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On 6 March 2020, the National Privacy Commission (NPC) announced that the validity of current registration of personal information controllers (PICs) and processors (PIPs)1 is extended from 8 March 2020 to 31 August 2020. The extension is to make way for the launching of an automated registration system by July 2020.

Applications for renewal of registration using the automated system will be accepted by the NPC beginning 1 July 2020.

The extension only covers PICs and PIPs which have previously completed at least Phase 1 of the NPC registration in accordance with NPC Circular No. 17-01. Phase I involves the submission to the NPC of the accomplished DPO registration form together with all supporting documents. It is completed upon the registrant’s receipt from the NPC of a digital certificate of registration.

For covered PICs and PIPs which have yet to begin the process of registration, they are required to immediately register their DPO with the NPC2 to avoid possible sanctions.

Actions to Consider

Clients covered by the registration requirement are advised to ensure that they have completed their DPO registration with the NPC to avoid sanctions and avail of the extended validity of their registration.

The automated NPC registration system would certainly result in a more convenient and seamless registration process. Clients are encouraged to promptly renew their registration with the NPC once the automated system becomes available.

1 Registration is required for PICs or PIPs meeting any one of the following criteria:

  • Processing the sensitive personal information of at least one thousand (1,000) individuals;
  • Employing at least two hundred fifty (250) persons; or
  • If belonging to the business/industry sector identified by the NPC (NPC Circular 17-01) as subject of mandatory registration.

2 Instructions for registering DPOs


Bienvenido Marquez III is a partner and head of Quisumbing Torres' Intellectual Property Practice Group and Information Technology & Communications Industry Group. He is also a member of Baker McKenzie's Asia Pacific Intellectual Property Steering Committee. He is experienced in handling IP enforcement litigation, trademark and patent prosecution and maintenance, copyright, data privacy, information security, IT, telecommunications, e-commerce, electronic transactions and cybercrime matters. He also counsels clients on compliance with consumer product laws, including packaging, labeling and regulatory requirements for food, drugs and devices and cosmetics, and conducts administrative litigation relating to the same.


Divina Ilas-Panganiban is a partner in Quisumbing Torres’ Intellectual Property and Information Technology & Communications practices. She has 15 years of experience in the fields of intellectual property law, commercial law and litigation. She currently serves as the Vice-President and Director of the Philippine Chapter of Licensing Executives Society International. Ms. Panganiban often serves as resource speaker in local and international seminars on IP and IT laws.


Neonette Pascual is an associate in Quisumbing Torres' Intellectual Property Practice Group and Information Technology & Communications Industry Group. She has nine years of experience handling matters involving contracts, incorporation, compliance, litigation, and corporate housekeeping. Prior to joining Quisumbing Torres, Ms. Pascual worked as legal counsel for the Philippine offices of two global outsourcing services companies