Primary Online Database: POD now (mostly) not compulsory (for now)

Ever since the introduction of the Primary Online Database of schoolchildren by the Department of Education, the Department and its Minister have been eager to point out that any parent who refused to allow a child’s data to be transferred would see that child’s education defunded.

Well, for all children other than this week’s crop of new Junior Infants, that threat has now collapsed. This is despite the Minister and her department having claimed that the drastic threat of defunding was because it simply wasn’t possible to give grants without a child’s full data being transferred.

“there is no mechanism for separate payment and allocation to schools for pupils that are not on POD, and from a practical point of view it is difficult to see how such a system could work in practice.”
Minister for Education, Jan O’Sullivan

Oddly, as the prospect of defunding the education of 30% of the nation’s children in the run up to an election loomed large, the Department discovered it could, after all, pay for a child’s education without all its POD data.

The 2nd attempt to make the POD legal, Department of Education Circular No. 25/2015 dropped the defunding threat for all children other than this year’s Junior Infants.

Paragraph 4.2(a-b) of the Circular:

a. Parents/guardians who continue to object to the onward provision of data to POD need to put their objections in writing to the school in order for their wishes to be carried out. Note that verbal objections will not be sufficient in this regard, as schools will be required by the Department to maintain written records of objections, and parents who do not put their objections in writing should be informed by the school that their record will be otherwise transferred to POD within a four week timeframe. Parents/guardians who object should be given every opportunity to provide their objections in writing to the school.

b. Schools that are in receipt of a letter from a parent outlining their objections to the onward provision of data to POD can create a partial record for that pupil on POD, using the guidelines available on request from the POD Helpdesk. This will ensure that a record is created for the pupil which will be counted for grant payments and teacher allocation purposes.

So, once you’ve written and put “your objections” in writing to the school, there should be only whatever the bare minimum of data the “POD Helpdesk” is seeking transferred.

For your convenience, here’s a sample letter you could use. Insert your own words as appropriate.

Dear Principal,

I write further to the proposed transfer of data regarding my child (insert your child’s name here) to the Department of Education as part of the Primary Online Database. I am not satisfied that the Department has acted legally regarding this scheme in the past, and the Data Protection Commissioner’s office has confirmed the lack of legal basis for the transfer of data during the course of the rollout of this scheme.

As I both object to the creation of the POD and have no confidence in the Department’s capacity to process this data in accordance with data protection law, please note that, per Paragraph 4.2 of Department of Education Circular No. 25/2015, I wish no transfer of data relating to my child to be made to the POD database.

Thank you for your assistance.

Yours faithfully
(Your name)

And if, like me, you’re the parent of a new Junior Infant who can’t avail of this opt-out system, well, I’ll link to a post I’ll write about that from here shortly about what you can do. Suffice to say, if defunding was threatened because POD data was the only way to fund, what is the justification for Junior Infants being defunded, now that there is an alternative?

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