The Philippine Data Privacy Act: Phase 1 Registration

Under Republic Act No. 10173 or the Philippine Data Privacy Act, companies which control or process (i.e. collect, record, organize, store, consolidate, modify) personal information (i.e. any information, whether recorded in a material form or not, from which the identity of an individual is apparent or can be reasonably and directly ascertained by the entity holding the information, or when put together with other information would directly and certainly identify an individual) are required to register with the National Privacy Commission under the following circumstances:

  1. when they employ more than two hundred and fifty (250) persons; or

  2. when they have less than 250 employees but:

  3. their processing of personal information is likely to pose a risk to the rights and freedoms of data subjects;

  4. they process personal data more than once a year; or

  5. they process sensitive personal information of at least one thousands (1,000) individuals.

Sensitive personal information refers to any information: (a) about an individual’s race, ethnic origin, marital status, age, color, and religious, philosophical or political affiliations; (b) about an individual’s health, education, genetic or sexual life of a person, or to any proceeding for any offense committed or alleged to have been committed by such individual, the disposal of such proceedings, or the sentence of any court in such proceedings; (c) issued by government agencies peculiar to an individual which includes, but is not limited to, social security numbers, previous or current health records, licenses or its denials, suspension or revocation, and tax returns; and (b) specifically established by an executive order or an act of Congress to be kept classified.

The deadline for the Phase 1 registration of companies covered by the Philippine Data Privacy Act is on 9 September 2017.

This article does not constitute and is not intended to be legal advice. If you have any question or need any assistance, please feel free to send us an email at

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