Data sharing restrictions as a barrier to addressing property vacancy in Ireland

Authors

Dr Philip Crowe, Dr Rob Brennan, Dr Gavin McArdle, Dr Anna Skoura, Dr Madeleine Lyes, Dr Katsiaryna Bahamazava, Dr Jack Kavanagh, Junli Liang, Orla Leyden, Carla Fidecaro, Rola Abu Hilal, Darragh Redmond, Milo Dennehy, Yasmin Carolina do Amaral Pires Cannavo, and Sara Curatolo

Preamble:

Barriers to data sharing impact the design and effective delivery of policy in many sectors including housing, healthcare, planning and energy efficiency. Using the example of geospatial data related to the built environment, and specifically to property vacancy, we argue that nurturing a positive data culture, informing and supporting data governance policy, and building increased capacity and resources to enable data sharing for the public good would lead to positive transformational change in addressing environmental and societal challenges.

Explanation of key terms:

Data governanceStandards and policies on how data is collected, stored, processed and disposed of.
Data sharingThe practice of making data accessible to multiple parties, organisations or systems.
Data cultureThe collective organizational mindset, behaviours and practices that prioritize data-driven decision-making.
Digital transformationThe comprehensive integration of digital technologies into all areas of an organization or society, fundamentally changing how operations are conducted, value is delivered, and stakeholders interact.
Proprietary data solutionsData that is not open or standards based and/or controlled by a private company.
Vacant propertyA property that is not currently occupied by anyone.

Acronyms:

BDNBBase de Données Nationale des Bâtiments (National Building Database)
CSTBCentre Scientifique et Technique du Bâtiment (Scientific and Technical Centre for Buildings)
DPCIrish Data Protection Commission
DPIAData Privacy Impact Assessment
ESBElectricity Supply Board (Ireland)
GDPRGeneral Data Protection Regulation (EU)
GHGGreenhouse Gas
GNIGas Networks Ireland
OGCIOOffice of the Government Chief Information Officer
RIResearch Ireland
UEUisce Éireann (Irish Water)

Introduction

The Building Stories project, based in the UCD School of Architecture, Planning and Environmental Policy, and the UCD School of Computer Science, sets out to address the challenge of the inefficient use of the existing built environment in Ireland, most directly evident in high levels of vacancy and underuse in our town centres. The project focuses on three impacts that would result from the more efficient use of the built environment:

  1. more urgently needed homes from the reuse of existing buildings and infill development;
  2. reduced greenhouse gas (GHG) emissions from less demolition and construction, helping Ireland to meet a target of a 51% reduction by 2030 (relative to 2018 levels) and reach carbon neutral status by 2050; and
  3. revitalised town centres to support sustainable communities.

Building Stories aims to resolve a specific problem that perpetuates the above challenge: the lack of comprehensive data on vacancy at the granular scale of individual buildings or sites in Ireland. As there is little understanding of the scale, distribution and nature of vacancy, Building Stories is developing a geospatial data platform and interface for the built environment in Ireland that can be queried to identify properties that are likely to be vacant, and therefore reveal the adaptive capacity of urban areas to address societal and environmental challenges. The platform brings together different proxy and real datasets, GIS and predictive modelling (using AI), to provide a dynamic management tool for the built environment at the granular scale of individual buildings and sites. This will lead to more efficient use and management of the built environment, and support public and private actors to provide urgently needed homes, reduce GHG emissions, and revitalise town centres.

Numerous policy documents and reviews have called for a national geospatial data platform for vacancy at a granular scale, including the National Spatial Strategy 2002-2020 (Government of Ireland, 2002); ReBuilding Ireland: Action Plan for Housing and Homelessness (2016), Action 5.1 (Government of Ireland, 2016); National Vacant Housing Reuse Strategy 2018-2021, Objective 1 (Government of Ireland, 2020); Town Centre Living Initiative (TCLI), Suggested Action 2 (Crowe et al., 2020); Housing for All (HfA), Objective 19.12 (Government of Ireland, 2021); Town Centre First (TCF), Section 5.1 (Government of Ireland, 2022); and the Vacant Homes Action Plan (VHAP) 2023-2026 (Government of Ireland, 2023). The latter notes that

“The challenge for policy makers and stakeholders is to identify a data baseline which can be used at a high level to report on vacancy and develop policy, but can also be interrogated at a granular level to enable activation of vacant properties.” (p.3)

The Building Stories project started in 2023, and is funded by Research Ireland’s National Challenge Fund under the Our Tech Challenge stream, which explores how digital technologies could enhance government processes and functions.

The project presents many technical challenges, but the greatest challenges are associated with data governance. More specifically, they relate to barriers to data sharing (of open, protected or sensitive data), despite a drive at EU and national levels towards data sharing for the public good using efficient, interoperable and trusted data infrastructures.

This paper briefly (1) discusses some barriers to data sharing; (2) describes the enabling regulatory environment for data sharing in the EU and Ireland; (3) introduces an EU precedent for the geospatial platform, and; (4) sets out ways in which Building Stories is addressing the barriers to data sharing, and how the project can help precipitate transformational change in our government processes and functions.

It should be noted that the Building Stories project fully acknowledges that personal data must be treated with care. The project will not compromise the integrity and security of personal data at any point. However, it does seek innovative solutions that avoid any compromise of personal data privacy while allowing datasets (that may contain personal data) to contribute to the public good.

1. Barriers to data sharing

A broad range of datasets can contribute to assembling a profile, or story, of a building or site. Building Stories has identified key datasets from outside of the traditional GIS domain that will help indicate the likelihood of vacancy, including utility data (Gas Networks Ireland, ESB, Uisce Éireann), energy performance (SEAI), Local Property Tax (Revenue), and datasets relating to waste, car registration, planning, compliance etc. (Local Authorities). We suggest here some examples of barriers to sharing in these cases that reflect the OECD (2023) finding that Ireland is still in the early stages of developing a data sharing culture and infrastructure.[i]

Lack of understanding of value

The value of data (Ebiele et al., 2025) as a resource essential for good governance and innovation (OECD, 2019; Brous et al., 2020) is not well understood. Data governance can be seen as an administrative burden or a compliance exercise rather than an opportunity for value creation, reflecting the lack of a strategic approach to data in Ireland (OECD, 2022). For example, data collection can be ad-hoc with limited consideration about what it can be used for beyond its primary (often ‘quick-fix’) purpose, resulting in barriers to sharing and reuse down the line (van Panhuis et al., 2014). In addition, datasets are often siloed between and within organisations, and viewed as proprietary rather than a public resource, reflecting that the power of aggregated datasets to help strategically address societal challenges (Kitchin, 2014; OECD, 2023) is not well appreciated.

Misinterpretation or misuse of General Data Protection Regulation (GDPR)[ii]

Organisations in Ireland can be seen to be out of line with other EU member states in restrictive interpretations of GDPR, with impacts evident across all sectors (Kirwan et al., 2021). For example, in the health sector, restrictive interpretations of GDPR are recognised as a significant impediment to clinical research (Peloquin et al., 2020). The experience of Building Stories to date is that similarly restrictive interpretations apply to property data and that this creates an environment where GDPR is widely used as a convenient organisational barrier to sharing. Even when GDPR does not strictly prohibit a data transfer, its complexity and local interpretations can hinder academic data sharing (Vukovic et al., 2022).

A fear of scrutiny

Data sharing may also be viewed as an invitation for criticism as it could expose data quality issues (Kim and Cho, 2017).[iii] Most real-world datasets have data quality issues to a greater or lesser extent (Steinberg, 2016). This can lead to a resistance to the transparency and accountability needed for a data sharing culture (ODI, 2022; OECD, 2023). A view of data sharing as a risk, rather than an opportunity, is often reinforced by high profile regulatory actions. For instance, the Bank of Ireland was sanctioned by the Data Protection Commission (DPC) for sending inaccurate customer data to the Central Credit Register, resulting in 19 personal data breaches under GDPR (DPC, 2022). Fear of scrutiny can also be tied to existing public distrust of data practices (Hartman et al., 2020). We hypothesise that many Irish organisations still lack policies or infrastructure for data governance or quality assurance, and this void exacerbates staff fears about data sharing.

Capacity and resources

Public service ICT capacity in Ireland has been traditionally delivered in a standalone manner (Government of Ireland, 2023), resulting in poor interoperability between datasets from different public providers (OECD, 2019), and there may not be the technical capacity (for example, data/GIS officers trained as data stewards) in an organisation to facilitate data sharing and maintain data quality (OECD, 2023). Technical platforms for data sharing may not exist, or they can focus on internal sharing or be structured in a way that does not garner sufficient trust (van Panhuis et al., 2014). In addition, technical platforms that do exist may rely on baseline national systems that are not fit for purpose. For example, Building Stories relies on a comprehensive, interoperable and accessible building identifier system, and while it is widely assumed that Eircodes fulfil this role, they are not adequate as they are address based, not building based.[iv] Building Stories currently uses Tailte Éireann geospatial entity identifiers which capture each building in Ireland but not the subdivisions within a building (such as apartments).

Restrictions on use and reuse

Datasets are often legally owned by a company or organisation that puts restrictions on access and use. For example, Geodirectory provides proprietary datasets in a business model that does not encourage data sharing as profit is directly tied to the number of licenses distributed.[v] Proprietary data owned, or at least collected, by utility companies are recognised in the literature as key to achieving accurate predictions of vacancy (Lee et al., 2022; Flas et al., 2024) as they can have very high dataset coverage, and any observation about what that data means in terms of vacancy can be extended across all other buildings with a similar profile (Sayuda et al., 2023). Data at the granular scale of buildings and sites that is recorded over time can provide a predictive model with a huge amount of information on the profile of the building, and can be useful for managing refurbishment grants (for example, where being vacant for 2 or more years is a requirement for eligibility) or understanding the condition of a building, inter alia. Reuse of data can also be restricted to the original purpose of the dataset where consent was collected or a data processing notice is in place.[vi]

These barriers are experienced by multiple organisations, including government departments, local authorities, and national bodies that could be key data providers for our geospatial platform. Examples include:

  • Land Development Agency (LDA): Mandated to identify and develop public land for housing but denied access to some utility datasets, despite powers vested in the agency by the Land Development Agency Act (2021), reportedly due to security concerns.
  • Office of the Revenue Commissioners: Unable to access reliable vacancy data to manage the Vacant Homes Tax (Finance Act, 2022), despite wide ranging data gathering powers; reasons include poor data quality and legal restrictions on dataset reuse, including their own (e.g. Local Property Tax data).
  • Sustainable Energy Authority of Ireland (SEAI): Restricted from carrying out statutory work by data sharing restrictions; for example, their just transition mandate to target energy supports in low-income areas cannot be carried out because data to identify these areas are not deemed shareable.    
  • Uisce Éireann: Water meter data collected for leak detection and billing cannot be reused (e.g. to identify vacancy), even internally, illustrating that siloed data and quality issues persist.
  • Local Authorities: Collected vacancy data in 2023 for the Department of Housing Local Government and Heritage using an online tool that built on Geodirectory as a baseline; it transpires that the Local Authorities do not own or have access to the data they have collected and therefore cannot use it to carry out their functions.                 

These data sharing barriers, in the context of the built environment, mean that essential local and national government functions such as planning, housing and infrastructure provision are managed in a partial data vacuum, with serious implications for the effective implementation and evaluation of key policies such as Housing for All (Government of Ireland, 2021), the Climate Action Plan 2025 (Government of Ireland, 2025), and Town Centre First: A Policy Approach (Government of Ireland, 2022). For example, monitoring and (ex-ante and ex-post) evaluation of policies or fiscal initiatives is not possible because the data is just not there, or even worse it is there and is not being shared. There are also implications for the informed design of future policy relating to the built environment.

2. An enabling environment

The above barriers exist despite an enabling environment for data sharing in both the EU and Ireland. The aim of the European Data Strategy is for data “to flow freely within the EU and across sectors for the benefit of businesses, researchers and public administrations” (European Commission, 2020, online), recognising that access to data can lead to tangible benefits including better policymaking and public services.

Key legislation on data sharing at the EU scale include:

The EU Open Data Directive (European Union, 2019)    

  • Addresses data (held by national, regional and local public sector bodies) that are not subject to any privacy, proprietary or licensing restrictions.
  • As geospatial data represent high-value datasets they must be shared free of charge, in machine readable formats, and provided via APIs.
  • These datasets must be reusable for commercial and non-commercial purposes.

The EU Data Governance Directive (European Parliament and Council, 2022)

  • Addresses data protected by commercial or statistical confidentiality, intellectual property and personal data.
  • These datasets must be available for reuse under request and under certain conditions (to preserve the protected nature, guarantee integrity, and maintenance of the technical systems and processing conditions, etc.).

The EU Data Act (European Union, 2023)

  • Addresses data held by private entities which can be requested by public sector bodies to fulfil a task of public interest and be further shared with Research Organisations for compatible purposes and under certain conditions.
  • The Act encourages open data, standardised databases and interoperability.

In Ireland, the legal basis for increased data sharing for the public good is through:

The Data Sharing and Governance Act (Government of Ireland, 2019)

  • Establishes a legal framework permitting personal and business data to be shared between public bodies where necessary, proportionate and for a specified purpose.
  • A specified purpose might be verifying identity, correcting errors, reducing administrative burden, determining entitlement, improving policy delivery, or evaluating services.

Harnessing Digital: The Digital Ireland Framework (Government of Ireland, 2022)

  • Aligned with the EU Digital Compass.
  • Sets out to explore how digital technologies could enhance government processes and functions, including the secure and efficient sharing of data between Government departments and agencies to provide integrated, citizen-centric services. 
  • The framework also includes policies for ethical data use and sharing.

The National Open Data Strategy (Government of Ireland, 2023)

  • Requires public bodies to conduct audits of all datasets and publish non-personal data in open formats with open licensing
  • Provides technical and governance frameworks to enable interoperability.
  • Supports initiatives that encourage reuse and sharing of open datasets across all sectors.

Increased capacity in data governance systems and research is evident through:

ISO standards

  • Relevant include the ISO 38000 series on data governance, ISO 9000 series for quality management, ISO/IEC 25012 for Data Quality or the ISO/IEC 27000 series for IT security management.

EU data spaces

  • Digital environments designed to build trust and enable sharing of data, policies, specifications, protocols etc.

The Office of the Government Chief Information Officer (OGCIO)

  • The strategic advisor on digital government to the Government of Ireland.
  • The OGCIO is granted powers and responsibilities for public sector data sharing under the Data Sharing and Governance Act (2019).

geohive.ie

  • Serves as Ireland’s National Geospatial Data Hub.
  • Provides centralized discovery, evaluation and access to authoritative geospatial data from public sector bodies across the country.

Research infrastructure:

Two major Research Ireland (RI) grants in particular have focused on the wider social and organisational, as well as technical aspects, of data governance and data sharing: ADAPT Centre for AI Driven Digital Content Technologyand the EMPOWER Data Governance Spoke project.[vii]

In April 2025, the Irish Government Chief Information Officer, Barry Lowry, stated that “with the Data Sharing and Governance Act 2019 Ireland is committed to the most transparent means of sharing data in the EU”.[viii] Building Stories wants to pursue this vision for the built environment sector by integrating data that is already collected by state agencies.

3. EU precedents for the geospatial platform

Building Stories is ambitious, but we know that it is possible. Other EU member states have successfully implemented similar projects that are subject to the same EU Data Laws and are achieving analytical and evidence-based actions at national and local government level through data sharing.

For example, in France, the Centre Scientifique et Technique du Bâtiment (CSTB) has developed the National Building Database (BDNB) by aggregating and cross-referencing data from more than 30 databases from public bodies. These data sources come from a range of sectors and include:

  • Geospatial and Planning: Data from the National Address Database (BAN), the National Buildings Reference System (RNB), cadastral records, and building permit databases.
  • Energy and Environment: Information on energy performance (DPE), heating networks, and environmental risks.
  • Infrastructure and Building-Specifics: Details from the Permanent Equipment Database (BPE), Fibre to the Home (FTTH) data, and specific building information such as co-ownership registers (RNC) and social landlord directories (RPLS).

BDNB has generated an identity card for 32 million buildings, or over 95% of the building stock, in France. There are between 200 and 400 attributes relating to each identity card that provide a detailed history and description of the building. The data covers everything from its administrative history and structural details to construction materials, heating methods, and estimated energy performance.  

BDNB utilises a three-tiered access system (BDNB Open, BDNB Ayants Droits, BDNB Expert) to serve a broad range of users, from the general public to specialised researchers, while maintaining data security and adhering to legal requirements. The primary business model is tied to long-term analytics, and the base dataset, ‘BDNB Open’ is available for free.[ix]

CSTB has overcome the barriers to data sharing experienced in Ireland by (a) fostering a collaborative data culture where data publishers are willing to share data to support a range of public policies including on climate change, housing, planning and development; (b) ensuring GDPR is not preventing key data being made available (using different tiers of access) and; (c) developing a trusted, secure technical platform.

Other precedents have been identified in the Netherlands (Zicht op Nederland), Switzerland (SwissTopo), Brussels Capital Region (SitEx), and Barcelona (OH-B). These generally involve collaborations between Government, Local Authorities, the public sector and utilities.

4. What needs to happen?

For Building Stories to provide an equivalent platform for Ireland, the project is (inter alia):

(A) Supporting a positive data culture by:

  • building a coalition of data providers and key stakeholders to collaborate and share data for the public good;
  • fostering cooperation between institutions and researchers to support partners in making data available in compliant, machine-readable formats;
  • advocating for data sharing and raising awareness of barriers through publications and engagement with key data providers, decision makers and citizens;
  • continuing to research precedents to understand how they operate and what they are used for, and to communicate tangible demonstrators to decision makers in Ireland.

(B) Informing and supporting policy by:

  • demonstrating the challenges and opportunities of data sharing in Ireland;
  • creating a forum for different data providers from across the building adaptive cycle to discuss data governance and data regulation;
  • examining interpretations of GDPR and data restrictions on original use for specific high-value datasets that show activity at the granular scale of buildings.

(C) Building increased capacity and resources by:

  • developing a platform for data sharing between actors in the built environment sector interested in the public good;
  • building trust and ensuring compliance through Data Sharing Agreements (DSAs), Data Protection Impact Assessments (DPIAs) and metadata;
  • working directly with Local Authorities to develop a model that requires minimal training and is intuitive to use.

The data sharing challenges noted in Section 1 above impede effective action on pressing environmental and societal challenges across all sectors in Ireland, including healthcare, social services and the energy transition. By focusing on data sharing in one sector (the built environment), the Building Stories project has the potential to precipitate transformational systemic change in government processes and functions across all sectors, in line with the Programme for Government 2025 and the National Challenge Fund’s Our Tech Challenge.

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[i] It is notable that this finding is in contrast to Ireland’s ranking as one of the most mature open data (as opposed to data sharing) climates in European assessments such as the Open Data Maturity Assessment (ODM, 2024).

[ii] The General Data Protection Regulation (GDPR) (2018) sets out how personal data can be collected, used and protected (European Union, 2016). While GDPR is an EU regulation and therefore a law in all EU member states, there are areas where member states establish their own systems or rules.

[iii] For example, related to accuracy, completeness, consistency, uniqueness, timeliness, validity etc.

[iv] For example, on the UCD campus only certain postal delivery points are allocated Eircodes, not every building. Eircodes are unsuitable as building identifiers for purposes such as planning applications or property databases that need to track physical structures rather than postal addresses.

[v] Geodirectory is a joint venture between An Post and Tailte Éireann. Government organisations pay separately to access Geodirectory data, and Building Stories has found that many Local Authorities choose not to invest in it.

[vi] There is an emerging consensus showing that consent is a weak legal basis for collection of data under GDPR, especially for state services, that has been over-used in the early years of GDPR implementation (DPC, 2019).

[vii] Building Stories is an associated project of the ADAPT Centre. Building Stories held a workshop on sharing geospatial data in the EMPOWER Data Governance Community of Practice meeting in Dublin in April 2025.

[viii] Public comment at EMPOWER Community of Practice event, Dublin, 28/4/2025.

[ix] 170 attributes are available via open access.