Lite Technology Business Solutions Corp. on Data Privacy Act No. 10173

This Privacy Manual is hereby adopted in compliance with Republic Act No. 10173 or the Data Privacy Act of 2012 (DPA), its Implementing Rules and Regulations, and other relevant policies, including issuances of the National Privacy Commission. This organization respects and values your data privacy rights, and makes sure that all personal data collected from you, our clients and customers, are processed in adherence to the general principles of transparency, legitimate purpose, and proportionality.

This Manual shall inform you of our data protection and security measures, and may serve as your guide in exercising your rights under the DPA.

Processing of Personal Data

 

LTBS Corp. collects the basic contact information of clients and customers, including their full name, address, email address, contact number, together with the products that they would like to purchase. The sales representative attending to customers will collect such information through accomplished order forms.

A. Definition of Terms:

 

  • A. Collection (e.g. type of data collected, mode of collection, person collecting information, etc.)

  • “Data Subject” – refers to an individual whose personal, sensitive personal or privileged information is processed by the organization. It may refer to officers, employees, consultants, and clients of LTBS Corp. 

  • “Personal Information” – refers to 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. 

  • “Processing” refers to any operation or any set of operations performed upon personal information including, but not limited to, the collection, recording, organization, storage, updating or modification, retrieval, consultation, use, consolidation, blocking, erasure or destruction of data.

 

B. Use  

  • Personal data collected shall be used by LTBS Corp. for documentation purposes, for warranty tracking vis-à-vis purchased items, and for the inventory of products.

  • C. Storage, Retention and Destruction (e.g. means of storage, security measures, form of information stored, retention period, disposal procedure, etc.)

     LTBS Corp. will ensure that personal data under its custody are protected against any accidental or unlawful destruction, alteration and disclosure as well as against any other unlawful processing. The company will implement appropriate security measures in storing collected personal information, depending on the nature of the information. All information gathered shall not be retained for a period longer than one (1) year. After one (1) year, all hard and soft copies of personal information shall be disposed and destroyed, through secured means.

    D. Access (e.g. personnel authorized to access personal data, purpose of access, mode of access, request for amendment of personal data, etc.)

    Due to the sensitive and confidential nature of the personal data under the custody of the company, only the client and the authorized representative of the company shall be allowed to access such personal data, for any purpose, except for those contrary to law, public policy, public order or morals.

    E. Disclosure and Sharing (e.g. individuals to whom personal data is shared, disclosure of policy and processes, outsourcing and subcontracting, etc.)

    All employees and personnel of the LTBS Corp. shall maintain the confidentiality and secrecy of all personal data that come to their knowledge and possession, even after resignation, termination of contract, or other contractual relations. Personal data under the custody of the company shall be disclosed only pursuant to a lawful purpose, and to authorized recipients of such data.

    Scope and Limitation

This section defines the coverage of the Manual. Given that the document is essentially an internal issuance and is meant for the use and application of the corporation’s staff or personnel, that fact should be emphasized here. 

Note that it would be useful to develop a separate Privacy Manual meant for external use or for persons who deal with the organization. Certain information may be omitted from that version, particularly those that relate to internal policies or processes that are relevant only to personnel of the LTBS Corp.

 

Security Measures

As a personal information controller or personal information processor, an organization must implement reasonable and appropriate physical, technical and organizational measures for the protection of personal data. Security measures aim to maintain the availability, integrity and confidentiality of personal data and protect them against natural dangers such as accidental loss or destruction, and human dangers such as unlawful access, fraudulent misuse, unlawful destruction, alteration and contamination. In this section, you give a general description of those measures. 

  1. LTBS Corp. Security Measures

    Every personal information controller and personal information processor must also consider the human aspect of data protection. The provisions under this section shall include the following: 

    1. Functions of the DPO, COP and/or any other responsible personnel with similar functions 

      The Data Protection Officer shall oversee the compliance of the organization with the DPA, its IRR, and other related policies, including the conduct of a Privacy Impact Assessment, implementation of security measures, security incident and data breach protocol, and the inquiry and complaints procedure.

    2. Conduct of trainings or seminars to keep personnel, especially the Data Protection Officer updated vis-à-vis developments in data privacy and security 

      • The organization shall sponsor a mandatory training on data privacy and security at least once a year. For personnel directly involved in the processing of personal data, management shall ensure their attendance and participation in relevant trainings and orientations, as often as necessary.

    3. Conduct of Privacy Impact Assessment (PIA) 

      • The corporation shall conduct a Privacy Impact Assessment (PIA) relative to all activities, projects and systems involving the processing of personal data. It may choose to outsource the conduct a PIA to a third party.

    4. Recording and documentation of activities carried out by the DPO, or the organization itself, to ensure compliance with the DPA, its IRR and other relevant policies.

      • The corporation shall sponsor a mandatory training on data privacy and security at least once a year. For personnel directly involved in the processing of personal data, management shall ensure their attendance and participation in relevant trainings and orientations, as often as necessary.

    5. Duty of Confidentiality

      • All employees will be asked to sign a Non-Disclosure Agreement. All employees with access to personal data shall operate and hold personal data under strict confidentiality if the same is not intended for public disclosure.

    6. Review of Privacy Manual

      • This Manual shall be reviewed and evaluated annually. Privacy and security policies and practices within the organization shall be updated to remain consistent with current data privacy best practices.

      • The designated Data Protection Officer is Atty. Nilo Balorio, CPA is concurrently serving as the Board Secretary of the organization.

      • Physical Security Measures

        1. Format of data to be collected

          • Personal data in the custody of the corporation may be in digital/electronic format and paper-based/physical format.

        2. Storage type and location (e.g. filing cabinets, electronic storage system, personal data room/separate room or part of an existing room)

          • All personal data being processed by the corporation shall be stored in a data room, where paper-based documents are kept in locked filing cabinets while the digital/electronic files are stored in computers provided and installed by the company.

        3. Access procedure of agency personnel

          • Only authorized personnel shall be allowed inside the data room. For this purpose, they shall each be given a duplicate of the key to the room. Other personnel may be granted access to the room upon filing of an access request form with the Data Protection Officer and the latter’s approval thereof.

        4. Monitoring and limitation of access to room or facility 

          • All personnel authorized to enter and access the data room or facility must fill out and register with the online registration platform of the organization, and a logbook placed at the entrance of the room. They shall indicate the date, time, duration and purpose of each access.

        5. Design of office space/work station 

          • The computers are positioned with considerable spaces between them to maintain privacy and protect the processing of personal data.

        6. Persons involved in processing, and their duties and responsibilities

          • Persons involved in processing shall always maintain confidentiality and integrity of personal data. They are not allowed to bring their own gadgets or storage device of any form when entering the data storage room.

        7. Modes of transfer of personal data within the organization, or to third parties 

          • Transfers of personal data via electronic mail shall use a secure email facility with encryption of the data, including any or all attachments. Facsimile technology shall not be used for transmitting documents containing personal data.

        8. Retention and disposal procedure

          • The corporation shall retain the personal data of a client for one (1) year from the data of purchase. Upon expiration of such period, all physical and electronic copies of the personal data shall be destroyed and disposed of using secure technology.

  2. This portion shall feature the procedures intended to monitor and limit access to the facility containing the personal data, including the activities therein. It shall provide for the actual design of the facility, the physical arrangement of equipment and furniture, the permissible modes of transfer, and the schedule and means of retention and disposal of data, among others. To ensure that mechanical destruction, tampering and alteration of personal data under the custody of the organization are protected from man-made disasters, power disturbances, external access, and other similar threats, provisions like the following must be included in the Manual:

  3. Technical Security Measures

    Each personal information controller and personal information processor must implement technical security measures to make sure that there are appropriate and sufficient safeguards to secure the processing of personal data, particularly the computer network in place, including encryption and authentication processes that control and limit access. They include the following, among others: 

    1. Monitoring for security breaches 

      • The corporation shall use an intrusion detection system to monitor security breaches and alert the organization of any attempt to interrupt or disturb the system.

    2. Security features of the software/s and application/s used 

      • The corporation shall first review and evaluate software applications before the installation thereof in computers and devices of the organization to ensure the compatibility of security features with overall operations.

    3. Process for regularly testing, assessment and evaluation of effectiveness of security measures 

      • The corporation shall review security policies, conduct vulnerability assessments and perform penetration testing within the company on regular schedule to be prescribed by the appropriate department or unit.

    4. Encryption, authentication process, and other technical security measures that control and limit access to personal data 

      • Each personnel with access to personal data shall verify his or her identity using a secure encrypted link and multi-level authentication.