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10 July 2018
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Q. Can a GP ask for a patient's PPS number?

A. GPs are not specified bodies under the Social Welfare Acts, but they may ask patients for their PPSN as part of specified HSE schemes such as the Mother and Child scheme, Childhood Immunisations and Cervical Screening or Sickness Certification for the Department of Social Protection. The Data Protection Commissioner acknowledges that entities such as the Department of Social Protection (DSP) or the HSE are legally permitted to seek the PPSN in the context of the provision of a service. 

The PCRS Circular 027/18, shown in Appendix M of "Processing of Patient Personal Data: A Guideline for General Practitioners" states that for GPs operating under a contract of service "the use of and the retention of an eligible person's PPSN is a prerequisite in the provision of general practitioner medical and surgical service to that person, or to his/her spouse or partner and child dependants that are also eligible to such services". This should provide reassurance to GPs that having obtained and stored a PPSN, it is reasonable to retain that number in the patient medical records, for purposes of audit if necessary or further lawful use. 

We would still advise that the capture of the PPSN must not be made on a "just-in-case" basis or be used as a practice identifier.