The Regina Monologues

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RTÉ’s Mary Wilson; Minister for Employment Affairs and Social Protection Regina Doherty and Minister for Finance Paschal Donohoe; Public Services Card

Last night.

On RTÉ’s Drive Time.

Minister for Employment Affairs and Social Protection Regina Doherty was interviewed by Mary Wilson following the publication, by her department, of the Data Protection Commission’s report into the Public Services Card.

Before their interview began, listeners heard a clip of an interview the Data Protection Commissioner Helen Dixon had with RTÉ’s Miriam O’Callaghan last month – during which Ms Dixon spoke about what the DPC had ordered Ms Doherty’s department to do.

These orders included that Ms Doherty’s department had to stop issuing new cards, with immediate effect, to people seeking a service that’s outside of her department – and Ms Dixon asked that the department write to her within 21 days to outline how the department carried out that order.

The DPC also ordered that the department delete the supporting documentation – such as utility bills, etc – that the department had retained on the 3.2million card holders. Ms Doherty was to write to Ms Dixon about that within six weeks.

But last night, Ms Doherty was categorical that her department will not be complying with these orders.

From last night’s interview:

Mary Wilson: “You heard what the Data Protection Commissioner said there. She said that on the 16th of August. Have you complied with all of those directions?”

Regina Doherty: “Well, I think, as is on the record, we took a number of weeks to consider the votes, the letter that the commission sent us and the report with all of its eight findings. And the simple and short answer to your question is ‘no’. Because we don’t agree with any of the eight findings and we have written to the commission to outline that.”

Wilson: “So, where to now?”

Doherty: “Well I suppose the position is that we’ve made, we’ve reacted to the instructions that the Data Protection Commission gave us in the letter of the 15th. We’ve requested a meeting, on a number of occasions, to see if we could establish. There are some inconsistencies with regard to the findings and the instructions in the letter and some of…”

Wilson: “Like what?”

Doherty: “It’s kind of technical, it’s…”

Wilson: “Well, we need to get technical, minister then because this is a damning report on your department and the operation of the Public Services Card and your response is that you’ve got problems with some complicated issues or fair procedures.”

Doherty: “No, well, actually, that’s not what I said. And our response I think is very clear and unambiguous, in so far as that we disagree and the legal advice that we’ve obtained, from the Attorney General, is that we have an incredibly strong legal basis to do exactly what was set out in the 1998 legislation, established in the 2005 legislation and amended thereafter in 2007, 2009, 2011 and 2013.

“And so we’re not trying to be ambiguous in any way, shape or form. Which is why we’ve been as transparent as we have been today – not only to publish the findings and the report from the Data Protection Commission but to publish the correspondence that’s gone on between ourselves and the commission since then.

“I’ll give you a small example of the difference between the findings in the report and the instructions in the letter.

“One of the findings in the report is that we, should not, under Data Protection law, retain data indefinitely. I’m not sure what the legal definition of indefinitely means but the instructions in the Data Protection Commission’s letter is that we have to immediately delete all of the data that we hold on people, even for people who’ve only got a PSC card last week.”

Wilson: “Supporting documentation, minister.”

Doherty: “That’s correct, yeah.”

Wilson: “Not the name, and so on, it’s the supporting documentation…”

Doherty: “So to be clear, Mary, that data set…”

Wilson: “…the data sent to get the card.”

Doherty: “The data set is entirely different to the supporting documentation and the discrepancy or the inconsistency is with regard to the supporting documentation. And that’s only one example. But unfortunately, we haven’t been able to meet with the Data Protection Commission staff and that’s why we are where we are today which is why we’re publishing the report…”

Wilson: “So, just to be clear before you move on. Just to be clear before you move on. You will not be getting rid of or eliminating or destroying the supporting documentation that you retain on 3.2million people who’ve received the card?”

Doherty: “No, Mary, because our advice is that it would be illegal and so if I acted as the directions in the Data Protection Commission’s letter has suggested, I would actually be contravening the legislation that underpins the practice and the policy as far as 1998 and that would be illegal.

“And that’s the advice that I have. And with respect to my role and my job, which is defending the delivery of services, in an efficient manner, to the public which we serve, we regard the legal basis underpinning this service to be incredibly strong.”

Wilson: “Will you stop any demand for the Public Service Card for the delivery of services other than welfare services?”

Doherty: “So, to say again, Mary. The eight findings, in its entirety, are not accepted by ourselves in Government and so we won’t be complying with any of the instructions with regard to the findings or the instructions in the letter.”

Wilson: “Spell that out for the public. When I go to apply for a passport now, are you going to ask for a Public Services Card?”

Doherty: “So, to spell it out for the public, in so far as 3.2million people in Ireland already have data, or PCS [sic] cards. Anybody that doesn’t have one is usually invited to come in and be registered under the SAFE 2 process and that allows them access. All of the public services across Government departments, on a once and done basis, and so what you would be suggesting that we do, is to go back and asking people to fill out forms in triplicate, across a number of departments…”

Wilson: “No, no, no. I asked a simple question: what are people to do now if they’re applying for a passport and they’re asked for a Public Services Card?”

Doherty: “Exactly as they always have done.”

Wilson: “What are people to do if they’re applying for their [driving] theory test? For their driver’s, their learner permit? And they’re asked for a Public Services Card? Are you saying it’s mandatory of compulsory or which? That they produce it?”

Doherty: “In most cases, in most cases, Mary, across all of Government departments, with maybe the exception of my own, there are different ways that you can apply for services and so there is a long-form way. And so, for argument’s sake, you can go and you can get your forms filled out in triplicate and bring your passport or driving licence…”

Wilson: “So you’re fudging it?”

Doherty: “No, I’m not. That’s a way that you can go and access services. The efficient way for people to access services is those who have a PSC card can do most of their conversing with the State online. And that still is true.

“So for people who don’t have a PSC card, nobody is absolutely going to make them get one but for those people who do have and want to deal with the State efficiently then, you know, 3.2million people tell us nine out of ten people, we conducted a survey…which tells us that it does actually make the transactional engagement much more efficient…”

Wilson: “What you’re saying is ‘we’ll make it so difficult for people to interact with the services that it’s going to be the only way forward’.”

Doherty: “No, no…no, no…”

Wilson: “That is what you’ll be doing.”

Doherty: “No, Mary, it’s not making it any more difficult. It’s just maintaining the way it always was….which was cumbersome.”

Wilson: “Meanwhile…meanwhile we have a report that you’re rejecting in full – all of the findings. And where are you going now? What is the next step?”

Doherty: “Well the next step is that we have to wait for the Data Protection Commission to enforce the findings, if they so wish. And because at the moment we don’t have anything that we can legally appeal. So I suppose we await for the Data Protection Commission to send us an enforcement notice.”

Wilson: “So you say ‘the ball is in your court, Helen Dixon’.”

Doherty: “Well, that’s just the reality, Mary so…”

Wilson: “The ball has been in your court since, was it August 2017 you got the draft report?”

Doherty: “No, I think it was that, that was the year the commission started their investigation and so…”

Wilson: “OK, you knew about the concerns since 2017. When did you first receive the draft findings of the Data Commissioner?”

Doherty: “So, in August of 2018, we received a draft report from the commission which we responded to comprehensively in November of 2018.”

Wilson: “The réponses – did they run to hundreds of pages?”

Doherty: “They did, yeah, they did.”

Wilson: “And at that point, did you inform your Cabinet colleagues of the content of that report?”

Doherty: “Well the first instruction from the Data Protection Commission was that the report was to be treated as private and confidential and wasn’t to be shared with anybody. We sought permission from the commission to share it with the Department of Public Expenditure, given that they are joint responsible for the roll-out of national services on an e-Government basis. That permission was granted and both myself, my department, and DPER compiled a very comprehensive response to the initial findings in the draft report and that did run to some 170 pages. And that was returned to the commission in November 2018.”

Wilson: “And where do you see this going though? You say you’re waiting for an enforcement order to come from the data commissioner. Do you then take it to the courts? What is the protocol? I don’t know what the process is here? What is the Attorney General advising you to do?”

Doherty: “So again it very much depends what’s in the enforcement notice and, given that we haven’t seen it yet, it’s difficult for me to be precise.”

Wilson: “But what are the options?”

Doherty: “In normal circumstances, if an enforcement notice was issued to a department that it didn’t agree with, it would take an appeal of that enforcement notice. In this particular case, it would probably start in the Circuit Court. The other possibility is to conduct a judicial review but, again, without seeing what’s in the enforcement notice, it’s a bit difficult to be precise.”

Wilson: “Would you want to expedite this quickly?”

Doherty: “Well look I’m very comfortable with the fact that the legal advice that I have given, gives me confidence that we are doing exactly what was established and set out as far back as 1998 and, as I said, it’s been reinforced in various different pieces of legislation by various different ministers for social protection and employment affairs.”

Wilson: “But it’s starting down the road now of legal challenges. You could be accused of kicking the can down the road and avoiding doing what you ultimately  you may have to do anyway.”

Doherty: “But how could I kick the can down the road of doing something I have no intentions of doing because I have no, because I don’t agree with it? And so where I have legal basis is, is that the legislation that was established in 1998, reformed in 2005, 2007, 2009 and 2011 and 2013 gives me robust legal basis to conduct the Government policy across any Government platform as was envisaged…”

Talk over each other

Wilson: “And you know as well that lawyers will differ and judge will ultimately in a court will have to decide and then ultimately you may have to accept an outcome contrary to what you believe yourself.”

“In any event, there is also another process now where the [Irish] Examiner is reporting today about the second generation of the Public Service Card. A further two million or so cards that are going to be processed. Is that continuing? Is that tender, is that contract signed? Is that tender done and those cards being prepared?”

Doherty: “There’s no iteration of a new version of card, I’m not sure where the Examiner is getting its information from. The Public Services Card is being renewed, the contract has just been renewed with a new agency to do what will be our second generation but it’s just the lifespan of a Public Service Card is seven years. We’ve come to the end of that and are starting a new card. I’m not sure, I haven’t seen the article in the Examiner so…”

Wilson: “I presume the new card will have more and varied capacity or ability…”

Doherty: “Well, there’s no plan in the legislation to have…”

Wilson: “You can tap it?”

Doherty: “No.”

Wilson: “That’s not going to be on the card?”

Doherty: “Well, it’s not in the current legislation so I can’t see why we would…”

Wilson: “And how much  are you spending now on the, the additional 2.6million cards?”

Doherty: “Again, it’s not additional spending. The project that was envisaged in as to roll out in 2005, sought to actually ensure that everybody was identified and registered under the Safe 2 process. The PCS process is a by-product of that, it’s only a token that’s given at the end of the identification and authentication process.”

Wilson: “And what’s it costing?”

Doherty: “Well, at the moment, I think we’ve just spent over €60million. I think that’s a very good and strong investment in the delivery of public services.”

Wilson: “We don’t know that yet. You actually don’t know that yet. You’re going to challenge the Data Commissioner’s findings so, ultimately, this will go through the courts. And, ultimately, that €60million, plus additional funding that you may continue to spend, could be money down the drain.”

Doherty: “I tell you what I do know, Mary, is that 3.2million people have taken the time to come in and get themselves identified and registered until the Safe Two process because they want and value to be able to do they business online, in an efficient and quick manner…”

Wilson: “Perhaps because they were told that it was compulsory and mandatory to get it by you.”

Doherty: “Well, they’re not,  they were invited in. And actually I think if you look at the finding of the one, of the first finding in the Data Protection [Commission’s] eight findings is that she has entirely deemed it legal for the Department of Social Welfare and Employment Affairs…”

Wilson: “She has…the only department that it is legal to use..”

Doherty: “…And..that’s the department that we were talking…”

Wilson: “And do you accept, you accept that finding?”

Doherty: “To go back to what I was saying to you a second ago is that we have 3.2million people who have registered extremely high satisfaction rates with the usage of the card. They value it and…it’s my job to make sure that I continue to provide those services in an efficient manner for the people that we serve.”

Wilson: “Minister Regina Doherty, thank you for joining us.”

Listen back in full here

Meanwhile..

49 thoughts on “The Regina Monologues

  1. eoin

    Wow, you’d almost think there was a total equivalence between the Office of the Commissioner for Data Protection and the minister. “that’s your opinion, this is my opinion”. I wonder would any minister be as dismissive of say, the Revenue Commissioners if the Revenue made an adverse ruling against a government department? Of course there’s no equivalence, the agency which is legally responsible for data protection matters has investigated a government scheme and now, following extensive consultation with the govt beforehand it should be said, issued her findings and directions.

    Of course we all have the right to resort to the courts, but to accuse the Commisioner of being “alarmist” and “senationalist” just reveals how weak your intrinsic arguments are.

    Regina should be dropkicked out of govt [with a deduction for her outstanding overpaid allowances]. Even Fergus O’Dowd would do a better job.

    1. Cian

      No.
      You should be comparing the legal team of Office of the Commissioner for Data Protection versus the legal team of the Department – the Attorney General.

      1. Portroegirl

        At Leader’s Questions, Taoiseach mentioned they got outside legal advice but wouldn’t publish it.
        According to Liam Herrick ICCL ,the DPC ‘decision was a conclusive finding by an independent statutory body with legal powers to make binding findings.
        According to Simon McGarr on Sean O Rourke this morning,Minister /Dept would have had a month to offcially appeal DPC findings but haven’t & month up!

        1. Cian

          Simon McGarr is talking rubbish.

          1. Unless and until the DPC issues an enforcement notice then there is nothing to appeal.

          2. If, say, Foreign Affairs is forcing you to get a PSC before getting a passport and the DPC thinks this should be stopped, then they need to issue an enforcement against Foreign Affairs.

          1. Cian

            @GiggidyGoo
            yes, he would. But he’s not here, and we’re being told “what he said”. We’re getting Portroegirl’s interpretation of what s/he heard.

            McGarr has been talking about this for the last month – even though he hadn’t actually seen the report until last night. He’s been talking “hypotheticals” for a month.

            Regina Doherty said there hasn’t been an enforcement notice.
            The DPC hasn’t said there is an enforcement notice.

            Until I hear it from either of them, there is no enforcement notice.

          2. Portroegirl

            Simon McGarr director of Data Compliance Europe and in Digital Rights Ireland!
            Also DPC issued Statement last month re her findings so that’s why Simon commenting for past month especially!!!!

          3. GiggidyGoo

            So you’re saying that the findings of the report cannot be appealed, as distinct from something else – that being an enforcement notice for a specific?
            Yet it is widely reported that the government is to appeal “the findings” of the report. Not that they are appealing any enforcement notice.
            Additionally, as per Fred Logue (who also would be more knowledgeable than you I take it)……

            “The outcome of the commission’s investigation is a legally binding finding,” he says.

            “The report is a finding on the law, so whatever way you look at it, it’s something people can rely on if there are breaches of their rights under the Data Protection Act.

            “There’s not even a requirement for commissioner to issue an enforcement notice; people can rely on the report to have its findings enforced in a private, civil setting if they want to.”

          4. Cian

            @Portroegirl – yes, he has been talking about a 1-page summary of an (up-to-last-night unseen) 200-page document.

            @GiggidyGoo
            You are actually correct. As you say Yet it is widely reported that the government is to appeal “the findings” of the report.

            “is to appeal”.

            “is [going] to appeal”.

            Future tense. If the DPC issues an enforcement, the government will appeal.

          5. Portroegirl

            The DPC Statement last month gave a summary of the findings of the DPC Report.
            One of the DPC findings on page 10/172 re ‘High level findings of this Investigation’ no 1 includes ‘bodies other than the DEASP cannot insist that a person who does not already hold a PSC must obtain one’.
            Did you read the full DPC Report yet,Cian,for completeness you should?Even though I usually disagree with some of your comments,I believe you to be sincere in your opinions!

          6. Barry the Hatchet

            The Department had 21 days within which to appeal the DPC’s decision. That time has expired. It did not appeal. If the Department insists on continuing to break the law (as it seems it will), the DPC can issue an enforcement notice against the Department. The Department may then appeal that notice to the Circuit Court, but doing so will look a little odd given that it did not appeal the decision itself.

          7. UnB9PFrom Planet GOD

            Thanks Barry
            I feel the government will make a stand on this one and it should. There is a strong public interest in requiring people to use this card.
            I really don’t see what the issue is other than in lawyers trying to make names for themselves.

        2. Portroegirl

          To Joe Small,I’m in the process of reading the 172 page DPC Report.
          I won’t make any personal comments re Regina.
          Cian is perfectly entitled to his opinion.I prefer to read the comprehensive Report & findings from DPC & listen to expert in Data Compliance,Simon Mc Garr and therefore have an informed opinion!

        3. Barry the Hatchet

          @unB9P – You’re missing the point here. The issue is not whether a national ID card of some sort is desirable (it might be) or legally possible (it is). The issue is that, if there is to be such a card, it must have a legal basis. The use of the PSC for services other than welfare does not have a legal basis. It is illegal. And you must agree that we cannot allow the State to flout the law with impunity even if, in this particular instance, you think the results are positive.

          1. Portroegirl

            Yes,DPC is just doing her job as she is entitled to and is obliged to under eg Section 10(2) of the Data Protection Act 1998
            :’If the Commissioner is of the opinion that a person,being a data controller or a data processor,has contravened or is contravening a provision of this Act(other than a provision the contravenment of which is an offence)the Commissioner may,by notice in writing (referred to in this Act as an enforcement notice) served on the person,require him to take such steps as are specified in the notice within such time as may be so specified to comply with the provision concerned.’

          2. UnB9PFrom Planet GOD

            Yes I totally accept that Barry, and I hope they will fill in the lacunae. And thanks for your patience. I just feel the level of outrage is disproportionate as I see little evidence of any damage to citizens from these unlawful uses of the card to date.

    1. UnB9PFrom Planet GOD

      Yes
      Pat Kenny slowly took the restaurant Association guy apart this morning when he came on to whinge about the farmers
      In fairness

      1. italia'90

        Clever move in fairness like.
        RTE to their shame have been kicking the beef farmers.
        Newstalk exec: I see an opportunity here for future ad sales.

        Plank is an awful fraud.
        DId he manage to offload his €500k suite in the Powerscourt “Ritz” yet?

        1. UnB9PFrom Planet GOD

          Yes Newstalk is very popular in rural areas as in many cases it’s the only one you can pick up other than Pravda and some awful local poo

        2. B9 Com From No

          He’s as thin as dull days old dishwater alright, gave up years ago
          That’s what makes it surprising when you see he can still pull it out of the bag
          like that goal from within his own half Wayne Rooney scored in MLS last season

    2. curmudgeon

      I don’t think she does a good job at all. Any hot topic interview is always the same. She asks a tough-ish question and then allow the interviewee to waffle thier way out of a direct answer,doesn’t call them out on it or challenge it meaningfully. Many times I’ve heard unbelievable lies being spouted and Ms. Wilson does not ask the obvious or point out the flaw or inconsistency and simply lets them off the hook and moves on. A good (and non complicit) interviewer would hammer down into the details and cross examine a rehearsed answer.

      Vincent Browne is gone but at least we have William Cambell, and broadsheet does a good job linking his Here’s How podcasts.

    1. Portroegirl

      But the Public Services Card is not just a welfare card for a few years now since it’s use expanded considerably to other public services eg the new National Childcare Scheme(Department of Children) to start in November ,a PSC is needed!If you don’t produce a PSC then you have to wait until paper based application running in January!

      1. eoin

        Indeed, according to the Commissioner “if draft legislation presently under
        development is passed in its present form – [the PSC card] may, in the near future, be used as an Age Card to
        be presented in off-licences to purchase alcohol.”

          1. Barry the Hatchet

            Cian, I have read your comments on several of these posts now and it seems to me that you are being deliberately obtuse in relation to the core issue here. The DPC has determined that there is no legal basis for bodies other than DSP to compel a person to obtain and produce a PSC. Therefore, a further extension of the PSC into the private sector would be seriously problematic.

            The DPC is not saying that a national ID card system is undesirable or unacceptable. The point is that, if we want a national ID card, we should have a debate about it and introduce one with a solid legal framework. We should not introduce one illegally by stealth.

          2. B9 Com From No

            I think that’s unfair to Cian in this instance even though I understand he has a history of trolling on the site.

            Others here are deliberately gainsaying the facts of the DPC finding and misrepresenting the intent behind the PSC’s use and making wild, unfounded claims.

          3. Cian

            @Barry.
            A passport is issued by the State for specific purposes – relating to travel. You can also use it in the off licence as a means of identification.

            The proposed legislation was to allow a citizen request that that their date of birth is printed onto their card, so they could choose to use it as age-identification.

            I don’t see this as “a further extension of the PSC into the private sector”.

          4. Joe Small

            In defense of Cian, a lot of posts here are informed only by something random they happened to hear on the radio rather than anything more than a brief acquaintance with the facts. Some people don’t like awkward facts getting in the way of kicking an unpopular minister and, like any good tabloid rag, see the world only in terms of heroes and villains. So Helen Dixon here is the hero apparently, and the Minister is the villain. The world is so black and white, it seems.

          5. Barry the Hatchet

            @Cian. It will be allowing the private sector to use the card as evidence of a person’s age. By definition, this extends the use of the card to the private sphere. What will be next? Will private companies be permitted to use it as evidence of name or address? Will they be permitted to insist that it is the only ID they will accept? Is that desirable or not? Literally all of this needs a sound legislative basis and a proper debate, not gradual mission creep.

            @JoeSmall. If you want to defend the Minister, by all means go ahead. But please base your defence on the facts and not on some vague notion that people are being mean and unfair. The body established by the legislature to determine whether data protection law is being breached has determined that the Minister is breaking the law. This is pretty appalling.

      2. Cian

        Everyone that is going to apply for National Childcare Scheme already has a (legally proscribed) PSC as they are in receipt of Child Benefit.

        1. Portroegirl

          If they had applied online for child benefit then yes a PSC is required.
          However the National Childcare Scheme is under the Department of Children and Youth Affairs.When discussed on Sean O Rourke show it stated that those who don’t have a PSC will have to wait until January until paper based application running.

          1. Cian

            My understanding is that everyone that gets a payment from Social Protection needed to get a PSC – regardless of how they applied. This is, after all, what the PSC was originally designed for.

            SCYA are creating a scheme and need people to identify themselves. PSC makes sense, especially if everyone that uses it already has a PSC from their Child Benefit.

            Or, SCYA could build a manual process identify these people independently of the PSC. Which. would. be. madness.

          2. Cian

            Technically they said that other bodies making the card manditory was the problem.

            Nothing wrong with any department allowing someone to use either their PSC or some other ID.

  2. garrett

    Cian, if I want to access my PRSI payments record I need to get a PSC card first. This is my data, why should I be obliged to do this?
    1. Take time off work for a face-to-face registration
    2. Bring my passport.
    3. Bring proof of address, which I already did for my passport
    4. Bring my mobile phone with me

    Also, You have the right to have your data erased, without undue delay, by the data controller, if one of the following grounds applies:
    Where your personal data are no longer necessary in relation to the purpose for which it was collected or processed.
    SO, once I get the card my data no longer needs to be stored.

    Minister is a liar.

    1. Cian

      Under Data Protection the data controller needs to satisfy themselves that the person making the request is entitled to the data. So you need to prove to the department you are who you say you are. This is a good thing, or I could pretend to be you and get your data.

      The DPC has said that Social Protection are entitled to use the PSC for services within the Social Protection. So they are entitled to ask you to produce a PSC to get your PRSI payment records.

      As for the retention of your proof-of-address – I’m not sure about that. I would tend to agree with you that is shouldn’t be needed and should be destroyed, but the department thinks differently:

      FINDING 3
      13. The authentication of identity relies on the information and documentary evidence provided in support of that identity. If a dispute arises (e.g. in the case of a subsequent prosecution for fraud), it is necessary to produce the information/documentation on which the identity was authenticated. It is not sufficient to simply record the fact that evidence was provided and examined – it is necessary to produce that evidence. A case study in relation to an investigation by DEASP’s Special Investigations Unit was provided to the DPC to illustrate this point. In the context where an accepted purpose of the SAFE process is to assist in the protection, detection and prosecution of fraud, it is, therefore, appropriate to retain the data and documentation acquired through this process for the purpose of any subsequent prosecution.

      14. In addition, proof of identity is one of the issues to be determined in any decision with regard to the payment of welfare claims. Under applicable law, any decision in respect of a welfare payment can be appealed or reviewed at the request of a person at any time. Production of the supporting documentation and information is important to the appeal/review process.

  3. jerry_banned

    i cant believe someone went to the hassle of transcribing that

    or banned me because i said the admin lives in a bedsit and threatened me ha ha ha ha

  4. italia'90

    Cian, can you explain why an English national can get an Irish passport without the PSC card and an Irish national here in Ireland can not?
    Is that not discriminatory?

    What a fiasco. And a very expensive illegal fiasco in my humble opinion.

    1. Cian

      Are there different application rules/documentation requirements (aside from the PSC) for English and Irish applicants?

      But that requirement only applied to adult first-time applicants. If you are renewing a passport, a PSC was never a requirement.

Comments are closed.