advertisers, the rogue producers will always gravitate to the easiest and least robust system.

It is not possible for an unregistered owner to advertise an animal on a marketplace that allows only ads that are verified through the system. What we have found is that rogue breeders and those who want to circumvent the system will register their animals on a database that does not have the same controls in place. Manual verification of these animals by the online advertiser is not robust and is easily circumvented by using old certs, falsified certs, previous owners' certs or other means.

The simplest solution is that advertisement sites publish only ads with microchips verified to the same level as Veripet, whether that is a voluntary code of practice decision or a legally mandated one. Nothing in the current regulations compels the databases to provide this verification. If, however, the online platforms did not allow non-verified ads to be posted, it would compel databases that are not on board to join the system because their clients, who will not be able to sell pets without proper verification, will demand that. Manual authentication and verification is simply not robust enough to provide the verification that the spirit of the regulations sought.

The Veripet system works, and all adverts for dogs in Ireland should be verified through it, or through an authentication system with comparable levels of security, probity and transparency. This will give consumers the protection they deserve when completing what can be expensive purchases. We are always available to the committee to elaborate on any points about the system that may be unclear. Again, I thank the committee members for their time. Because of time pressures, we have kept much of the technical detail out of this presentation, but API documentation and further technical specifications are available should any member require them.