NPC launches online registration system for data processing systems

PASAY CITY – The National Privacy Commission (NPC) launched its online registration
system today February 3, 2023. The NPC Registration System (NPCRS) is an online platform that
provides a secure and seamless portal for both government and private organizations to register
their data processing systems with the Commission. It is the latest system developed and
implemented by the NPC to deliver services in a more effective and efficient manner.

The implementation of the NPCRS shall provide the following benefits to the Commission
and its stakeholders, specifically: ease of monitoring requests/approval of registration
applications; a secure portal for the registration monitoring unit to access registration data using
role based access control; real-time visibility in the validation of documentary requirements;
accurate collection of sectors and subsectors information; accurate verification of active/inactive
registration; efficient retrieval of contact details of the Data Protection Officer (DPO); and easy
generation of documents (e.g. Certificate of Registration, statistical reports on registered entities
(daily, monthly, yearly).

Digitalization of services

“The call for digitalization of government services by the current administration triggered
the launching of the NPCRS this February, and the Data Breach Notification Management System
(DBNMS) last April 2022. The finalization of the Circular on Registration was simultaneous with
the development of the National Privacy Commission Registration System,” Privacy
Commissioner Atty. John Henry Naga said.

The new system allows personal information controllers (PICs) and processors (PIPs),
through their Data Protection Officers (DPOs), to comply with the registration requirements
provided in the Data Privacy Act (DPA) of 2012 and its Implementing Rules and Regulations

According to Commissioner Naga, information on Data Processing Systems owned by
PICs and PIPs allows the NPC to a more efficient compliance monitoring process. “Through the
NPCRS, the data processing activities of PICs and PIPs will be effectively and efficiently
monitored. Through this system, compliance with the Data Privacy Act of 2012 will be ensured
and our endeavor to protect the personal data of every Juan and Juana will be fortified,” the
Privacy Commissioner added.

More efficient compliance monitoring

Atty. Rainier Anthony Milanes, Chief of the NPC’s Compliance and Monitoring Division,
explained that the new circular on registration aims to address the issues encountered in
implementing the old circular such as common or multiple DPOs.

“It also provides new regulations such as the requirement to display the NPC Seal of
Registration which will provide data subjects the needed assurance that entities processing their
personal data have completed the first level of DPA compliance,” Atty. Milanes added. The NPC
Seal of Registration will be issued simultaneously with the Certificate of Registration.

Section 5 of NPC Circular No. 2022-04 provides for the mandatory registration of a PIC or
PIP that employs 250 or more persons, or those processing sensitive personal information of 1,000
or more individuals, or those processing data that will likely pose a risk to the rights and freedoms
of data subjects, to register all Data Processing Systems

Atty. Milanes stated that adherence to the data privacy principles of transparency,
legitimate purpose, and proportionality were one of the cornerstones in developing the NPCRS.
“The registration system was developed using Privacy by Design and Development, Security,
and Operations (DevSecOps). Privacy Impact Assessments were conducted during planning,
before implementing changes concerning personal data processing, and before the system goes
live,” he explained.

The development of NPCRS is parallel with the finalization of NPC Circular No. 2022-04
published last December 27, 2022. The Circular on the Registration of Personal Data Processing
System, Notification Regarding Automated Decision-Making or Profiling, Designation of Data
Protection Officer, and the National Privacy Commission Seal of Registration became effective on
January 11, 2023.

Access the Circular here: Link

Register using the NPCRS here: Link