After a 15-year investigation, the DPC has ruled that the Department of Employment and Social Protection (DEASP) unlawfully collected facial images, classified as biometric data, from approximately 70% of Ireland’s population. The DPC found that the Department failed to inform individuals of the purpose and legal basis for this data collection and did not conduct an adequate Data Protection Impact Assessment (DPIA).
The decision follows a previous DPC ruling prohibiting public bodies, other than the DEASP, from making the PSC a mandatory requirement for accessing public services. Alternative methods for verifying identity must be provided.
The DPC’s key findings are as follows:
The DPC has imposed a €550,000 fine on the Department and granted it nine months to either cease processing biometric data or establish a lawful basis for doing so.
On 12 June 2025, the Irish Council for Civil Liberties (ICCL) issued a statement partially welcoming the Data Protection Commission’s (DPC) findings on the Public Services Card (PSC) but criticised the long delay and limited enforcement measures.
The ICCL and Digital Rights Ireland have long challenged the legality of the PSC and its biometric data requirements. In response to the ruling, ICCL Executive Director Joe O’Brien stated that the findings confirm the ICCL’s longstanding concerns that the PSC undermined privacy rights, violated data protection standards, and lacked a proper legal basis. The PSC system, estimated to have cost the State €100 million, effectively created a national biometric ID scheme without sufficient safeguards.
The ICCL criticised the outcome as inadequate and is calling for the immediate deletion of the facial recognition database. ICCL Senior Policy Officer Olga Cronin highlighted the disproportionate impact on vulnerable individuals who were required to provide biometric data to access essential services. The ICCL also referenced several cases where individuals suffered adverse consequences after objecting to the collection of their biometric data, including being denied pensions, benefits, or passports. The ICCL is urging the Department and DPC to explain to the Oireachtas and the public how the system was permitted to operate unlawfully for over a decade.