Blog Post

In late November, we wrote to the Minister for Communications, Energy and Natural Resources to reiterate our concerns about Eircode, the postcode system that is proposed for Ireland.

We wrote: 

We want to state clearly that we are not at all ‘satisfied’ with the postcode that hasbeen designed or the implementation proposals. Our view is that you are taking a dangerous and needless step into the unknown by going ahead with the code as currently proposed. We gave details of an immediate privacy problem that will present itself immediately after launch. We warned that the mitigating measures that the Department is proposing would not really help, and might even be a distraction from other critical project issues. We warned that the legal protections of the data protection regime would be largely unenforceable in the context of global Internet advertising networks.

Although ‘eircode’ is by no means the first postcode in the world to code down to the individual house level, it is the first postcode anywhere to use this unstructured pseudo-random design. Simple changes would bring eircode into line with international best practice and would greatly alleviate the privacy concerns. Risks would still exist, but they could be managed and mitigated.

Decisions about the postcode are your political prerogative and this is clearly your chosen design. As part of our ‘in-depth conversation’ with your officials, we made suggestions in relation to the implementation of the design in order to mitigate some of the worst problems that the design will cause. We are happy to see that some of these suggestions have been taken on board and are being implemented.

To reiterate, we see a great deal of uncertainty and dangerous ‘downside’ in relation to privacy arising from the particular design which has been chosen. These are completely uncharted waters and so it is really impossible to say how great the privacy impact will be.

We are not opposed to the principle of a postcode which codes down to the individual house level where the privacy benefits outweigh the risks. That said, we are puzzled as to how the firmly conveyed views of the Data Protection Commissioner about individual house coding were put to one side when the requirements for the code were totally revised without consultation in 2010.