IPA Philippines Privacy Notice

Submitted by cvu@poverty-ac… on Mon, 10/16/2023 - 11:50
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IPA Philippines
Privacy Notice

 

Republic of the Philippines National Privacy Commission - Certificate of Registration


Our Commitment


Innovations for Poverty Action is an international research and policy nonprofit that discovers and advances what works to improve the lives of people living in poverty. Since 2002, IPA’s Philippine Country Office has partnered with government agencies, NGOs and the private sector, to study innovative solutions in various sectors. Our mission is to discover truly effective solutions to global poverty, and in service of that mission, we combine rigorous research practice with an eye for arming policymakers with actionable, high-quality evidence.

IPA determines the means and methods of its data collection and processing activities for its own purposes and acts as a processor for the research projects it conducts for its partners. We at IPA are committed to upholding, respecting, and valuing your data privacy rights and protecting the confidentiality, integrity and availability of your personal data through our formulation and implementation of a comprehensive and risk-based data privacy program.

This Privacy Notice


This Privacy Notice is intended to inform you of how IPA Philippines (IPA) collects, uses, stores, discloses and protects your personal information and sensitive personal information in its operations in the Philippines.

The terms “personal data,” “personal information,” “sensitive personal information,” “processing of personal data,” and other related terminologies in this Privacy Notice are used in the same context as they are found in the Data Privacy Act of 2012 (DPA) and all its related issuances (“Data Privacy Laws”). Please refer to the following definition:

  • Personal data pertains to both personal information and sensitive personal information.
  • Personal information is any information or set of information that can be used to identify an individual or can reasonably and directly identify an individual but are not considered as sensitive personal information.
  • Sensitive Personal Information is any information about individual’s race, ethnic origin, marital status, age, color, and religious, philosophical or political affiliations; individual’s health or education; about any criminal, civil or administrative proceeding of an individual; unique government issued identifiers; and those established by law as classified.
  • Processing of Personal Data refers to any operation or any set of operations performed upon personal data including, but not limited to, the collection, use, storage, disclosure or disposal.

Our Basis for Processing Your Personal Data


In general, we may process your personal data based on any of the following basis, as applicable:

  1. your consent, in such case, you may withdraw your consent to the processing of your personal data anytime by sending your request to our Data Protection Officer with contact details provided below;
  2. the existence of our legitimate business interest;
  3. our need to comply with legal obligation or as required by existing laws and regulations; and
  4. our need to protect our lawful rights and interests or establish, exercise or defend our legal claims in court.

For our research projects, we process your personal data based on:

  1. your consent, in such case, you may withdraw your consent to the processing of your personal data anytime by sending your request to our Data Protection Officer with contact details provided below; or
  2. our research exemption as provided under the DPA, only if we are able to establish that the research project is necessary to achieve the specific purpose, the research is intended for a public benefit and is subject to the requirements of applicable laws, regulations or ethical standards.

Personal Data We Collect


IPA may collect the following personal data from you:

  1. When you visit our website (poverty-action.org), subscribe to the IPA newsletter, fill out a form, or make a donation:
    1. Name, email address, mailing address, phone number, and credit card information.
    2. Other information that may be collected from your interaction and use of our website.
  2. When you become a respondent to any of our research projects and you directly provide your personal data to us or when you provide your personal data to third parties (our sponsors, partners, vendors) and you authorized them to share your personal data to us:
    1. Personal Information of yourself and/ or members of your household  such as name, address, GPS location and phone number depending on the purpose of the particular project.
    2. Sensitive Personal Information of yourself and/or members of your household such as age, sex, marital status, housing condition, health status, educational background, or employment status, depending on the purpose of the particular research project.

Use of Your Personal Data


We collect and use your personal data for the following purposes:

  1. To provide you with information on IPA’s services per your request and respond to your queries, comments or feedback.
  2. To carry out our obligations arising from any contracts that we entered.
  3. To gather the necessary information required by any of our research projects, by law or existing contracts.
  4. To use for purposes that would be necessary or beneficial to administer your transactions with us.
  5. To be used in pursuit of our research objectives and policy works where it will be analyzed and used to generate evidence and build capacity to use evidence to inform policy.
  6. To be used to advanced research methods and/or adhere to data quality standards and protocols.
  7. To send you information and updates pertaining to your donation and respond to your inquiries, questions, and/or other requests. If you decide to opt-in to our mailing list, you will receive emails that may include company news, updates, etc. If at any time you would like to unsubscribe from receiving future emails, we include detailed unsubscribe instructions at the bottom of each email or you may contact our DPO via the email below.

The personal data we collected from you will be used only for the reasons stated above and for purposes related to those stated. We will never sell your information nor disclose it to any other parties for commercial purposes.

Disclosure of Your Personal Data


We may disclose and share your personal data to the following:

  1. Regulatory government agencies to comply with our obligations to submit reports and records under relevant issuances and contracts.
  2. Third-party vendors or service providers engaged by IPA who, in providing their service to us, may collect and process your personal data. These service providers will only process your personal data upon our instructions.
  3. To our research project sponsors or partners or entities who commissioned us to conduct the research project. We usually only disclose de-identified data, where you will no longer be identifiable. However, there are instances that we have to disclose personal data in their raw form, where you will be identifiable, in such a case, you will be notified before we collect your personal data, and we will implement security measures to ensure the safety of the personal data we disclose.

We ensure the personal data being shared to the above listed recipients are not excessive in relation to the declared and specified purpose. Further, we will only share your personal data when allowed by the Data Privacy Laws, or upon obtaining your consent, when required.

Our Storage and Retention Period


Storage


Your personal data in electronic form is securely stored in our cloud database. The physical records on the other hand are securely stored and kept within the office premises in locked filing cabinets and storage rooms.

Retention


Your personal data are retained only for a period necessary for us to fulfill the purposes for which they were collected, such as to fulfill the purpose of a particular research project or after our researchers have done their analysis, to execute the terms and conditions of our contracts, to fulfill IPA’s legitimate interests or as long as required by applicable laws, rules or regulation.

Disposal


After expiry of the retention period or when you withdraw your consent (if applicable), we will securely dispose your personal data in accordance with our Record Retention Policy such as shredding the physical records and deletion of the electronic data or any other secure disposal methods allowed by relevant regulations.

For our research projects, upon completion of the study and analysis, our researchers implement de-identification techniques such as anonymization where you will no longer be identifiable.

Your Data Security


Security threats are now a question of when rather than an “if”. A data breach may happen when there is a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored, or otherwise processed.

IPA implements reasonable and appropriate technical, physical and organizational security measures to protect personal data from these threats through the following measures:

  1. We implement data privacy and protection policies to provide standards and guidelines on how we handle personal data we process.
  2. We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of your personal information, username, password, transaction information and data stored on our Site.
  3. We ensure that our employees, agents, vendors and anyone who is involved in the processing of your personal data are trained to properly handle your data and are under strict confidentiality.

Your Data Subject Rights


Under the DPA, you have the following rights:

  • Right to be informed. You have the right to be informed of how your data is collected, used, stored, shared and disposed before you disclose your information to us.
     
  • Right to object. You have the right to object from giving consent to our processing of your personal data or withdrawing the same thereafter in case our processing is based on your consent.
     
  • Right of access. You have the right to ask for information on how we use, store, disclose or protect your personal data.
     
  • Right to rectification. You have the right to ask us to modify or correct your personal data when the same is inaccurate, outdated, false or incomplete.
     
  • Right to erasure or blocking. You have the right to request us to delete your personal data in some instances or have us stop using your data for specific purpose/s.
     
  • Right to data portability. You have the right to ask that we transfer your personal data to another organization, or to you, in certain circumstances.
     
  • Right to file a complaint and ask for damages. If you think that your rights as a data subject have been violated, or if you sustained damages due to any inaccurate, incomplete, outdated, false, unlawfully obtained or unauthorized use of your personal information, you may escalate your concern to our Data Protection Officer so we can assist you. In case we failed to resolve your complaint or in you are unsatisfied with the way we handle the matter, you have the right to file a complaint with the National Privacy Commission (NPC).

How to exercise your data privacy rights?


If you would like to exercise any of the mentioned rights, you may fill out this Data Subject Request Form and send the same via email to dataprotection_ph@poverty-action.org.

If you have privacy concerns, believe that your personal data has been breached or your rights as a data subject have been violated, you may contact our Data Protection Officer:

Data Protection Officer
Unit B, 7th Floor Belvedere Tower, San Miguel Avenue, Ortigas Center, Pasig City, 1605, Philippines
dataprotection_ph@poverty-action.org
(02) 871-46595

Changes to This Privacy Notice


This privacy notice is under regular review to make sure it is up to date and accurate. Innovations for Poverty Action has the discretion to update this privacy notice at any time. When we do, we will revise the updated date at the bottom of this page. You acknowledge and agree that it is your responsibility to review this privacy policy periodically and become aware of modifications.

This notice, and any updates, amendments or supplements thereto is available here in our official website. Any changes to this privacy notice shall be posted here.

Version No.: 1.0
Effectivity Date: October 11, 2023