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Local Authority: Use of PPS Numbers [2006] IEDPC 7 (31 December 2006)

I received a complaint from a member of the public who had submitted an application for planning permission to a local authority on its Rural Housing Application Form. The complainant informed me that she was required to provide her PPS Number on the form and she expressed grave concern that this personal information would become publicly available as the local authority is obliged by law to make planning applications available to the public at its offices during working hours.

Following my Office's intervention on this matter, I am pleased to say that the local authority responded in a positive and quick fashion. It put in place the following measures which were recommended by my Office:

 in relation to all completed Rural Housing Application Forms which were already publicly available in the public counter area, it blacked out the PPS numbers before they were handed over for inspection to any member of the public;

 it blacked out the PPS numbers on all newly received Rural Housing Application Forms prior to their transmission to the public counter area;

 it reviewed its policy on the collection of PPS numbers on the Rural Housing Application Forms following which the forms were altered to exclude the requirement for the provision of PPS numbers in future.

I consider that the requirement to provide personal data in the form of a PPS number for a rural housing planning application to be excessive data, having regard to Section 2(1)(c)(iii) of the Data Protection Acts which provides that data "shall be adequate, relevant and not excessive" in relation to the purpose for which it is kept. Data controllers must examine whether it is absolutely necessary to harvest such personal data. In this case, following my Office's intervention, the local authority had to examine if the particular application forms could be processed without the provision of the PPS numbers and it considered that they could. Incidentally, on a point of information, it should be noted that it is an offence for any person or body to request or hold a record of a PPS number unless they are permitted by law (the Social Welfare Acts) to do so. It is the duty of all bodies to ensure that they are specified in law as being so entitled before they request or hold a record of any person's PPS number. (This, of course, is not a matter for my Office to enforce or police).