Philippines: National Privacy Commission launches new online system for data breach notifications and Annual Security Incident Reports

The Philippine National Privacy Commission now requires personal information controllers and personal information processors to use the Data Breach Notification Management System when submitting personal data breach notifications and Annual Security Incident Reports (ASIRs). ASIRs for 2018 to 2021 are due on 30 June 2022.

In brief

On 20 April 2022, the Philippine National Privacy Commission ("NPC") announced the launch of its new Data Breach Notification Management System ("DBNMS"), an online reporting system that must be used by personal information controllers ("PICs") and personal information processors ("PIPs") to submit personal data breach notifications and Annual Security Incident Reports ("ASIRs") to the NPC.

The DBNMS is available here, and the NPC published a video tutorial on the use of the system. The chief of the NPC's Compliance and Monitoring Division announced during the DBNMS launch that beginning 20 April 2022, PICs should use only the DBNMS for submitting personal data breach notifications to the NPC. This means that data breach notifications submitted to the NPC via email, personal filing or courier/postal delivery, will no longer be accepted. ASIRs covering the years 2018 to 2021 should be submitted to the NPC via the DBNMS on or before 30 June 2022.


Contents

Recommended Actions

Although the NPC has yet to issue its formal and written guidelines with respect to the use of DBNMS, clients are urged to prepare their respective Annual Security Incident Reports (covering the years 2018 to 2021) in order to ensure its timely submission to the NPC by 30 June 2022.

Failure to submit the Annual Security Incident Report is a violation of the issuances of the NPC, which may be taken into consideration by the Commission on whether a PIC or PIP may be subject to a compliance check by the NPC. The NPC's evaluation or examination of a PIC or PIP's compliance with the requirements of the Philippine Data Privacy Act of 2012, its Implementing Rules and Regulations, and NPC issuances include privacy sweeps, documents submission and on-site visits.

Clients are likewise encouraged to view the NPC's video tutorial on the use of DBNMS and sign up with the system here.

Our firm is closely monitoring further developments on this important compliance matter, and we will provide updates as soon as they arise.

 

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Contact Information
Bienvenido Marquez III
Partner and Head of Intellectual Property, Data & Technology
Quisumbing Torres, Manila
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bienvenido.marquez@quisumbingtorres.com
Divina Pastora Ilas-Panganiban, CIPM
Partner, Intellectual Property, Data & Technology
Quisumbing Torres, Manila
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divina.ilas-panganiban@quisumbingtorres.com
Neonette Pascual, CIPP/E, CIPM, CIPT
Senior Associate, Intellectual Property, Data & Technology
Quisumbing Torres, Manila
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neonette.pascual@quisumbingtorres.com

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