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Philippines: Latest eRehistro updates from the National Privacy Commission

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In brief

The Philippine National Privacy Commission (NPC) released on its official Facebook page two announcements regarding the soon-to-be launched eRehistro system. The NPC announced: (1) the system’s process and requirements for account creation, data processing systems (DPS) inventory; and (2) the amendment of registration information for covered personal information controllers (PIC) and personal information processors (PIP).

Recommended actions

While we monitor further NPC announcements on the launch date and formal guidelines of eRehistro, we continue to encourage covered PICs and PIPs to commence preparing, reviewing and updating their compliance and registration information for both Phase 1: Data Protection Officer (DPO) renewal of registration, and Phase 2: Data Processing System (DPS) registration.

We also recommend that clients keep themselves updated of further developments from the NPC, either through the NPC’s website or its social media channels. For additional guidance on the various announcements made by the NPC on the eRehistro system, you may refer to our previous alerts in the following links:

Our firm will provide more updates in due course.

In more detail

Overview of eRehistro account creation and DPS registration

The creation of an eRehistro account involves a two-step process: (1) uploading a duly accomplished and notarized eRehistro form; and (2) registering all of the PIC or PIP’s DPS — both of which should be done once the eRehistro system is available to the public.

In the meantime, the NPC recommends conducting a DPS inventory by completing the following information:

  • name of the DPS
  • type of DPS (i.e., paper-based, manual, electronic/automatic, or both)
  • purpose(s) of the DPS
  • whether the registrant is a PIC or PIP
  • whether the DPS involves automated decision-making
  • whether data processing is outsourced or subcontracted
  • categories of the data subject and personal data involved
  • number of staff in the PIC or PIP’s data protection office
  • number of individuals to whom the personal data will be or may be disclosed
  • whether personal data will be transferred outside the Philippines

Amendment of registration information

Amendments or updates to a PIC or PIP’s registration information may likewise be made using the eRehistro system. Under current NPC regulations, amendments or updates to a covered PIC or PIP’s registration information should be made within two (2) months from the date of effectivity of the change.1

Specifically, an amendment or updating of registration information is required if it involves any of the following information:

  • name or contact details of the PIC or PIP
  • name or contact details of the head of the agency or organization
  • name or contact details of the DPO

Prior to the availability of the eRehistro system, the covered PIC or PIP should send by email any amendment or update on its registration information to [email protected], which submission will be validated by the NPC within three to seven days.

1 See Section 15, NPC Circular No. 17-01.

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Author

Bienvenido Marquez III is a partner and head of 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 Steering Committee and the 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). 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

Author

Jose Angelo Tiglao is an associate with the Intellectual Property, Data and Technology Practice Group as well as the Technology, Media & Telecommunications Industry Group at Quisumbing Torres. He ranked sixth in his batch upon graduation from De La Salle University College of Law, where he also received the Most Outstanding Thesis award for his thesis on social media and fake news regulation in the Philippines. He is both a Certified Information Privacy Professional (Europe) and a Certified Information Privacy Manager by the International Association of Privacy Professionals (IAPP) and is currently the Assistant Corporate Secretary of the Licensing Executives Society Philippines.

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