The legal basis of the PPS Number and its use is contained in the Social Welfare Consolidation Act 2005 (as amended). Only bodies specified in statute or their agents can use the PPS Number. Section 262 of the Act allows the PPS Number to be used by a specified body in certain limited ways in the course of a “transaction” with a member of the public. The section requires that the service being supplied must relate to a “natural person" i.e. not a private function by a private company.
Persons are required by section 262 to provide their PPS Numbers to Specified Bodies for the purpose of a "transaction".
The section also allows the Minister for Social Protection to share a person’s public service identity (including their PPS Number) with a Specified Body for authentication purposes. Accordingly, as both the Minister for Social Protection and all Specified Bodies must operate in accordance with the provisions of the Act, there is no requirement for a separate agreement to be in place.
Section 20 of the Social Welfare and Pensions Act 2014, which was enacted on the 17th July 2014, added Irish Water to the list of Specified Bodies. Irish Water has advised that PPS Numbers will only be processed by it in relation to confirming eligibility for allowances and accurately calculating water charges. Irish Water has posted information about its use of the PPS Number on the Register of PPS Number Users which is available on the Department of Social Protection website.
The Department is in discussions with Irish Water with regard to the appropriate assistance that can be given in relation to validation of PPS Number data.
