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Co-ops Must Register with NPC

Cooperatives as Personal Information Controllers or Processors are mandated to comply with the Data Privacy Act (DPA), and are thus, required to register with the National Privacy Commission (NPC).

This was the reply of the NPC to a query by co-op blogger, Virgilio V. Maclang, on whether co-operatives are “mandated to comply with the directives provided by the Data Privacy Act, its IRR and other NPC issuances.”

Republic Act 10173 or the Data Privacy Act of 2012 (DPA) is an “Act protecting individual personal information in information and communications systems in the government and the private sector.”  The DPA also created the NPC, to implement said law. 

The NPC issued Advisory No. 2017-01 on March 14, stating that “all natural or juridical persons, or any other body in the government or private sector engaged in the processing of personal data within and outside of the Philippines” shall “register its data processing systems (under certain) conditions.

In the NPC’s Advisory Opinion No. 2017-021 addressed to Maclang dated June 14, NPC Chairman, Raymund E. Liboro, said: “Upon examination of the nature of information handled by the CDA and cooperatives, it is clear that cooperatives may be considered as personal information controllers (PICs) who collect, hold, process and use personal information of its members.”

Liboro added: “cooperatives process personal data of members, particularly with regard to the application and processing of their individual loans.  Thus . . . cooperatives are involved in the processing of personal and sensitive personal information and are thereby obliged to adhere with the provisions of the DPA.”

The Opinion cited that as far as the Credit Information System Act (RA 9510) is concerned, co-ops are “submitting entities” to the Credit Information Corporation (CIC) for credit data of borrowers.  Thus: “It is imperative to note that cooperatives process personal information of is members and employees as part of its regular operations.  The credit data or loan information mentioned is just a segment of personal information collected and stored by cooperatives.

Another Requirement of the DPA is that co-ops will have to hire or designate a “Data Protection Officer” (DPO) “who are accountable for the organization’s compliance with the law (DPA) and other relevant rules and regulations on data privacy and security.”

Liboro wrote: “Cooperatives, as PICs (or PIPs) are required to implement reasonable and appropriate organizational, physical and technical measures intended for the protection of personal information against any accidental or unlawful destruction, alteration, and disclosure, as well as against any other unlawful processing.”

For Registration requirements, Section 47 of the IRR of the DPA says “if a PIC or PIP employs at least 250 persons, registration is automatically required.”

But what if a co-op has less than 250 employees? The co-op may still be required if 1) the processing it carries out is likely to pose a risk to the rights and freedoms of the data subjects, or 2) processing is not occasional, or 3) the processing includes sensitive personal information of at least one thousand (1,000) individuals.

For registration, the co-op must submit a notarized registration form containing details on the PIC, head of the organization, and the Data Privacy Officer (DPO).  Registration can eventually be done online, thru the NPC website.

A cooperative is required to notify the NPC and the affected persons within 72 hours if personal data has been breached.

Co-op leaders may e-mail inquiries to This email address is being protected from spambots. You need JavaScript enabled to view it. , or visit the NPC website www.privacy.gov.ph for information or to download necessary forms.

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