Inquiry concerning the Department of Social Protection – June 2025

• Year: 2025
• Section: Decisions made under data protection act 2018

Inquiry concerning the Department of Social Protection

IN-21-7-3 Date of Decision: 9 June 2025

The Data Protection Commission (DPC) has completed an inquiry into the Department of Social Protection’s (DSP) processing of biometric facial templates and the use of associated facial matching technologies as part of the Public Services Card (PSC) registration process, referred to as “SAFE 2 registration”.

Background

This own-volition inquiry, which commended in July 2021, follows a prior DPC investigation into certain aspects of the DSP’s processing of personal data in connection with the issuance of PSCs. That investigation resulted in legal proceedings, in which the DSP appealed an Enforcement Notice issued by the DPC, which were subsequently withdrawn. A joint agreement between the DPC and the DSP as well as the final investigation report from that inquiry were published in December 2021. The final investigation report stated that processing of personal data, including biometric data, by the DSP in respect of SAFE 2 registration was to be addressed separately by the DPC. The current inquiry was established to separately examine the...