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Ireland’s Data Protection Commission (DPC) found that Children’s Health Ireland (CHI) failed to adequately secure and control children’s paper health records at its facility at Tallaght University Hospital. The records included documents that overflowed from a confidential-waste bin beside the Non-Consultant Hospital Doctor’s (NCHD) office. The DPC reprimanded CHI at Tallaght and ordered corrective action; 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. During an unannounced inspection at the CHI facility on 16 July 2025, and through the disclosure process, it learned that documents containing children’s sensitive and special-category data had overflowed from a confidential-waste bin beside the NCHD office door. The documents were subsequently removed. The DPC opened its inquiry on 11 August 2025. The DPC’s final-decision announcement says the inquiry examined paper records stored and retained in the office, their confidentiality, and the proper management and control of those records and confidential waste.

This was a finding about physical records and their handling at one specific CHI facility—not a report of a cyberattack, and not a finding against every CHI facility. The earlier inquiry notice described the investigation as examining data security and processes for managing physical records, following potential issues identified through multiple sources, including protected disclosures and a CHI breach notification. The DPC published that notice on 14 August 2025.

Which GDPR rules did the DPC say CHI breached?

The DPC found infringements of two provisions:

  • Article 5(1)(f): the GDPR principle that personal data must be processed with appropriate security, including protection against unauthorised or unlawful processing and accidental loss, destruction or damage.
  • Article 32(1): the requirement to implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk.

In its announcement, the DPC said CHI at Tallaght failed to ensure appropriate security and confidentiality for personal data in the NCHD office, and failed to ensure proper management and control of data there and in confidential-waste bins. The announced findings do not identify Article 35 as an infringement; the requirement to complete data protection impact assessments (DPIAs) is part of the corrective orders.

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Was CHI fined?

No monetary fine was announced. The DPC said it reprimanded CHI at Tallaght and ordered it to bring the processing into compliance. The announcement specifies those measures and does not state that the DPC imposed an administrative fine; it does not give a reason for the outcome.

What must CHI do now?

The decision was notified to CHI at Tallaght on 10 September 2026. The DPC’s 1 October announcement lists these corrective requirements:

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  1. Complete and finalise the draft DPIA covering healthcare records in the NCHD office.
  2. Complete and finalise a second draft DPIA covering confidential-waste management.
  3. Implement all technical and organisational measures and action items in the final DPIAs, including the identified standard operating procedures.
  4. Provide both final DPIAs to the DPC within four weeks of the decision for consultation.

What has CHI said?

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. A CHI spokeswoman told the newspaper: “We apologise for any upset this issue may have caused to the children, young people, and families in our care.” The Examiner also reported that CHI said it would work with the DPC. These are CHI statements reported by the newspaper, not additional findings in the DPC announcement. Irish Examiner report, 1 October 2026.

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What remains unclear?

The DPC said it would publish the full decision “in due course.” Its announcement therefore does not provide the detailed reasoning behind the findings or further particulars of the evidence considered. The published summary establishes the provisions found infringed, the records and physical-handling issues in scope, and the corrective orders; further detail depends on publication of the full decision.

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