OPW announces change to Visitor Comment Books policy at Heritage sites
25 July 19
The Office of Public Works today announced that it has reviewed its approach to making Visitor Comment books available at sites following clarification by the Data Protection Commission that the use of Visitor Books are not a breach of GDPR.
OPW’s Heritage Service, which manages some of the most iconic visitor sites in the country such as Newgrange, Dublin Castle and Kilmainham Gaol, had started to withdraw Visitor Comment books from sites following advice received that they could pose a risk of being non-compliant with the General Data Protection Regulation (GDPR) if visitors chose to record personal data such as names and addresses. According to the advice received by OPW, this ran the risk of being viewed by other people who could retrieve visitors’ personal data for purposes other than that for which it was offered, potentially placing the organisation in breach of the GDPR.
In this case the objective of the OPW was to remove in so far as possible any risk to the data volunteered by customers in Visitor Comment books at OPW sites.
Frank Shalvey, Head of OPW’s Visitor Services Division, today said “The Data Protection Commission has confirmed that our interpretation may have erred on the side of caution and that there is no legal risk. The visitor season is at its peak right now and we would expect thousands of people to come to our sites throughout the remainder of July and August in particular and we are delighted to offer them the opportunity to leave comments on the books”.
The OPW will now review the use of Visitor Books with a view to reinstating them while ensuring compliance with the key GDPR principles.