This policy states out the commitment of Seat Lease Manila (“SLM”) to collect and process personal information and sensitive personal information in accordance with the applicable laws and regulations on data privacy, including the R.A. No. 10173 also known as, Philippine Data Privacy Act of 2012 (“DPA”) and its implementing rules and regulations (“IRR”).
The Commission refers to the National Privacy Commission (NPC).
B. Data Subject
This refers to the individual whose personal information or sensitive personal information is processed.
Incident is an event or occurrence that affects or threaten to affect the protection of data, or may compromise the confidentiality, integrity and availability of information. It includes the type of incident that would result to a personal data breach if left vulnerable and no layer of protection that have been put in place.
D. Information and Communications System
Also known as, ICT, this refers to the systems being used by a company for generating, sending, receiving, storing, or otherwise processing electronic data messages or electronic documents and includes the computer system or other similar device by which data is recorded, transmitted or stored.
E. Personal Information
Personal Information is a compilation of data collected from the individual whether recorded in a material form or not, from which the identity of an individual is apparent or can be directly ascertained by the entity holding the information and when put together with other information, it would also entail the identity of the individual.
F. Personal Information Controller
Refers to a person or company who controls the collection, holding, processing or use of personal information, including a person or company who instructs another person or company to collect, hold, process, use, and transfer or disclose personal information on his or her behalf.
The term excludes:
1. A person or company who performs such functions as instructed by another person or company; and
2. An individual who collects, hold, processes or uses personal information relating to the individual’s personal, family or household affairs.
G. Personal Information Processor
Also known as, PIP. This refers to any entity that is qualified to act as such under the Act to whom a personal information controller may outsource the processing of personal data pertaining to a data subject.
This refers to any set of operations performed by the company upon personal information including, but not limited to, the collection, recording, organize, storage, updating or modification, retrieval, consultation, use, consolidation, blocking, erasure or destruction of data.
I. Privileged Information
Refers to any and all forms of data collected from data subjects which under the Rides of Court and other pertinent laws constitute privileged communications.
J. Sensitive Personal Information
The type of personal information that reveal information
(i) about an individual’s health, education, genetic or sexual life of a person, or to any proceeding for any offense committed or alleged to have been committed by such person, the disposal of such proceedings, or the sentence of any court in such proceedings;
(ii) issued by government agencies peculiar to an individual which includes, but not limited to, social security numbers, previous or current health records, licenses or its denials, suspension or revocation, and tax returns; and
(iii) Specifically established by an executive order or an act of Congress to be kept classified.
3. How we collect personal data
SLM may be able to obtain personal data in different ways. These include where a person:
(i) Submits any application form, request, notice, or some documents;
(ii) Get in touch with us by inquiring or applies for employment;
(iii) Becomes a consultant, employee, officer, supplier, or service provider of the company;
(iv) Uses any of our communication channel (websites, platforms, and other online presence);
(v) Gets into an agreement with us, regardless if it is written or not, including employment contracts, or other contract to avail our services; or
(vi) Provides us with personal data, directly or through another person.
4. Purposes of collection and processing
SLM collect and process personal data for the purposes for which you have provided the data or made it available to the public or directly to us, and to allow us to efficiently achieve those purposes (“Subsection 4.1”), as allowed by applicable law.
The recipient of personal data that we collected include persons within SLM (including affiliates or related companies) and third parties whom we may outsourced under certain business activities in order to achieve the purposes stated in Subsection 4.1.
Let it be known that some of the transfer of data will be cross-border because some of the entities may be outside the Philippines.
We use personal data to:
(i) Comply with and exercise the rights under contracts and agreements, and the law, as may be required by our operations;
(ii) Perform and improve our services and address concerns or questions about those services;
(iii) Create and nurture relationship with the goal to continuously provide you with our service;
(iv) Obtain services for our operations and business;
(v) Conduct survey, research, feedback and other data gathering exercises;
(vi) Market, promote and share information about the company and our services;
(vii) To meet legal and regulatory requirements. We perform such other processing or disclosure that may be required under pertinent laws, rules, or regulations; and
(viii) Establish communication with you.
We may collect and process personal data from current and prospective employees of SLM. This is for the company to carry out certain departmental duty to initiate, review or terminate an employee agreement.
For job applicants, SLM may process certain personal data that are part of the requirement to commence the employment process. The collected personal data of any applicants, whether they have been hired by SLM or not, may be retained by the company for the purpose of a future selection process.
Aside from personal data, part of the employment conditions are to submit the results of certain medical examinations to SLM.
5. Consent and other lawful criteria for collecting and processing
When a person provided us with personal data through any of the interaction mentioned in Section 3, in providing or making available the personal data, the person agrees and consent to processing the personal data for the purpose stated in Section 4, and the terms and conditions applicable to the nature of the transaction between the data subject and SLM.
6. When we disclose personal information
There are circumstances where we may need to disclose or share some of the information that you have provided to us. In these cases, we ensure that personal information is disclosed on a confidential basis, and always subject to the applicable rules and regulations of the Data Privacy Act of 2012.
We will never share, rent or sell your personal information to third parties outside of the Seat Lease Manila except in circumstances where you have given your specific consent for.
In circumstances where law enforcement is involved, the disclosure will be subjected to applicable laws and regulations.
7. What your choices are
You are afforded certain rights in relation to your personal da
ta under the DPA and its corresponding IRR. We would like to ensure that we have your consent to continue to collect, record, organize, update or modify, retrieve, consult, use, consolidate, block, erasure or destruct and disclose your personal information for the purposes that we have identified.
At the same time, we want you to know that you do have choices and can object or withdraw your consent and/or edit your consent preferences at any time.
If you wish to have access to your personal information in our records, obtain a usable “portable” electronic copy of your personal information; or you think that such information we have about you is incomplete, not up-to-date, or inaccurate. You may get in touch with our Data Privacy Officer through the contact details provided below. In some instances, we may ask you to provide supporting documents or proof before we warrant any changes to your personal information. We will also send you an update regarding your request. Depending on the nature of the request, SLM may charge a reasonable fee for providing access to your personal information.
In compliance with the Data Privacy Act of 2012 and its Implementing Rules and Regulations to protect individual personal information and to uphold the rights to privacy by regulation of personal information processing, Seat Lease Manila seeks to acquire your express consent in storing and processing any personal and sensitive information you supply to our database under the following considerations:
The information to be processed includes your name, contact details, skills, educational attainment, other information that may establish your identity or other such information that you voluntarily provided to Seat Lease Manila for profiling and transaction reference.
This information will be used by Seat Lease Manila for the purpose of matching your profile with a prospective employer or client; and for use in employment or skills-development related events and activities organized by Seat Lease Manila.
Scope and Method of Processing and Data Sharing
To pursue the purpose relating to this document, Seat Lease Manila will share your information to prospective employers or clients as described above. Likewise, Seat Lease Manila may share your information with its contractors or business partners for Seat Lease Manila-organized events and activities.
Seat Lease Manila will store your information for a period of twenty-four (24) months. At the end of the period, and unless deleted or upon your instruction to delete, Seat Lease Manila may continue to store your information for a similar period.
You have the right to access, correct or delete your information at any time by logging into your account. For more information on your rights under the law, please take the time to read Sections 11-21 of the Data Privacy Act
How to contact us
About Seat Lease Manila.
Write to Us / Office Address:
11/F Wynsum Corporate Plaza, #22 F. Ortigas Road Jr. (Formerly Emerald Avenue), Ortigas Center, 1605 Pasig City, Philippines
Unit 1504, Ecotower Building, 32nd Street corner, 9th avenue Bonifacio, Global City, Taguig City, Philippines 1634 Metro Manila
20th floor, Robinsons Cybergate 3, Pioneer St, Mandaluyong, Metro Manila, Philippines 1550
9. Seat Lease Manila
About Seat Lease Manila
Seat Lease Manila (SLM) is the Philippine partner office of Anderson International, operating in different cities across the world. Its headquarters, originally in the United Kingdom, is currently in Dubai, with offices in Luton London, Australia, Manila, and Mumbai. As a whole, Anderson International specializes in helping clients with finance, accounting, payroll, back office support, customer contact centers, IT solutions and more.
The Manila branches deliver an array of comprehensive business solutions and world-class customer service. The SLM focus is on customizing standard operations to attend to each unique client needs, giving exceptional value to partners. The SLM expertise includes three core offerings: BPO Services, I.T. Solutions, and Seat Leasing.
SLM works with the vision to be the most versatile BPO provider able to adapt to the challenges any client situation presents, making use of top-quality facilities, industry knowledge, and competent management to fulfill partner needs. At the core of the SLM business are the people who provide services like no other.
SLM provides solutions that enable its clients to focus on their main business while they enjoy increased efficiencies and improved costs. Here at Seat Lease Manila, the right partnerships enable smart solutions and added values.
10. What happens when there are changes in our policy
Seat Lease Manila may update our policy and practices from time to time in order to comply with changes in the laws, rules, and regulations, government and regulatory requirements, to adapt to new technologies and protocols, to align with industry practices, or for other legitimate purposes.
You will be notified if these changes are significant and, if we are required by law, we will ensure to obtain your updated consent.