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Philippines: National Privacy Commission announces new online registration platform and extends validity of DPO registrations to 30 June 2021

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In brief

On 1 March 2021, the Philippine National Privacy Commission (NPC) announced its new online registration and renewal platform called “eRehistro,” which can be used by Personal Information Controllers (PICs) and Personal Information Processors (PIPs) to register, amend or renew their Data Protection Officer (DPO) and Data Processing Systems (DPS) registrations.1

In addition, the NPC extended the validity of existing DPO registrations, from 7 March 2021 to 30 June 2021, in order to give way to the launch of the eRehistro platform. According to the NPC, this extension is also meant to give PICs and PIPs ample time to prepare for the creation of their eRehistro accounts as it will now include both Phase 1: DPO and Phase 2: DPS of the registration process.

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Although the NPC has yet to issue its formal guidelines with respect to the eRehistro platform, clients are advised to prepare, review and update their compliance and registration information in preparation for both the renewal of existing DPO registrations and the registration of their DPS with the NPC. In addition to preparing for the NPC’s online registration system, the internal review and updating of DPO and DPS information will ensure compliance with the requirements of the Data Privacy Act of 2012 and its Implementing Rules and Regulations, including the designation of accountable individual(s) who will ensure the company’s compliance with the said law and the maintenance of records of data processing systems.

Clients are likewise encouraged to stay tuned to further updates from the NPC, especially with regard to the eRehistro platform. Our Firm is closely monitoring developments on this important compliance matter and will provide more updates as soon as they arise.

1 Registration with the NPC is required for PICs and PIPs processing personal data and operating within the Philippines under any of the following conditions:

  • Processing the sensitive personal information of at least 1,000 individuals
  • Employing at least 250 individuals
  • Belonging to a business/industry sector identified by the NPC (NPC Circular No. 17-01) as subject to mandatory registration
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Author

Bienvenido Marquez III is a partner in Quisumbing Torres' Intellectual Property, Data and Technology Practice Group. He also co-heads the Consumer Goods & Retail Industry Group and is a member of the Technology, Media & Telecommunications Group. He participates in initiatives of Baker & McKenzie International of which Quisumbing Torres is a member firm. He is a member of Baker McKenzie's Asia Pacific Intellectual Property Business Unit for Brand Enforcement. He is immediate Past President of the Philippine Chapter of the Licensing Executives Society International (2019-2021), and is currently co-chair of the LESI Asia Pacific. He is also a member of the Anti-Counterfeiting Committee of the International Trademarks Association (INTA). He has been appointed as member of the INTA Asia Global Advisory Council (GAC) for 2022 to 2023, making him the only Philippine representative on the council.

Bien has vast experience in handling IP enforcement litigation, trademark and patent prosecution and maintenance, copyright, data privacy, information security, IT, telecommunications, e-commerce, electronic transactions, cyber security and cybercrime. He has been consistently ranked as a leading individual for Intellectual Property and TMT in Legal 500 Asia Pacific, Chambers Asia Pacific, asialaw Leading Lawyers, Managing IP Stars, Asia IP, and World Trademark Review. He was also recognized as a Volunteer Service Awardee by INTA in 2018.

Author

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.

Author

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

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