Michael Colreavy (Sligo-North Leitrim, Sinn Fein) | Oireachtas source

It must have been about the early 2000s, long before I had any ambition or intention of coming to this place that I first heard in the news that Ireland was to have a post code system. I thought that made obvious sense. I certainly did not think, back then, that I would be standing here today and saying to the Minister that I will not be able to support this potentially good idea. I need to outline the reasons I cannot offer that support.

Either the Minister or I, if we were taking on the portfolio the portfolio he took on, would probably have asked the same questions I will ask. Discussion of a post code system has probably been going on for at least 12 or 15 years. In theory it is a fairly simple concept. A system is required so that a vehicle, a person, a parcel or a letter, can get to an address in Ireland. There are several standard satnav systems and we all use them to help us to get from place to place. There are 31% unique addresses but there are different ways to handle those addresses. The original cost figure for the proposed system was €27 million. A package was available from at least one Irish company which the company offered for free. That offer was turned down for some reason. The figure of €27 million is a gross understatement, in my view, because when I asked for some information about how the records of the various Departments that will use this system would be made ready to use the Eircode codes, I will describe some of the responses I received but it is clear that money will need to be spent to get Departments in a position to use Eircode.

I asked what business problem or gap required such a complex non-standard - this is what we are talking about - addressing system. That is the first question that any business needs to ask. What problem am I trying to address by introducing this technology? If it is expensive technology one needs to have a very clear answer to that question. I have asked many times and I have not been able to get an answer to that very simple question. What business problem is being addressed and can only be addressed by a non-standard numbering sequence in a geo-locator system? I have been unable to get an answer to that most fundamental of questions.

The Department of Communications, Energy and Natural Resources has projected the cost to the State of the project will be in the region of €27 million, although others have projected an even higher cost. When a project with a technical specification is being carried out it is an attempt to fix a clear problem that has been identified. I agree with the high level of discussion about the lack of a post code system in Ireland.

I have not got an answer as to why an expensive, extensive and complex system such as this is being introduced. Although we are told Ireland is the only OECD country without a postcode system, that is not a good enough reason to spend so much money while overlooking technology and systems that are currently available, particularly if one of those systems was being offered for free.

There is a risk that this is an expensive vanity project. I can understand Ministers, politicians, civil servants and citizens feeling embarrassed that we are the only OECD country without a postcode system. However, I do not believe we need such a system to extend as far as the Government has brought it with this incarnation.

As the Minister has probably heard me say before, the role of management consultants constitutes another risk. Typically, management consultants would work with a business and would know what the business wanted to get from new technology. The consultants might help the business define its requirements more precisely and would thus be in a support role, putting into words the problem the business wanted to solve. Once that had been signed off, there would be a different set of consultants to translate the business requirements into a set of specifications, identifying the solution to the problem. The reason for having two separate sets of consultants is clear; it is to avoid the Stockholm syndrome of the management consultancy world, whereby the consultants are making the decisions even though somebody in the civil service is signing off on it. For very obvious reasons, multiple stages of the process, including identifying the problem, defining the requirements, preparing the functional side and how it is going to look, preparing the technical specifications, preparing the request for tenders, issuing the tenders, evaluating the tenders when they come back, doing the coding and implementing the system, should never, ever be done by the same set of management consultants. The Minister knows that cannot be right and knows the risks involved in having one company, or individuals from one company, involved all the way through this process. It is the gift that keeps on giving in the management consultancy world.

When I was speaking to some of the senior civil servants on this, although I cannot be sure, I believe I detected that they felt a less complex system would have done the job just as well. Satellite navigation companies such as Garmin work and are available. The expected cost of consultation on the project is projected to be in the region of €1.8 million. I have explained the advisability of breaking up the work among management consultants.

The cost to several Government Departments to prepare their systems to use Eircode remains undisclosed. Also unanswered is the question I put to a number of Government Departments as to how their operation will differ and how they will be able to work better with their records converted for Eircode. I asked a question of the Minister for Social Protection as to what the projected cost of implementing Eircode in her Department would be. In fact, I asked a lot of Departments, but got a response from the Minister for Social Protection. I will quote the response:

The initial phase will be completed in 2015. To this end, the project governance committee of the Department has approved the issue of a supplementary request for tender to a framework of approved bidders in order to implement the technical changes required to the IT systems of the Department. The associated costs of this initial phase will be known on completion of this technical work.

Although this response is not very clear, I think I know what it means, and what it would mean to a management consultant. Given all the people in receipt of social welfare, children's allowance and the whole range of social protection payments, the Department has a huge number of records that will need to be updated. If each of those now has to be allocated a random number, it will be a huge task. I know what is involved in converting computer records. There are duplicates and triplicates and it is a great effort. I believe the Minister for Social Protection is being fully truthful when she says she is not in a position to estimate precisely the cost of this work.

Here we are, launching Eircode to help Government agencies do their work better. Nobody has explained how that is going to happen, and we do not know how much it will cost the Government and the people for those agencies to get their systems up to a stage at which they can start using Eircode.

The Freight Transport Association of Ireland has raised serious concerns and has said it will not use the system. It is no use to them because it is not sequential; they cannot plan a journey around the order of deliveries. If it is no good to the people who are delivering the parcels here, there and everywhere, it is difficult to see how it can be of great benefit to the private market, apart from those marketers who want to send out flyers and that sort of thing.

I believe the HSE and the local authorities have said that it can and will work, yet the Irish Fire and Emergency Services Association, which represents front-line staff, has expressed serious concerns about the system because it does not identify small local areas. It will not be any help for emergency call-outs and accidents along the roads. The Eircode numbers will not be up on the street signs. Unless the person making the emergency call happens to know his or her Eircode number and is able to call it out, it will be of no help to those services.

I am concerned that a change in primary legislation is needed in order to ensure there is comprehensive data protection.

To me, this says there is something fundamentally flawed with the system we are trying to put in.

In a letter to the Minister, Digital Rights Ireland stated:

Our organization ... was happy to have been consulted by your officials and advisors in relation to the 'privacy impact assessment' for the eircode. We have deep concerns about the eircode initiative.

In relation to this meeting, Oireachtas Debates records the following statement by one of your officials:As part of this [privacy impact assessment] we have spoken to many stakeholders. We have spoken to the National Consumer Agency, logistics companies and Digital Rights Ireland, with which we have had an in-depth conversation to see if there is anything in the proposal that might be considered to have an impact on anyone's privacy. Broadly, they are satisfied with what we are doing.An observer might infer from this factual statement that Digital Rights Ireland was among the organisations which were 'broadly satisfied'. We are assured that this implication was not intended, and we would like to state clearly that this is not the case.

We want to state clearly that we are not at all 'satisfied' with the postcode that has been designed or the implementation proposals. Our view is that you are taking a dangerous and needless step into the unknown by going ahead with the code as currently proposed. We gave details of an immediate privacy problem that will present itself immediately after launch. We warned that the mitigating measures that the Department is proposing would not really help, and might even be a distraction from other critical project issues. We warned that the legal protections of the data protection regime would be largely unenforceable in the context of global Internet advertising networks.

Although 'eircode' is by no means the first postcode in the world to use code down to the individual house level, it is the first postcode anywhere to use this unstructured pseudo-random design. Simple changes would bring eircode into line with international best practice and would greatly alleviate the privacy concerns. Risks would still exist, but they could be managed and mitigated.

The letter goes on a little further, but right the way through is the message that Digital Rights Ireland continues to have very serious concerns over data protection in regard to the Eircode system. Although I and my party will oppose the Bill today, mathematics being mathematics, it will go through. However, I and my party will certainly be putting down amendments at a later stage.

I have probably said enough. I have been unable to establish what is the business problem that needed such a complex software system to address it. I do not understand how currently available software and a company that could have provided it were turned down, although the company offered it for free. I am very concerned at the role of management consultants throughout all the phases of this project. It is the gift that keeps on giving for management consultants. I am not saying it was abused but I am certainly arguing it was wide open to abuse and that the normal checks that should have been there were not there.

I am very annoyed that the request for tenders was designed in such a way that small and medium enterprises in Ireland simply could not afford to submit tenders. I know a case was made to the EU on this and that, while it did not say there was a breach that would cause the tender process to be re-run, the EU did advise the Government that it should do it in a different way in future. I understand the EU is still in contact with the Department on that issue. Effectively, the design of the tender form precluded small Irish companies from tendering for this work, reinforcing what I was saying about the continuous involvement of management consultants through all of the phases of a project.

I hope it works. This country needs a postcode system. However, we could have done it a lot more simply. If I had been in the Minister's place, I would have stopped what was an ill-conceived start. Everything the Minister goes to do will be flawed and it will cost this country an awful lot more money than we currently think it will. I believe it will cost us a small fortune to get all the records of the other Government Departments ready. It is a bit scary that the other Departments do not know how much it is going to cost but at least they are being truthful about the fact they do not know. Even at this late stage, I would have gone back to basics on this one. I would have taken the advice of the independent management consultants and the State-established body, which said we do not need this randomly assigned number and we do not need this complexity within the system, that there is an easier way to do it and that the technology is already there. I would have taken that advice and worked on it.

I will be opposing the Bill, although I know it will pass despite my opposition. I will be submitting amendments on the next stage.

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