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Philippines: Understanding the key changes to be introduced by the National Privacy Commission’s eRehistro system

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In brief

The Philippine National Privacy Commission (NPC) highlighted in its official Facebook page the main distinctions between the current registration process and the upcoming eRehistro system, specifically with regard to (1) the registration form, (2) the registration of data processing systems (DPS), (3) the certificate of registration, and (4) addressing deficiencies and concerns.

Recommended actions

As we continue to await further NPC announcements as well as its formal guidelines on the eRehistro system, we recommend that personal information controllers (PICs) and personal information processors (PIPs) commence preparations for complying with both Phase 1: Data Protection Officer (DPO) renewal of registration and Phase 2: Data Processing System (DPS) registration.

For additional information, please feel free to access our previous alerts on the eRehistro system through the following links:

Our firm will provide more updates in due course.

In more detail

Registration form

Current systemeRehistro system
The DPO registration form is currently available for download on the NPC’s official website, which is to be filled out electronically. Thereafter, a scanned copy of the executed and notarized registration form is sent by email to registration@privacy.gov.ph, together with the other supporting documents.Instead of downloading a separate form from the NPC’s official website, all the required information will only have to be encoded in the eRehistro Application Form. Once completed, the form must be downloaded and notarized, and thereafter, uploaded to the eRehistro system.

Registration of data processing systems (DPS)

Current systemeRehistro system
There is a separate DPS registration process, but it has been suspended indefinitely by the NPC.Since both the Phase 1: DPO and Phase 2: DPS registration processes are integrated in the eRehistro system, the DPS must be registered using this system.

Certificate of registration

Current systemeRehistro system
Currently, the NPC sends a digital copy of the PIC or PIP’s Certificate of Registration to the DPO’s registered email address.The PIC or PIP will receive a notification from the NPC once the digital copy of its Certificate of Registration is available for download using the eRehistro system.
The NPC will only send the Certificate of Registration of the PIC or PIP once, unless a new copy is requested.There is no limit to the number of times the PIC or PIP may download its Certificate of Registration using the eRehistro system.

Deficiencies and concerns

Current systemeRehistro system
In case of any deficiency or concern raised by the Commission, the NPC will send the PIC or PIP a list of matters to be complied with. This list is sent to the registered DPO’s email address.Once the additional documentary requirements have been prepared, scanned copies must be sent by email to the NPC at registration@privacy.gov.ph.If deficiencies are identified in the submitted requirements, the NPC will send the PIC or PIP a list of matters to be complied with, which the PIC or PIP may readily upload to the eRehistro system.

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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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