Administrative Data File Names
The Central Statistics Office (CSO) is accepting multiple data flows from the Health Service Executive (HSE) during the COVID-19 pandemic. The incoming data is being processed, pseudonymised (pseudonymisation of data means replacing any identifying characteristics of data with a pseudonym, or, in other words, a value which does not allow the data subject to be directly identified) and stored securely. As governed by the CSO Data Management Policy, the data flows are stored in the Source Tier of the Administrative Data Centre (ADC) warehouse and are named as follows:
NOTE:
The Central Statistics Office is the Data Controller for the COVID-19 health data that is transferred in to the CSO for the duration of this collaboration.
Purpose of processing
The collaboration between the CSO, HSE and the Department of Health (DoH) is taking place following extensive consultation and is covered by Section 11 of the Statistics Act, 1993. The context for the collaboration is in relation to the statistical analysis of special category health related data, gathered from multiple sources within the Health Sector. The National Public Health Emergency Team (NPHET) and DoH has decided what data is being gathered for analysis in order to formulate an effective public policy response to the COVID-19 virus.
Legal basis for collection and processing of Data are as follows:
Access by the CSO to the sensitive confidential health records is underpinned and provided for by a written request under Section 30 of the Statistics Act 1993 - ‘Use of Records of Public Authorities for Statistical Purposes’ by the written permission of the Minister for Health.
Section 30 of the Statistics Act states that:
(1) For the purpose of assisting the Office in the exercise of its functions under this Act, the Director General may by delivery of a notice request any public authority to—
(a) allow officers of statistics at all reasonable times to have access to, inspect and take copies of or extracts from any records in its charge, and
(b) provide the Office, if any such officer so requires, with copies or extracts from any such record,
(2) Subsection (1) of this section—
(b) shall apply to medical records which are not publicly available only with the agreement of the Minister for Health;
Processing of personal health data as contained in the COVID-19 Data Flows is permitted under Article 6.1.e, Article 9.2.i and j of the General Data Protection Regulation (GDPR).
Processing of personal health data as contained in the COVID-19 Data Flows is also permitted under Sections 38.1.a, 42.1.c, 53 and 54.c of the Data Protection Act 2018 i.e.
Who uses the results?
The data collected from the HSE is processed in the Administrative Data Centre by a dedicated team prior to making the data available for statistical analysis purposes. This processing prior to analysis involves removing directly identifiable data and replacing identification numbers with Protected Identifier Keys (PIKs). PIKS are encrypted identifiers that enable safe linking across data sources and over time (linking occurs without revealing any identification details).
Access to the pseudonymised data for analysis purposes is then provided to named statisticians within CSO once a statistical requirement is identified.
Pseudonymised versions of the data may subsequently be made available to accredited researchers under strict researcher protocols and strict governance procedures. The purpose of the access is to contribute to the effort in informing the Government response to the pandemic. A separate transparency notice in relation to researcher access is available on the CSO website, should you wish to have further information. [Link to be confirmed]
Is your personal data confidential and how long will the data be retained?
All information supplied to the CSO is treated as strictly confidential. The Statistics Act, 1993 sets stringent confidentiality standards: Information collected may be used only for statistical purposes and no details that might be related to an identifiable person may be divulged to any other government department or body.
There will be a post-pandemic review which may make certain recommendations regarding the duration of the data storage element regarding COVID-19 related data sources.
The sources and categories of your personal data, where the data has not been collected directly from you:
The Health Service Executive (HSE)
For further information on this survey, your Data Protection rights and how your data is used, please contact:
John Dunne, Secondary Data Sources and Innovation, CSO, Skehard Road, Cork T12 X00E.
Tel +353 (21) 4535499 E-mail: SDSI@cso.ie
Data Protection Information:
Under the General Data Protection Regulation, you have the following rights:
However, because your data is processed for statistical purposes ,these rights may be limited in accordance with Article 89 of the GDPR. This is due to the fact that the exercise of any of these rights may render impossible, or seriously impair, the achievement of the statistical processing and such restriction maybe necessary for the fulfillment of those purposes.
Contact details of the Data Protection Officer:
The CSO Data Protection Officer (DPO) is responsible for overseeing questions in relation to this Privacy Statement (contact details below). If you have any questions about this statement, including any request to exercise your legal rights, please contact or send them to the CSO DPO:
Data Protection Officer,
Central Statistics Office,
Skehard Road,
T12 X00E
Tel: 021-4535000
Email: dpo@cso.ie