31 December 2006
School Archiving Project: Disclosure of personal data
A former pupil of a national school in Dublin complained to me about a disclosure of personal data through the availability of school registers in Dublin City Libraries and in the National Archives.  These registers were indexed as part of the E Project.
The information contained in school registers, including names, addresses and dates of birth, is personal data within the meaning of the Data Protection Acts. 
The E Project involved the archiving of certain Dublin national school registers.  It was undertaken by the Irish Prison Service, in partnership with the Dublin City Public Libraries. The aim of the project was to reproduce certain school registers in an electronic format by inputting them into a computer database.  The information was then made available to the schools involved and was lodged in “The Dublin and Irish Collection” in Dublin City Libraries at Pearse Street and in the National Archives.
The complainant contacted my Office concerning the disclosure of his personal information in this manner.  
On investigation, it was established that Dublin City Libraries had not put the archive in question on public display and that the National Archives withdrew the material in their possession from display immediately upon receipt of a complaint made directly to them by the data subject. 
This case highlights, among other things, the vast quantity of personal data which is held in school records and the necessity of treating and handling such data in accordance with the Data Protection Acts (the Acts will apply fully to manual data with effect from October 2007).  I also recognise and appreciate the importance and significance of indexing and archiving school material as valuable genealogical, historical and sociological resources.  However, such indexing and archiving should be carried out in a manner compatible with an individual's right to privacy. In this case, the information indexed and archived was from the relatively recent past, with some records dating back to as recently as 1981, therefore allowing living individuals to be easily identified from the archived information.  
This is a matter that my Office is taking up with the Department of Education & Science to allow for the identification of the appropriate balance between the privacy rights of the individual and the broader public interest in such material being available for research purposes.