The Irish Council for Civil Liberties and Digital Rights Ireland have written to the Data Protection Commission, seeking an investigation into the use of the Covid-19 Tracker App to store a person's EU Digital Covid Certificate.
To coincide with the implementation of the Digital Covid Certificate this week, the Covid-19 Tracker App was upgraded to allow holders of the DCC to upload it to the app if they want to.
However, concern has been expressed about whether this additional functionality is compliant with GDPR.
In their letter to Helen Dixon, Liam Herrick of the ICCL and Antóin Ó Lachtnáin of DRI argue that the upgrade would see "personal medical information and identifiers" loaded into the app, which goes "far beyond the app's original scope".
They express concern that it was not developed in accordance with European Data Protection Board guidelines.
They also take issue with the tracker app's updated "Data Protection Impact Assessment", which they claim contains a "very general, incomplete" and "incorrect description of the new functionality concerning the EU Digital Covid Certificate Wallet".
Mr Herrick and Mr Ó Lachtnáin also say that the updated DPIA lacks "any information about safety and security measures".
Last week, the Oireachtas Transport Committee heard that the Covid-19 Tracker App could be used as a "wallet" on person's smartphone to store the EU Digital Covid Certificate.
However, this added feature is not a pre-requisite to travel and it is a person's choice as to whether they want to upload the DCC to their tracker app.
People can still use a hard copy of the DCC or else store it on a device through whatever means they choose.
The Oireachtas Health Committee will receive an update tomorrow on the roll out of the EU Digital Covid Certificate from officials in the Departments of the Taoiseach, Health, Transport, Justice and the HSE.