Personal information controller

How it works

The EOR controls employee data for payroll. You control customer data in the inbox. Two controllers can exist. Name them. Processors follow instructions. If you tell the EA to scrape a customer list into a sheet, that instruction is yours. 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: EOR files SSS using employee addresses. You file nothing with NPC about that employee file - the EOR might. You still own the customer CRM the EA uses.

How it differs

Data sharing agreement sets the rules between parties. Processor language belongs in the service agreement.

Common errors

Assuming the EOR absorbed your customer-data duties.

In practice

Treat Personal information controller 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 personal information controller 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.