1.   Introduction

This policy states out the commitment of Anderson Group BPO, Inc. (“AGBI”) to collect and process personal information and sensitive personal information in accordance with the applicable laws and regulations on data privacy, including the R.A. No. 10173 also known as, Philippine Data Privacy Act of 2012 (“DPA”) and its implementing rules and regulations (“IRR”).

2.   Definitions

A. Commission

The Commission refers to the National Privacy Commission (NPC).

B. Data Subject

This refers to the individual whose personal information or sensitive personal information is processed.

C. Incident

Incident is an event or occurrence that affects or threaten to affect the protection of data, or may compromise the confidentiality, integrity and availability of information. It includes the type of incident that would result to a personal data breach if left vulnerable and no layer of protection that have been put in place.

D. Information and Communications System

Also known as, ICT, this refers to the systems being used by a company for generating, sending, receiving, storing, or otherwise processing electronic data messages or electronic documents and includes the computer system or other similar device by which data is recorded, transmitted or stored.

E. Personal Information

Personal Information is a compilation of data collected from the individual whether recorded in a material form or not, from which the identity of an individual is apparent or can be directly ascertained by the entity holding the information and when put together with other information, it would also entail the identity of the individual.

F. Personal Information Controller

Refers to a person or company who controls the collection, holding, processing or use of personal information, including a person or company who instructs another person or company to collect, hold, process, use, and transfer or disclose personal information on his or her behalf.

The term excludes:

  1. A person or company who performs such functions as instructed by another person or company; and
  2. An individual who collects, hold, processes or uses personal information relating to the individual’s personal, family or household affairs.

G. Personal Information Processor

Also known as, PIP. This refers to any entity that is qualified to act as such under the Act to whom a personal information controller may outsource the processing of personal data pertaining to a data subject.

H. Processing

This refers to any set of operations performed by the company upon personal information including, but not limited to, the collection, recording, organize, storage, updating or modification, retrieval, consultation, use, consolidation, blocking, erasure or destruction of data.

I. Privileged Information

Refers to any and all forms of data collected from data subjects which under the Rides of Court and other pertinent laws constitute privileged communications.

J. Sensitive Personal Information

The type of personal information that reveal information

(i) about an individual’s health, education, genetic or sexual life of a person, or to any proceeding for any offense committed or alleged to have been committed by such person, the disposal of such proceedings, or the sentence of any court in such proceedings;

(ii) issued by government agencies peculiar to an individual which includes, but not limited to, social security numbers, previous or current health records, licenses or its denials, suspension or revocation, and tax returns; and

(iii) Specifically established by an executive order or an act of Congress to be kept classified.

3.   How we collect personal data

AGBI may be able to obtain personal data in different ways. These include where a person:

(i) Submits any application form, request, notice, or some documents;

(ii) Get in touch with us by inquiring or applies for employment;

(iii) Becomes a consultant, employee, officer, supplier, or service provider of the company;

(iv) Uses any of our communication channel (websites, platforms, and other online presence);

(v) Gets into an agreement with us, regardless if it is written or not, including employment contracts, or other contract to avail our services; or

(vi) Provides us with personal data, directly or through another person.

4.   Purposes of collection and processing

AGBI collect and process personal data for the purposes for which you have provided the data or made it available to the public or directly to us, and to allow us to efficiently achieve those purposes (“Subsection 4.1”), as allowed by applicable law.

The recipient of personal data that we collected include persons within AGBI (including affiliates or related companies) and third parties whom we may outsourced under certain business activities in order to achieve the purposes stated in Subsection 4.1.

Let it be known that some of the transfer of data will be cross-border because some of the entities may be outside the Philippines.

4.1. General

We use personal data to:

(i) Comply with and exercise the rights under contracts and agreements, and the law, as may be required by our operations;

(ii) Perform and improve our services and address concerns or questions about those services;

(iii) Create and nurture relationship with the goal to continuously provide you with our service;

(iv) Obtain services for our operations and business;

(v) Conduct survey, research, feedback and other data gathering exercises;

(vi) Market, promote and share information about the company and our services;

(vii) To meet legal and regulatory requirements. We perform such other processing or disclosure that may be required under pertinent laws, rules, or regulations; and

(viii) Establish communication with you.

4.2. Employee

We may collect and process personal data from current and prospective employees of AGBI. This is for the company to carry out certain departmental duty to initiate, review or terminate an employee agreement.

For job applicants, AGBI may process certain personal data that are part of the requirement to commence the employment process. The collected personal data of any applicants, whether they have been hired by AGBI or not, may be retained by the company for the purpose of a future selection process.

Aside from personal data, part of the employment conditions are to submit the results of certain medical examinations to AGBI.

5.   Consent and other lawful criteria for collecting and processing

When a person provided us with personal data through any of the interaction mentioned in Section 3, in providing or making available the personal data, the person agrees and consent to processing the personal data for the purpose stated in Section 4, and the terms and conditions applicable to the nature of the transaction between the data subject and AGBI.

6.   When we disclose personal information

There are circumstances where we may need to disclose or share some of the information that you have provided to us. In these cases, we ensure that personal information is disclosed on a confidential basis, and always subject to the applicable rules and regulations of the Data Privacy Act of 2012.

We will never share, rent or sell your personal information to third parties outside of the Anderson Group BPO, Inc. except in circumstances where you have given your specific consent for.

In circumstances where law enforcement is involved, the disclosure will be subjected to applicable laws and regulations.

7. What your choices are

You are afforded certain rights in relation to your personal data under the DPA and its corresponding IRR. We would like to ensure that we have your consent to continue to collect, record, organize, update or modify, retrieve, consult, use, consolidate, block, erasure or destruct and disclose your personal information for the purposes that we have identified.

At the same time, we want you to know that you do have choices and can object or withdraw your consent and/or edit your consent preferences at any time.

If you wish to have access to your personal information in our records, obtain a usable “portable” electronic copy of your personal information; or you think that such information we have about you is incomplete, not up-to-date, or inaccurate. You may get in touch with our Data Privacy Officer through the contact details provided below. In some instances, we may ask you to provide supporting documents or proof before we warrant any changes to your personal information. We will also send you an update regarding your request. Depending on the nature of the request, AGBI may charge a reasonable fee for providing access to your personal information.

How to contact us

Please contact us if you have any questions about our privacy policy or information we hold about you.

Anderson Group BPO, Inc.

Country: Philippines
Office Address: 11/F Wynsum Corporate Plaza, #22 F. Ortigas Road Jr. (Formerly Emerald Avenue), Ortigas Center, Pasig City, Philippines

Email: dpo@andersonbpoinc.com
Write to us: 11/F Wynsum Corporate Plaza, #22 F. Ortigas Jr. Road, Ortigas Center, Pasig City, Philippines

8. What happens when there are changes in our policy

Anderson Group BPO, Inc. may update our policy and practices from time to time in order to comply with changes in the laws, rules, and regulations, government and regulatory requirements, to adapt to new technologies and protocols, to align with industry practices, or for other legitimate purposes.

You will be notified if these changes are significant and, if we are required by law, we will ensure to obtain your updated consent.