The saga on the PPSN is unbelievable. A CU needs PPSN now for Revenue & for Central Credit Registry purposes.
GDPR in Article 5(1)(b) "...collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes.." and Article 6(1)(c) "processing is necessary for compliance with a legal obligation to which the controller is subject.." seems to say without much of a stretch is a CU have PPSN already they don't need another consent.
Department of Social Protection under instruction from Department of Finance (after being savaged about Irish Water) have insisted the Public Services card cannot be used. But curiously this means that a letter with the card one receives is correspondence under 6(1)(a) below but the card in the letter is somehow not correspondence.
In any event there is a VIES website where you can already verify Irish VAT Numbers (PPSN with addition of IE) which allows electronic verification- and would seem a simple solution.
However: The Regulations issued by Central Bank of Ireland seem to want a paper verification under SI 488 2016 but sanity prevailed in 6(3) which assumes an electronic method may arrive at some stage.
"Personal public service or other tax number
6. (1) A credit information provider shall verify an individual’s personal public service number (PPSN) against an original of any of the following
documents—
(a) any correspondence from the Department of Social Protection or the Revenue Commissioners addressed to the individual showing the individual’s PPSN,
(b) P21, Tax Assessment or Notice of Tax Credits,
(c) Receipt of Social Welfare Payment,
(d) Medical Card / Drug Payment Scheme (DPS) Card,
(e) Payslip, P60/P45.
(2) If a credit information subject cannot provide any of the documents specified in paragraph (1) the credit information provider may verify a credit information subject’s PPSN using any other document or process that may reasonably be relied upon for the purpose.
(3) A credit information provider shall verify any other number allocated to the individual for the purposes of tax against any document that may reasonably be relied upon for the purpose.
(4) In determining the reliability of any document referred to in paragraph
(2) or (3) the credit information provider shall have regard to the following:
(a) the nature of the body by whom the document was issued;
(b) the nature of the document;
(c) whether it might reasonably be expected that the document was issued following checks on the identity of the person.
(5) A credit information provider shall retain a copy of any document used for the purpose of verification under this Regulation for a period of 5 years beginning on the date that the credit information provider is last required by section 11 of the Act of 2013 and any Regulations made thereunder to provide personal information to the Bank in respect of that credit information subject"