26 June 2020
The Irish Council for Civil Liberties (ICCL) and Digital Rights Ireland (DRI) welcome the Health Service Executive (HSE) release today of the Data Protection Impact Assessment (DPIA) and source code of the Covid-19 tracker app.
Elizabeth Farries, director of ICCL’s Information Rights programme, said:
“Along with other experts, we have been calling for clear transparency in the app development process since April. We’re pleased to have been provided an opportunity to review these details prior to app’s release. Further to our expert principled framework, we are also encouraged by the Department of Health’s engagement with our expert group in order to encourage diverse views and inputs.”
Having reviewed the DPIA and source code we would raise the following concerns:
The DPIA claims that this app is being developed because “mobile technology can improve the speed and accuracy of manual contact tracing”. However we have not seen any evidence that the HSE app will fulfil this goal. Rather we have evidence suggesting Bluetooth signal strength is not a reliable means to detect contact with individuals infected with Covid-19.
Dr TJ McIntyre, chair of DRI, said:
“We welcome that an App Advisory Committee will continually assess the efficacy of the Covid-19 app and include a ‘self destruct’ mechanism within 90 days if they find the app is ineffective. We ask the HSE and Department of Health to clearly explain how they have determined the app is effective pre-launch, outline the committee’s criteria for efficacy and review and publish criteria for the self destruct mechanism immediately.”
We understand the terrible reality of Covid-19 for the population and everyone wants to do everything possible to fight Covid-19. However, to ensure Ireland’s Covid-19 tracker app is effective, respects rights and legality, and adheres to our expert’s principled framework, we encourage the App Advisory Committee to include a member of civil society. The Irish Council for Civil Liberties is available and willing to participate.
Press queries: Sinéad Nolan 087-4157162
Read ICCL and DRI’s joint submission to the Oireachtas COVID19 Committee here: https://www.iccl.ie/dri-iccl-covid-19-app-oireachtas-submission/