# Water Utility collecting PPS Numbers



## monagt

If I do NOT wish to claim Water Allowances...why does a water utility need my PPS numbers?

When Irish Water is privatised, will the new owners then get my PPS number?


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## cremeegg

And your children's !


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## rob oyle

monagt said:


> If I do NOT wish to claim Water Allowances...why does a water utility need my PPS numbers?


 
My understanding is that this is to prove the number of occupants in the house (for water allowance purposes). Why wouldn't you want to claim the allowances? Presumably it'll cost more for the water without them!


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## monagt

Is the free allowance per house or per person (children aside)?


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## rob oyle

It's per person... 2+2 gets more of an allowance than 1+2.


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## Time

I think there is a basic household allowance, then you add in each person.


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## vandriver

rob oyle said:


> It's per person... 2+2 gets more of an allowance than 1+2.



Its 30,000 litres allowance per *household* with and additional 21,000 litres per child.


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## rob oyle

vandriver said:


> Its 30,000 litres allowance per *household* with and additional 21,000 litres per child.


 
Cheers... my bad. The Rob Oyle campaign of misinformation ends here!


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## Steven Barrett

Looking forward to listening to Liveline when the water charges coming into effect:

Joe: Tell me Mary, how often do you flush the toilet?

Mary: Once a week Joe. I'm afraid if I do it more often, I'll go over my allowance.

Joe: Afraid? Afraid? There's a fear then Mary. Do you hear that listeners. People living in fear in their own homes because of the water charges.


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## michaelm

sahd said:


> (It is proposed that there will be  minimum charge of €160 a year for vacant homes).


Surely that would translate to a minimum €160 charge of for all homes.


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## fobs

I am sure there will be a standing charge to ensure we all pay a minimum charge no matter how frugal with water we are.


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## michaelm

sahd said:


> Why ?  It will be possible for a single person with a water meter to have zero water charges if they use less that 30000l a year.  The minimum charge will apply just to non principal residences (it is proposed)


That's a bit Irish alright . . an empty house using no water will pay €160 but other can get a zero bill of staying within their quota.  I'll be interested if I can get a zero bill so.


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## Bronte

monagt said:


> When Irish Water is privatised, will the new owners then get my PPS number?


 
Don't know, but I personally have the PPS numbers of at this stage a large amount of people.  (PRTB for landlords requires this)  I've accumulated quite a lot of data on people.


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## Time

sahd said:


> Why ?  It will be possible for a single person with a water meter to have zero water charges if they use less that 30000l a year.
> 
> The minimum charge will apply just to non principal residences (it is proposed)



So NPPR by the back door?


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## monagt

ESB can charge even if no units used so it is better to use some rather than none as a minimum charge kicks in (to pay for the availability of the service)


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## potnoodler

Can be sure this data will be used when they launch 
Their new tv tax . The broadcasting tax


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## moneybox

Time said:


> So NPPR by the back door?


 
Precisely, these proposals  do seem extortionate for someone not living in their house or for expats who may not even live in the country.  Then as it stands at the moment they are only proposals and the eventual charges may not be as high.




> There will be no standing charge in respect of principal residences, but a minimum charge may apply to second homes. Irish Water has proposed a minimum charge of €80 per service per year for second homes – a total of €160 for a house using both public water supply and public wastewater services. This was among the proposals that the CER consulted on during August 2014.


 
http://www.citizensinformation.ie/en/environment/water_services/water_charges.html


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## Time

Would it not make sense to have vacant houses disconnected, so no charges then?


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## moneybox

it will be very expensive now for people to keep holiday homes or second homes in Ireland what with the €160 euro a year for water/sewage charges+ property taxes + ground rents for electricity and gas +house insurance, I reckon there will be another tsunami of houses coming on to the market very soon. It's all great news for the economy and will help stop the current spiral in house prices getting out of control


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## moneybox

sahd said:


> From supply and sewage? There will probably be a disconnection and reconnection fee which will be more tham the annual charge.


 
What €160 a year to turn off or turn on a couple of taps??


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## SlugBreath

We are two adults living alone with our children moved on. Do we still have to give our PPS number to get the water allowance or will the allowance be automatically allocated to the house?


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## SlugBreath

Will I be able to read my meter that is in the ground on the public footpath. I don't want to be a sad bas**** but I will be curious initially to see what my usage is. I hope that our monthly bills are itemised as to weekly usage.
I grow my own vegetables. Last night I needed to put a fair bit of water on these as they were wilting from the recent dry spell. It would be nice to know if I had "spare" water in my allowance so I can treat my veggies now and again.


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## michaelm

SlugBreath said:


> Will I be able to read my meter that is in the ground on the public footpath.


Yes.





SlugBreath said:


> I hope that our monthly bills are itemised as to weekly usage.


They won't be.





SlugBreath said:


> I grow my own vegetables. Last night I needed to put a fair bit of water on these as they were wilting from the recent dry spell. It would be nice to know if I had "spare" water in my allowance so I can treat my veggies now and again.


Seriously, are people really going to be counting litres?  Although I'm opposed to metered water charges in principle, it's actually really cheap . . just put half a red brick into each cistern in your house and give your parsnips a drink.


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## Gerry Canning

moneybox said:


> it will be very expensive now for people to keep holiday homes or second homes in Ireland what with the €160 euro a year for water/sewage charges+ property taxes + ground rents for electricity and gas +house insurance, I reckon there will be another tsunami of houses coming on to the market very soon. It's all great news for the economy and will help stop the current spiral in house prices getting out of control


 
Probably a lot of the 2nd/holiday homes are in places like Donegal , since we have a huge amount of vacant homes here, we don,t need the {tsunami}. 
You are are all welcome to come for very good houses @100,000.
Please bring the jobs too.


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## Gervan

> Seriously, are people really going to be counting litres?



Er, yes, michaelm, and I don't think it is "really cheap". As a pair of pensioners on low income (no big Irish pension) with 2 students over 18 in the house, based on the water we use at present we would be paying over €600 a year. 
Even if we get the rumoured household benefit it won't bring the cost down to the €200 per year I have spare.
I will have to do more than put a brick in the cistern, flushes will have to be rationed. It's sad and miserable, but I have no choice.

It does irk me that a PPS is required, when the electricity provider did not need it in connection with the household benefit.


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## cremeegg

Bronte said:


> Don't know, but I personally have the PPS numbers of at this stage a large amount of people.  (PRTB for landlords requires this)  I've accumulated quite a lot of data on people.



Excellent one. Free water for me then. And if I am queried I will tell them Bronte put me on to it.


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## moneybox

monagt said:


> ESB can charge even if no units used so it is better to use some rather than none as a minimum charge kicks in (to pay for the availability of the service)


 

Bord Gais charge just the standing charge if no electricity units are used, so unlike the ESB they don't fleece their customers for non usage.


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## SlugBreath

michaelm said:


> Yes.They won't be.Seriously, are people really going to be counting litres?  Although I'm opposed to metered water charges in principle, it's actually really cheap . . just put half a red brick into each cistern in your house and give your parsnips a drink.



I will certainly be keeping an eye on usage as I always have done but then again I keep an eye on lots of things and don't waste my money needlessly.
I actually find that parsnips are cheaper to buy in Aldi or Lidl than it is to grow them. My turnips were great this year and I got a double crop out of a packet of seeds.


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## moonman

moneybox said:


> Bord Gais charge just the standing charge if no electricity units are used, so unlike the ESB they don't fleece their customers for non usage.


as far as i know the reason for the esb charges you refer to is that the esb own the network and most of the infrstructure. the gas company just buy electricity wholesale and then retail it to us. i think it was an arrangement  all the electricity and gas suppliers came to with the dept of energy and the regulator. someone might know what charges the esb or electric ireland charge if they supply gas to a customer.


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## moonman

i have just received a letter from dept of social welfare with a form . the need my bank details for to pay 25 euro in to it every quarter starting januay for the 100 euro allowance for the over 66 year old


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## PyritePete

working this out logically & so if I have this correct...

30,000 + 42,000 litres for our 2 kids. This is not annual, just the free allowance given.

our toilets are 9 litre flushes, times the number of flushes per day.Throw in washing fruit & veg, washing hands & showers, washing machine etc the allowance seems low.


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## michaelm

Gervan said:


> Er, yes, michaelm, and I don't think it is "really cheap". As a pair of pensioners on low income (no big Irish pension) with 2 students over 18 in the house, based on the water we use at present we would be paying over €600 a year.


I suppose you're right. Although less than €2 per day for all water needs of four adults doesn't seem excessive to me . . that said it think that they should have fixed the leaking mains pipes rather than digging up half the country and creating this whole usage-less-allowance bill nonsense.


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## Bronte

sahd said:


> The PTRB are allowed to keep PPS numbers -but the forms the tenants fill in are surely for the PTRB and not for landlords to retain the data. I would have thought that retaining PPS details is breaking the data protection regulations ?
> I don't see Landlords mentioned on this list http://www.welfare.ie/en/Pages/Personal-Public-Service-Number-Register-of-Users.aspx


As it happens I'm just finishing off my landlord tax returns so I have my PRTB file with me. Going back to the 2005 form:

Requirements

1. PPSN no of tenant, tenant to sign and date form, my ppsn no, my signature and date, Cheque. 

2. Rule F on PPSN, 

_how to get a PPSN, says the use of it is governed by law, not to be stored, or used for any other purpose other than registration._

Now as I was a) dealing with the totally incopetent PTRB, and boy were they incompetent at the time, b) a matter that has serious revenue implications for me if I get it wrong, I photocopied the form before posting it. I do this in general with any government body. All those forms are in my PRTB file. 

If I hadn't done that, I wouldn't have been later able to send the PRTB a copy of that form so they could issue me with the confirmation number as they were not very efficient at the beginning on doing this.

The confirmation letter you receive from the PRTB does not mention the PPSN no of me or the tenants, it pretty much hasn't anything on it really, not in comparision to what I filled out in the form.

At some stage the PRTB stopped requiring the tenants signature and eventually not mine either if I'm not mistaken

Electronic submission

This format means when you submit, you can no longer see all you've filled out, they delete teh PPSN no. But I just write it on the paper file, I'd in any case have it on a piece of paper before I sit down at the computer to register. In addition I write on that document the Out date of the tenant.


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## Time

My water bill is €70 with an included household allowance of 200,000 litres. Between today and last April when my meter was last read, I have only used 15,000 litres. I am not stingy on the water either.

I think people are blowing this out of all proportion.


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## PyritePete

eh, no silly billy.


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## Drakon

Why are Irish people so private about the PPSNs?  It the US the SSN is not such a guarded secret.  It's like your name; though it's unique.


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## Time

The DSP specifies who may use a PPSN. This has been eroded over the years by other non state bodies asking for it, mostly banks etc. The DSP and DPC are clear on what it may be used for.

The situation in the US is the same. People do not give it freely and although banks ask for it there is no legal reason for this and service cannot refused if the person does not give it. It is a government identifier only.


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## Roisinb

monagt said:


> If I do NOT wish to claim Water Allowances...why does a water utility need my PPS numbers?
> 
> When Irish Water is privatised, will the new owners then get my PPS number?


 
Can Irish Water take money with the Bank details they require?


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## moneybox

Time said:


> *My water bill is €70 with an included household allowance of 200,000 lit*res. Between today and last April when my meter was last read, I have only used 15,000 litres. I am not stingy on the water either.
> 
> .


 
I gather you dont live in Ireland, you have a very generous water allowance.


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## Time

That is in Ireland.


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## Sumatra

A recently received Irish Water application form requests my children's PPS numbers. 

When you read Section G Data Protection, you realise there is no control over how much PPS data you are actually giving Irish Water and/or their agents (present and future) permission to obtain. Not only that but it appears that all persons you give PPS numbers for are not being given the opportunity of opting out of marketing. From the wording it appears the bill payer can opt out of certain marketing but that doesn't seem to extend to the other persons information you have given.

1. I'd like to understand how much information I am effectively permitting Irish Water to collect from my PPS number and those of my Children. Does anyone know?

2. I wonder if the other persons you are being asked to supply PPS numbers for also should be given the individual opportunity of opting out from marketing? 

The bill payer is responsible for paying the charge. It seems strange that that person is asked to give other persons PPS numbers and by so doing also giving authority for Irish Water / agents to collect unspecified information about them and to use that information in unspecified ways. 

My reading of the application guide is if you don't give your Children's PPS numbers then you won't receive the additional water allowance and if you don't return the form then you will be charged the default assessed charge - although it appears you retain a certain control over your personal information.


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## Time

If you don't return the form you don't even get the household allowance, they need 1 PPSN for that. You will just get charged the per 1000 litre rate.


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## monagt

http://www.independent.ie/opinion/columnists/gene-kerrigan/the-government-is-ppsing-all-over-us-30602998.html


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## moneybox

monagt said:


> http://www.independent.ie/opinion/c...overnment-is-ppsing-all-over-us-30602998.html


 
Well after reading that, I have firmly made up my mind these people are not getting my PPS number, I am a non resident, I will pay whatever charge I have no pay but without my pps number. The cheek of them to attempt to commercialise the numbers, its a disgrace.


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## theresa1

*"The free household water allowance is  30,000 litres  a year and is   worth up to €146.40 a year per household. The childrens water allowance  of 21,000 litres   is worth up to €102 per child per year." - *****************

Not giving your PPSN will cost you - people need to be aware of this.
*


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## mandelbrot

Time said:


> My water bill is €70 with an included household allowance of 200,000 litres. Between today and last April when my meter was last read, I have only used 15,000 litres. I am not stingy on the water either.
> 
> I think people are blowing this out of all proportion.


 


Time said:


> That is in Ireland.


 
The island of Ireland, maybe, but not the Republic of Ireland based on those figures..?


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## moneybox

theresa1 said:


> *"The free household water allowance is 30,000 litres a year and is worth up to €146.40 a year per household. The childrens water allowance of 21,000 litres is worth up to €102 per child per year." - ******************
> 
> *Not giving your PPSN will cost you - people need to be aware of this.*


 

*Irish Water reduces free allowance for children *

*Allocation of 38,000 litres announcedby Government cut to 21,000 litres *

http://www.irishtimes.com/news/politics/irish-water-reduces-free-allowance-for-children-1.1884285


I am sure the Joe Duffy show will be busy tomorrow once people cop on to the fact that our personal data may be used for commecial reasons.


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## Time

mandelbrot said:


> The island of Ireland, maybe, but not the Republic of Ireland based on those figures..?



Laois to be exact.


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## Lightning

theresa1 said:


> *"The free household water allowance is  30,000 litres  a year and is   worth up to €146.40 a year per household. The childrens water allowance  of 21,000 litres   is worth up to €102 per child per year." - *****************
> 
> Not giving your PPSN will cost you - people need to be aware of this.
> *



Unless you are on an unmetered plan, in which case supplying additional PPN numbers costs you because your bill is based on the number of people in the household.


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## Bronte

Any chance somebody could scan the form.  I'm wondering why I as owner has to register when it should actually be in my tenant's names, same as electricity etc.  

I also don't understand all this debate about allowances, it's making it very complicated.


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## Sumatra

How do you think they will check??

Child Benefit is linked to the Mother and only to the Father in 2%-3% of the cases. What do you bet the vast majority of application forms have been sent out to the 'male' in the family to complete. How will they link the child's PPS number to the bill payer to give the children's water services allowance??


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## Steven Barrett

Just by registering for this website, you have given away a lot of personal information to a 3rd party. never mind all the details you give away on amazon, facebook etc. Then those on LinkedIn have their entire cv's up on public display. For those who have your own business, your home address and date of birth can be found in 2 seconds. If you have a limited company, even more information can be found in those 2 seconds. You give away personal information online all the time and it is constantly being sold to companies who want to sell you stuff. 


Steven
www.bluewaterfp.ie


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## chrisboy

Bronte said:


> Any chance somebody could scan the form.  I'm wondering why I as owner has to register when it should actually be in my tenant's names, same as electricity etc.
> 
> I also don't understand all this debate about allowances, it's making it very complicated.



Was listening to Joe Duffy today, and the reason they're looking for the landlords pps number is so if the tenant doesn't register then the landlord will be charged. It will then be upto the landlord to get reimbursed from the tenant. Unbelievable but true.


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## Sumatra

It is the access to data over and above what is required to manage a bill for water that ruffles my feathers. 

Section G data protection on their application form also refers you to their full data protection notice which appears on their web site. I can't see anything in this that clearly states the eight rules of data protection which govern the processing of personal data set out.

The Eight rules are:

Obtain and process the information fairly;
Keep it only for one or more specified, explicit and lawful purposes;
Process it only in ways compatible with the purposes for which it was given to you as a utility;
Keep it safe and secure;
Ensure that is adequate, relevant and not excessive;
Retain it no longer than is necessary for the specified purpose or purposes;
Give a copy of his/her personal data, on request.

Their current data protection statement is a shambles and without clarification and revision I can't see how it is possible for the vast majority of people to return their completed forms by the deadline.


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## Time

If you are only a waste water only customer do you need to apply for allowances?


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## Steven Barrett

sahd said:


> It is the PPS numbers that people seem to be more worried about - which I can kind of understand but I think it is worry probably over nothing .
> The Government decided that they wanted this free water allowance thing - and I assume that they need some verification of who has had the free allowances from Irish Water. PPS is the identifier used for all govt transactions - tax, welfare, health and now water.
> The PPS is  probably as safe (or unsafe) with Irish Water as it it with Revenue, HSE, PTRB, Welfare and all the other bodies that use it.



I don't know why. If they think someone will rob their identity, there have probably given more than enough information to less secure organisation to have their identity cloned.

Another way of looking at it is that society has become so dishonest as a whole. We cannot be trusted not to abuse the system by declaring the actual number of people living in each house.

Anyway, lots of ammunition for Joe Duffy. I must download a few podcasts to hear the hysteria.


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## Sumatra

> If they think someone will rob their identity, there have probably given more than enough information to less secure organisation to have their identity cloned.


 
There are less than 50 authorised bodies to use PPS numbers under Social Welfare Law and those bodies have clearly stated what information they obtain and what they use it for. Irish Water have not.


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## Bronte

sahd said:


> Using the PPS number they will probably just..
> a) check PPSN is a valid PPSN for a child getting child Benefit
> b) check that a given child PPSN has not been given for anothe child at this or any other address on their system.
> 
> I don't expect them to be cross checking parents/carers and addresses.


 
Based on their incompetence so far, 6K letters sent incorrectly, many landlords not receiving any letter despite being in multiple 'systems', those landlords that have received letters have been linked to incorrect premises (according to my phone call with Irish water they are spending most of their time rectifying the system they have) I wouldn't hold out much hope for them cross checking anything.


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## Bronte

chrisboy said:


> Was listening to Joe Duffy today, and the reason they're looking for the landlords pps number is so if the tenant doesn't register then the landlord will be charged. It will then be upto the landlord to get reimbursed from the tenant. Unbelievable but true.


 
Don't believe everything you hear on Joe Duffy, and don't ever believe that Irish state bodies are telling the truth.

It seems to me, if I give them my PPS number and register as landlord, then I could potentially be liable. 

However if I don't register or give them my PPS voluntarily they cannot bill me. But they are threatening us right now hoping we stupidly will register.

So far my conclusion as non resident landlord is that I simple notifiy them that I am a non occupier of any property and they are not to charge me anything. I have no intention of pursuing my tenants for a quango like Irish water.

I fully however support water charges. They have enough time and money to waste, let them go out and chase the tenants.  150 million or so on consultants and start up costs.


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## Bronte

Sumatra said:


> There are less than 50 authorised bodies to use PPS numbers under Social Welfare Law and those bodies have clearly stated what information they obtain and what they use it for. Irish Water have not.


 
I've no idea who those 50 authorised bodies are.  But every landlord in the country is legally obliged to collect the PPS number of their tenants for registration with the PRTB.  

Now does that mean we are authorised or not?  No idea.


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## olddoll

Irish Water say they require the PPS number to determine the free water allowance for each household.  Can they decide at a future date to reduce the water allowance and/or eliminate it?  What would prevent them from doing this?


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## Sumatra

Olddoll, if I was an EU citizen living in Ireland and my child lived in another EU country I could get the Child water allowance here.

Hi Bronte, see http://www.welfare.ie/en/Pages/Personal-Public-Service-Number-Register-of-Users.aspx

Note: Above site last updated 28/08/2014 and to date Irish Water have not replied to answer the 5 questions. Also note, Irish Water's application guide and application form that we received in the post is version IW/V/Form/0814


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## Time

Why do they still need it if you are only using the sewerage only? It is simply bizarre.


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## STEINER

Sumatra said:


> if I was an EU citizen living in Ireland and my child lived in another EU country I could get the Child water allowance here.



I find it laughable that a child water allowance be given for a child who doesn't use any water in this country.


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## michaelm

moneybox said:


> *Irish Water reduces free allowance for children *. . *Allocation of 38,000 litres announcedby Government cut to 21,000 litres *. .
> http://www.irishtimes.com/news/politics/irish-water-reduces-free-allowance-for-children-1.1884285


My understanding is that the expected usage for a single occupancy household is 66,000 and increasing by 21,000 for each additional person; and as the government don't want to be seen to be charging children for water their free allowance (now 21,000 down from 38,000) is supposed to cover the average usage attributable to a child.

My meter was installed in September last year so, assuming the meter read 0 when installed, I know what I've used, having read it this week.  I have no doubt that our water usage is not excessive and not untypical.  If I take it that the expected 87,000 usage for two adults is probably about right then my kids used 26,500 on average . . so their free allowance covers <80% of normal usage.


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## Sarenco

The relevant legislation creates a rebuttable presumption that the owner and occupier of a dwelling are one and the same.  However, the legislation does NOT create a secondary liability on the part of an owner to discharge any water charges that are unpaid by the occupier of that dwelling.  Irish Water are entitled to access details from the PRTB so there is no legislative basis for any suggestion that the owner of a property that is subject to a registered tenancy would ever be liable for water charges relating to that property.


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## Bronte

Sarenco said:


> The relevant legislation creates a rebuttable presumption that the owner and occupier of a dwelling are one and the same. However, the legislation does NOT create a secondary liability on the part of an owner to discharge any water charges that are unpaid by the occupier of that dwelling. Irish Water are entitled to access details from the PRTB so there is no legislative basis for any suggestion that the owner of a property that is subject to a registered tenancy would ever be liable for water charges relating to that property.


 
Very good post. Especialy for a first and only post, perchance someone in Irish water. I suspected the same myself. Irish Water are trying to 'encourage' landlords to register or get their tenants to register. 

In the meantime I am in contact with Irish water and it will be at least a week before they confirm the legal situation. 

I believe Joe Duffy's team are also seeking clarity.  And the IPOA is working on clarity.


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## PyritePete

did anyone catch PrimeTime last night, there was a lady from Irish water on. She seemed to explain away the data transfer to outside the EU as for maintainence reasons, so someone who could fix whatever issue remotely ?

I agree with one of the contributors that we should pay for GOOD service.

One other contributor saying this lady was twisting the truth...by giving PPS numbers we get the allowance.


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## Sarenco

Hi Bronte,

I'm afraid I have no connection whatsoever with Irish Water. I just find it very frustrating that Irish Water appear to be adopting a position that is completely at odds with the relevant legislation.

The Commission for Energy Regulation (which regulates Irish Water) has published the following on its website as part of a series of FAQs:

*Q: I own a property, which I rent out to tenants. Who pays the water charge on my property?*
_The occupier or tenant of a property should pay the water charges applicable to that property. However, where an occupier cannot be identified, then liability for the charges defaults to the owner who will ultimately be responsible for the payment of those charges._

So far so good.  If the occupier of a property cannot be identified (for example because the property owner has failed to register a tenancy with the PRTB) then the property owner is deemed to be the occupier of that property under the legislation and is liable for any outstanding water charges.  

However, Irish Water appear to be taking this one step further by saying that if the occupier of a property fails to pay a water charge then the obligation to make this payment somehow "defaults" to the property owner, even in circumstances where that occupier can be identified by Irish Water.  This is simply nonsense.

Aside from the lack of legislative basis for this position, how would it work in practice?  For example, at what point would the property owner become liable for this unpaid charge (i.e. would the charge have to be outstanding for 30 days, six months, a full year?).  Also, if a property owner did pay outstanding water charges in these circumstances, would this discharge the occupier from any further liability or would Irish Water be entitled to continue to pursue the defaulting occupier?

Like many others on this forum, I am fully supportive of the "user pays" principle when it comes to precious resources like water.  However, I am rapidly coming to the conclusion that the implementation of this important policy by Irish Water is turning into a fiasco and requires urgent intervention by the CER.


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## Sarenco

Well, the following is apparently a direct quotation from an Irish Water help centre agent that was reproduced in last week's Sunday Independent:  

_"In the worst case scenario, if the tenants tried to dodge the bill, the onus would fall on the landlord," he said._

I have no idea whether this the agent was misquoted or whether the agent is misrepresenting the position of Irish Water (which is why I referred to the position that Irish Water appear to be adopting).


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## diver

I am a landlord. I received the Irish Water pack to my home address today in respect of the rental property.

If I fill out my own details as a landlord, it's possible I may become liable for water charges if the tenant doesn't pay. This is not something I'm prepared to do. All other utilities are paid for by my tenant with no liability on me if they default on payments (bill follows the tenant etc).

So, my other option is to get the tenant to fill out their PPS no etc in my presence and I post the return letter back to Irish Water? How will I know if the information supplied is correct? If it's not, will they still chase me as the landlord?

There are too many variables in this whole sorry mess.

What are other landlords planning on doing in this above scenario?


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## Bronte

sahd said:


> A second hand quote from a call center operative is not official policy.
> That's half the problem with a lot of the "uproar" about the water charges - people hear things and see things in papers or on facebook and believe them to be true.
> 
> ANyway - that quote could be justas easily referring to the tenant "dodging the bill" by not registering in the first place.
> 
> Basically if nobody declares themselves as occupants and Irish Water know who the owner is what else can they do except go after the owner for water charges?


 
I totally disagree that they can come after me as non occupier until I see a legal basis for this. So far I've been only able to clarify this,

*non occupiers are not liable.*

In addition I telephoned the call center and spoke to one person and later the supervisor as I was getting nowhere. Both told me I was the liable person if the tenant did not register. When I asked on what basis, they actually told me to go to www.irishstatutebook.ie to look up the legislation. I asked them which legislation, and what clause on what page. 'We are not legally qualified to answer that' is what I got. 

I asked whose idea was it to direct people to the legislation, 'that's what we learnt at the training'. I nearly hit the roof at that. 

Finally via the supervisor's advice I have taken this further and when I have my correct answer I will get back on here.

In addition to that, I* have it in writing from them,* and not just from one person

_- if the tenants don't fill out the form that I am liable -_

_- that as landlord I am the legal owner, if the tenants don't register, then I am liable - _

I've slightly changed the wording there, so as not to be identifiable and I'm not the only one working on this, but so far they are unable to prove to me that I am liable. As I said Joe Duffy's team are working on it, and so are the IPOA. 

What I do however believe is that, *IF* I fill out the form, I'm somehow making myself liable. I've no intention of doing this.


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## delgirl

diver said:


> I am a landlord. I received the Irish Water pack to my home address today in respect of the rental property.
> 
> If I fill out my own details as a landlord, it's possible I may become liable for water charges if the tenant doesn't pay. This is not something I'm prepared to do. All other utilities are paid for by my tenant with no liability on me if they default on payments (bill follows the tenant etc).
> 
> So, my other option is to get the tenant to fill out their PPS no etc in my presence and I post the return letter back to Irish Water? How will I know if the information supplied is correct? If it's not, will they still chase me as the landlord?
> 
> There are too many variables in this whole sorry mess.
> 
> What are other landlords planning on doing in this above scenario?


Complete the form with your tenant's details and check the 'tenant' box on the form - you only need 1 PPS number and you should have this already when you registered the tenancy with the PRTB.

If there are children in the house, ask the tenant for their PPS numbers and list them on the form.  Ask the tenant if they want to pay by Direct Debit or if they wish to receive a bill.  If by DD, they need to give you their bank details, if not leave that section blank and send off the form to Irish Water.

I've done this with my tenants and would definitely not risk posting or giving the form to the tenant to complete as my name is on it as the owner of the property.


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## Bronte

Delgirl, Irish water told me I'm not allowed to fill out the form for the tenants, something to do with data protection.  I told them I have my tenant's PPS numbers as I was allowed to fill it out for the PRTB, but they explained because this is going to be a 'charge' then I'm not allowed to fill it out.


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## delgirl

To be honest with you, I don't really care what they say.  There's no signature required and I have completed and sent off the forms.

My tenants are nice people, but I couldn't risk them not sending off the forms either on time or at all as my name is on the forms.

If they have access to the PRTB database, which I believe they do, then they should have sent the forms to the tenants directly and not to the landlords.


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## Bronte

Thanks Sahd for it's location, here's it in full (and we had it on the other thread too)

_(5) It shall be presumed, unless the contrary is proved, that the owner of a premises is also the occupier of that premises._

By the way, I also asked IW (Irish Water) what proof they require from me to show I'm a non occupier, no reply to that either.


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## delgirl

sahd said:


> Maybe they would have sent forms to the tenants once you returned your form confirming your properties ?


Hi Sahd, I'm not sure which form you're referring to - the only one I received was the actual registration form from Irish Water with my name on it and the addresses of my rental properties.


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## Bronte

delgirl said:


> To be honest with you, I don't really care what they say. There's no signature required and I have completed and sent off the forms.
> 
> .


 
Didn't realise that either, I've no form of any description yet.  Great news, no signature required, sure it's easy peasy for me to fill out the form for the tenants so.


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## delgirl

My tenants didn't get any forms, the forms came to my home address instead with my name on them and the addresses of the rental properties.

I got the child's PPS number from one of the tenants and she said she'd prefer not to pay by DD so I filled in the form and sent it off.

I'm afraid if I don't do it, I'll end up having to pay as my name is on the forms.


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## Time

My brother is a tenant and got his form addressed to "The Occupier, Flat xxx, etc".


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## Sumatra

When claiming the Children's water allowance it is up to you to contact Irish Water when they are 18 to have them taken off the allowance. Their system doesn't take them off automatically.


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## Time

Surely they can check DOB's with the DSP on any child PPSNs supplied?


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## mandelbrot

Time said:


> Surely they can check DOB's with the DSP on any child PPSNs supplied?



DSP are no more going to give them DOB details than any other personal data they hold - Data Protection...


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## Time

So what exactly are IW checking with the DSP?


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## Sarenco

mandelbrot said:


> DSP are no more going to give them DOB details than any other personal data they hold - Data Protection...



Actually IW do have the power under the relevant legislation to obtain such information as it may reasonably require in order to discharge its functions from various bodies (including DSP).


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## Sumatra

> What makes you think that?


 
I spoke to a manager in Irish Water today regarding their use of Children's PPS numbers and I found out that when your child reaches 18 'It is incumbent on the person who has made the declaration on behalf of that child to contact us and declare it'. They will NOT automatically delete the information.  All they want to know from the child's PPS number is (a) it is a valid PPS number (b) it has not been duplicated to claim allowances at another address and (c) that the PPS number for the child is related back to the postal address where the child benefit is paid out. Their system does not pick up that a child has reached 18 just like it doesn't pick up a person moving from one address to another.  

The manager was adamant, telling me in the declaration it is clearly stated that it is my responsibility to contact them if there is any change of information provided in the form. I asked if they intend sending out an application form each year and I was told 'no'. I asked what if I only discovered this in 5 years time? The reply 'I suppose you'd owe us for water you shouldn't have been claiming for.'



> Surely they can check DOB's with the DSP on any child PPSNs supplied?


 
'When I contacted the Department of Social Protection their reply to me was '..this department will be verifying data provided to us by Irish Water'. Apparently it is up to Irish Water to apply. Irish Water has said they never said they would be checking the date of birth of a child.


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## Bronte

Now's the time to reach out for the PPS number of deceased relatives.  

What a totally and unnecessarily complicated system.  No wonder the start up costs are in millions.


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## Sarenco

Extract from a report in today's Irish Times (29 September 2014):

_"Irish Water has said landlords will not be held liable for arrears of water charges built up by their tenants. _

_The utility firm said landlords will be sent application packs in relation to their rental properties, which they must forward to the tenants. _
_In the case of an owner occupier, the full allowances in relation to water usage are allocated in the normal way and the occupier is liable for the bill._

_A spokeswoman explained that if the property was unoccupied the landlord could claim unoccupied dwelling status and pay a set charge. The level of which is still under consideration by the regulator. In this case the landlord is liable for the charge. _

_However in the case of a rented property, Irish Water said, “The tenant is liable for the charge and is also eligible for the allowances as the property is the principal primary residence of that household.”_

_However the spokeswoman said application packs for rented dwellings would be addressed to the landlord, at the landlord’s residence, and it would be the landlord’s responsibility to ensure the tenant received the application pack."_


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## Bronte

Here's the link to the article

http://www.irishtimes.com/news/irel...-not-liable-for-tenants-water-bills-1.1944634

So they are getting our home address from the NPPR and LPT database.  I'm on both, and have received no documentation from them yet.


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## Sarenco

Assuming the accuracy of the Irish Times article, it appears that Irish Water have changed their position that a landlord/owner would be liable for water charges relating to a particular property unless the tenant/occupier of that property assumed liability for those charges by completing and returning an application form.  That position, in my opinion, was not supported by the relevant legislation and therefore this apparent change of approach is to be welcomed.

However, the legislative basis for imposing a responsibility on landlords to ensure that their tenants have received an application pack is unclear to me.  Furthermore, what are the consequence where a landlord fails to discharge this "responsibility", for whatever reason?

Perhaps this will all become clear in the coming days but the approach of Irish Water to date on this issue does not fill me with confidence.


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## mandelbrot

Bronte said:


> Here's the link to the article
> 
> http://www.irishtimes.com/news/irel...-not-liable-for-tenants-water-bills-1.1944634
> 
> So they are getting our home address from the NPPR and LPT database.  I'm on both, and have received no documentation from them yet.



Have they sent out all the application packs yet though, maybe yours is at the tail end?


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## TTI

I just received mine within the last four days, so it seems the process is ongoing.




Bronte said:


> Here's the link to the article
> 
> http://www.irishtimes.com/news/irel...-not-liable-for-tenants-water-bills-1.1944634
> 
> So they are getting our home address from the NPPR and LPT database.  I'm on both, and have received no documentation from them yet.


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## moneybox

Sarenco said:


> but the approach of Irish Water to date on this issue does not fill me with confidence.


 

and big Phil is not around to sort it all out


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## monagt

Can you fill in the form with the PPS and delete the references that say "you are a customer of Irish Water" and sign it?

This "customer of Irish Water" is used 3 times, B(4), B(5) and (D) Declaration.

I was never a "customer of the Local Authority" and for example, in places like Meath water charges always existed.


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