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

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.


Contents

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 system eRehistro 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 system eRehistro 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 system eRehistro 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 system eRehistro 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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*Authored by Quisumbing Torres, a member firm of Baker & McKenzie International, a Swiss Verein. Please contact QTInfoDesk@quisumbingtorres.com for inquiries.

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