National Privacy Commission

How it works

Watch NPC issuances for registration and breach-notice timing. Your EOR may be a processor; you may still be a controller of customer data. A complaint can name both. Do not wait for a U.S. state law to teach you the local one. For a U.S. company hiring one Filipino teammate, write this into the brief, the employment contract, and the peso payroll file before the start date. Slack habits do not override the Labor Code, BIR, or NPC. If the local employer of record holds the paper, they run the statutory step; you still owe a clean operating definition so the seat does not fail in week three. Put a number on the example when you budget loaded cost, because a nameless allowance always returns as a December surprise or a missed SLA.

Example: lost laptop with inbox cached. Notice path runs through your DPA/NPC analysis the same week, not after a journalist calls.

How it differs

RA 10173 is the statute. Data sharing agreement is a contract tool. PIC is the role.

Common errors

Filing nothing because ‘we’re small.’ Size exemptions are not a complete shield.

In practice

Treat National Privacy Commission as a week-one operating object. Name the system of record, the device, and who can still log in on the last day. If the answer is a shared password, stop. Write an owner - founder, local employer, or worker - and a date you will look at it again: first cutoff, first holiday, or first miss. If nobody can show a contract clause, a payslip line, a calendar block, or a checklist box, you do not have national privacy commission yet. You have a conversation. Convert the conversation before the person starts, while changing the deal still costs a paragraph rather than a resignation. Re-read the worked example above against the actual hire in front of you. If the numbers in that example cannot be swapped for this seat’s pesos, hours, and start date, the brief is still unfinished.