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Sensitive personal information
Sensitive personal information is the DPA’s hotter class - things like health, government IDs, financial data, and other listed categories - which need tighter purpose and security.
How it works
An EA who sees passports, medical claims, or card numbers is in this water. Minimize. Mask. Do not keep local copies. NPC cares more here than about a public business email. 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: support seat handles medical-device tickets with patient names. Policy: no local CSV, no screenshots in personal chat.
How it differs
Ordinary personal information is still covered. Customer PII on a home desk is the physical risk.
Common errors
Storing ID scans in a shared Slack channel.
In practice
Treat Sensitive personal information 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 sensitive personal information 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.