The Department of Education and Skills is currently creating an individualised database of primary school students; the Primary Online Database (POD). The POD will gather personal data and sensitive personal data about pupils, such as information about ethnic and cultural background, religion, medical conditions, students with special needs and students' Personal Public Service Numbers (PPSN). The POD will be shared with other state bodies, including the Central Statistics Office, the Department of Social Protection, the Department of Public Expenditure and Reform and the Revenue Commissioners.

The express written consent of the parents/guardians or students (if over 18 years) is required before a student's ethnic/cultural background or religion may be recorded on the POD. However, it has been reported that the Department of Education and Skills can by-pass parents' refusals to disclose their children's PPSN by obtaining them directly from the Department of Social Protection. 

Question marks have also recently been raised over the retention period of the data. Circular Letter 0017/2014 states that some details will be held until the pupil reaches their 30th birthday. The Data Protection Acts 1988 – 2003 provide in section 2(1)(c)(iv) that data may only be stored for as long as is required for the purpose for which it is collected. This has sparked opinion that this may amount to an excessive retention period for pupil's data leading to the Data Protection Commissioner, Helen Dixon, to seek clarity on this matter.