There has been a pretty significant exchange of correspondence with the Data Protection Commissioner over the Primary Online Database since my last post.
The result is that I am copying all of the documentation to date and will be forwarding it to the European Commission as part of a complaint regarding Ireland’s failures to ensure that Article 8.3 of the Charter of Fundemental Rights and Article 28 of the Data Protection Directive are given force by the Irish State. I have notified the Attorney General’s legal agent, the Chief State Solicitor’s office, of this intention.
I attach a lightly redacted copy of the relevant recent letters from me and the Data Protection Commissioner’s agent.
(There was also a minor one of today where I point out that I had answered the questions raised regarding my daughter’s data in one of the emails of the 19th May acknowledged in the first paragraph of the DPC’s reply letter.)
This is a regrettable sequence.