Ireland’s Data Protection Commission (DPC) found that Children’s Health Ireland (CHI) infringed GDPR rules on security and confidentiality after examining the handling of children’s paper health records at one CHI facility at Tallaght University Hospital. The DPC reprimanded CHI and ordered corrective measures; its 1 October 2026 announcement did not announce a fine.
What happened to the children’s records at Tallaght?
The DPC said it received protected disclosures in June and July 2025. It carried out an unannounced inspection at the CHI facility on 16 July 2025 and opened an inquiry on 11 August. During the disclosure process, the regulator learned that documents containing children’s sensitive and special-category data had overflowed from a confidential-waste bin beside the door of the Non-Consultant Hospital Doctor’s (NCHD) office. The documents were subsequently removed.
The inquiry examined the confidentiality of paper records stored and retained in the NCHD office and the proper management and control of those records. The DPC also included management and control of data placed in confidential-waste bins in its finding. This was a case about physical handling and security of paper records, not a reported cyberattack.
The DPC notified CHI at Tallaght of its decision on 10 September 2026 and announced it publicly on 1 October 2026. Its announcement is limited to one CHI facility at Tallaght University Hospital; it does not report a finding against every CHI facility. The DPC’s final-decision announcement describes the inquiry’s scope and outcome.
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Which GDPR rules did the DPC say CHI breached?
The DPC found infringements of Article 5(1)(f) GDPR, the principle requiring personal data to be processed with appropriate security, including protection against unauthorised or unlawful processing and accidental loss, destruction or damage. It also found an infringement of Article 32(1), which requires appropriate technical and organisational security measures.
In its announcement, the DPC said CHI failed to ensure appropriate security and confidentiality for personal data in the NCHD office, as well as proper management and control of data there and data placed in confidential-waste bins. The announcement does not identify Article 35 as an infringement; the orders to complete data protection impact assessments (DPIAs) are corrective requirements, not a separately announced finding under that article.
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Was CHI fined?
No monetary fine was announced. The DPC’s stated outcome was a reprimand and orders requiring CHI to bring the processing into compliance. The announcement does not set out the full decision’s reasoning, so it does not establish why the regulator chose those measures rather than a fine.
What must CHI do now?
The DPC ordered CHI to complete and finalise two draft DPIAs: one covering healthcare records in the NCHD office, and another covering confidential-waste management. It also directed CHI to:
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- Implement all technical and organisational measures and action items in the final DPIAs, including the standard operating procedures identified there.
- Provide both final DPIAs to the DPC for consultation within four weeks of the decision.
The DPC said it would publish the full decision in due course. Its 1 October announcement does not provide the detailed reasoning or the content of the draft DPIAs. An earlier notice, published when the inquiry opened, said the investigation would address data security and processes for managing physical records after potential issues came to light from multiple sources, including protected disclosures and a CHI breach notification. That earlier DPC notice gives the inquiry’s initial scope.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.What did CHI say?
The Irish Examiner reported that CHI acknowledged records had been stored in an unlocked room at CHI Tallaght in August 2025, described this as a breach of its own protocols, and said it accepted the reprimand. The newspaper quoted a CHI spokeswoman saying: “We apologise for any upset this issue may have caused to the children, young people, and families in our care.” These are statements attributed to CHI by the Examiner, not additional findings in the DPC announcement. The Irish Examiner’s report contains the reported response.
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