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Philippines: National Privacy Commission Resets Deadline for Renewal of Registration to 31 August 2020

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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

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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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