I wrote twice before on product recalls by Toyota and the apparent legislative oversight which meant that there was no legal provision allowing Toyota to obtain records of Toyota owners from the vehicle licensing authorities.
At the time I wrote those posts, the most recent legislation on the issue was the Finance Act 1993 (Section 60) Regulations 2005. Now that Toyota are undertaking another product recall, I discover the Finance Act 1993 (Section 60) Regulations 2009, which took effect on 25 September 2009 but which, oddly, were not available on the Irish Statute Book when I wrote my posts in 2010 and 2011.
At any rate, the 2009 Regulations revoke and replace the 2005 Regulations and designate specified manufacturers and distributors as being entitled to obtain vehicle licensing records, rather than the generalised category stated in the 1996 Regulations.
So, it appears that I was mistaken, but had no way of knowing it at the time.