ASAHI NETWORKS PHILS., INC.
PRIVACY POLICYc.
d.

A. PRIVACY STATEMENT
As a globally-recognized organization, Asahi Networks
Phils., Inc. (“Asahi”) takes the privacy rights of individuals
seriously. As such, we always protect and secure the personal
data we collect and process in compliance with Republic Act No.
10173, otherwise known as the Data Privacy Act of 2012 (“DataPrivacy Act”), its corresponding Implementing Rules andProcedures (“IRR”), and the existing Memorandum Circulars andAdvisories issued by the National Privacy Commission (“NPC”).
B. SCOPE
1.

This document provides our policy in relation to our personal
data processing activities in accordance the Data Privacy Act,its IRR, and all related issuances of the NPC.

2.

We may amend and/or modify this policy from time to time
to reflect changes in how we process your data and tocomply with developments in data privacy regulation subject
to reasonable notice and consent, where applicable.

3.

This policy applies to all of Asahi’s personal data processing
activities including, but not limited to, the collection, use,
storage, sharing and disposal of all personal data about ouremployees, subcontractors, and individuals with whom wework with as representatives of our affiliates, partners,
suppliers and customers.

e.

We also collect and process the personal data of ouremployees for Administrative and Human Resource Development
purposes as well as in compliance to applicable laws, rules andregulations covering government employees, including, but notlimited to:
a.
b.
c.
d.

e.
f.
g.

C. COLLECTION AND USE OF PERSONAL DATA1.

SCOPE AND PURPOSE OF PERSONAL DATA PROCESSING

As a business process outsourcing company, we provide
payroll management, corporate registration, and regulatorycompliance and reporting services for various corporate clients.
In the provision of such services, we receive and process personal
data about our clients’ employees, including their directors,
officers, and/or agents. We process such data strictly for
purposes of providing outsourced services and in accordancewith the instructions of our clients. We also ensure that the data
we receive from clients bear the consent of the data subjects
from such data is originally collected. Some of the personal data
we process include:a.
b.

Employee name, address, tax identification number andbirthdate;
Name of incorporator, address, nationality, passportdetails, and equity holdings;

Name of directors, address, nationality, passport details
and equity holdings;
Name of officers, position, address, nationality,
government identification, and tax identification number;andName of shareholders, nationality, government
identification, and tax identification number.

h.

2.

Maintenance of employee database for Identity
verification procedures, internal security and accessprotocols, and regulatory compliance;
Pre-qualification and post-qualification assessments
Processing of various contracts, certificates anddocuments evidencing employment/engagement with
ANP;
Processing and grant of employment compensation andcorporate benefits, including payroll and loan
management, Health Maintenance Organization (“HMO”)
and corporate loans;
Development and implementation of employee learning
training, and welfare programs, including workplace
performance and compatibility testing;
Maintenance of employee performance metrics as well as
attendance records;
Compliancewithgovernment
andregulatory
requirements such as Bureau of Internal Revenue (“BIR”),
Department of Labor and Employment (“DOLE”), SSS,
PhilHealth, and Pag-IBIG reportorial requirements,
business, and occupational permits, and licenses as well asother National Government and Local Government Unit
(LGU) compliance requirements; andFor the protection of lawful rights and interests of theorganization in internal quasi-judicial and judicial
proceedings, or the establishment, exercise or defense oflegal claims against prospectively malfeasant employees.
HOW WE COLLECT AND PROCESS PERSONAL DATA

We collect both electronic and paper-based personal data
directly from our employees and clients through physical forms
as well as through our company-licensed work productivity
software and e-mail platform.
D. THE RIGHTS OF DATA SUBJECTS
Asahi fully recognizes that the data subjects involved in
our personal data processing activities are accorded the following
privacy rights:
Page 1 of 3

•They have the right to demand and be informed of thedetails about the type of personal data, the purpose of processing,and how they are being processed by Asahi, including its sources,
recipients, methods, disclosures to third parties and theiridentities, automated processes, manner of storage, period ofretention, manner of disposal and any changes to such processing
activities before the same is undertaken.
•

Right to object

They have the right to reject further processing of theirpersonal data, including the right to suspend, withdraw, andremove their personal data in possession of ASAHI which arefalsely collected or unlawfully processed.
E.
to:Ensure that such personal data are proportional, necessary
and limited to the declared, specified and legitimate
purpose of the processing;7.

Ensure that such personal data are retained for only alimited period or until the lawful purpose of the processing
has been achieved;

8.

Ensure that such personal data are destroyed or disposed ofin a secure manner;

9.

Ensure that they have the facility to lodge complaints to the
IBP relating to any violations to their rights as data subjects
and that such complaints are adequately and timely
addressed.

F.

DATA PROTECTION OFFICER

Right to dispute

They have the right to dispute inaccuracy or error inpersonal data processed by Asahi.
•

6.

Right to access

They have the right to have reasonable access to theirpersonal data, sensitive or otherwise, upon demand. They havethe right to review and amend their personal data processed by
the Asahi in case there are errors.
•manner and purpose by which they are processed, withdraw
consent where applicable, and to suspend, withdraw, block,destroy, or remove any unnecessary, falsely collected or
unlawfully processed personal data;

Right to be informed

POLICY ON THE COLLECTION AND USE OF PERSONAL DATA

Asahi takes data protection seriously and has appointed a
Data Protection Officer (“DPO”) tasked to monitor compliancewith any and all applicable foreign and/or local data privacy laws,
rules, and regulations.
Should you have any concerns regarding our privacy
practices and policies, you may reach our DPO through thefollowing contact information:

In relation to the rights of Data Subjects, it is Asahi’s policy
E-mailOffice Address

Data Privacy Officer
stanaka@asahinet.asia
6th Floor, Maripola Bldg., 109 Perea
St., Legaspi Village, 1229 Makati
City, Philippines

1.

Ensure that our employees and our clients’ employees,
incorporators, directors and/or officers are fully andadequately informed of their privacy rights;

2.

Ensure that they are fully and adequately informed of allprocessing activities performed by the Asahi with respect totheir personal data;

G. PERSONAL DATA SECURITY POLICY

3.

Ensure that their consent is obtained where necessary prior
to the processing of their personal data or within reasonable
time thereafter. Where consent is not required, we will,
nonetheless, endeavor to fully and adequately inform ourmembers of the bases of such processing;

We ensure that all personal data stored by theorganization, whether in manual or electronic form, are kept insecure areas with appropriate physical, technical andorganizational security measures and accessed in accordancewith the data security standards of the organization.

4.

Ensure that they have the facility to reasonably access,review and amend their personal data and to request forcopies thereof in a commonly portable format;

5.

Ensure that they have the facility to: dispute any inaccuracy
or error in their personal data, object to any changes in the

We adopt appropriate data collection, storage andprocessing practices and security measures to protect against
unauthorized access, alteration, disclosure or destruction of yourpersonal data, username, password, transaction information anddata stored and processed by the IBP, including appropriate

1.

STORAGE OF AND ACCESS TO PERSONAL DATA

Page 2 of 3

encryption tools, firewalls and security incident management
systems and procedures.

Breaches shall be subject to notification and remediation
requirements.

Transfers of personal data internally and externally shall
only be made in accordance with strict security protocols andunder modes of transfer compliant to the requirements andstandards of the Data Privacy Act.

5.

We also ensure that only authorized individuals within theorganization shall be allowed to process personal data.
2.

RETENTION AND DISPOSAL OF PERSONAL DATAHUMAN RESOURCE POLICY

Asahi requires its employees to undergo periodic andmandatory training privacy and data protection in general and inareas reflecting job-specific content. Likewise, it will ensure that
all employees, representatives, and agents exposed to personal
data pursuant to their function are adequately bound by strict
confidentiality.

We ensure that personal data is only retained for a limited
period or until the lawful and legitimate purpose of theprocessing is achieved. To that effect, we have establishedprocedures for securely disposing files that contain personal data
whether the same is stored on paper, film, optical or magnetic
media, personal data stored offsite, and computer equipment.
3.

MANAGEMENT OF THIRD-PARTY RISKSa.

PERSONAL INFORMATION PROCESSORS

Where any processing of personal data is outsourced toa third-party processor, Asahi will make sure that such third party
shall be covered by the appropriate contracts that will enforce
adequate data security standards under terms and conditions
compliant with the requirements of both local and/or foreign law,where necessary.
b. PERSONAL INFORMATION CONTROLLERS
Asahi shall ensure that any disclosures or transfers of
personal data to controllers shall be governed by legallycompliant data sharing agreements and in accordance with therights of data subjects. Data subjects shall be duly informed andconsent from them obtained, where applicable, before such data
sharing activities are performed.
Apart from this, we do not sell or disclose your personal
data to third parties unless you allow us to; when we are legallyrequired to do so; or if such action is necessary to protect, defend
and/or enforce our rights, property or the personal safety of ourmembers and other individuals.
4.

PERSONAL DATA BREACH

Personal Data Breach refers to a breach of security
leading to the accidental or unlawful destruction, loss, alteration,
unauthorized disclosure of, or access to, personal datatransmitted, stored, or otherwise processed. Personal Data
Page 3 of 3