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ARTICLE · 01 APRIL 2021

Legal Developments In The Philippines: Focus On Data Privacy, Digital Banks And FinTech

SyCip Salazar Hernandez & Gatmaitan
SyCip Salazar Hernandez & Gatmaitan
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SyCip Salazar Hernandez & Gatmaitan

SyCip Salazar Hernandez & Gatmaitan

SyCip Salazar Hernandez & Gatmaitan (SyCipLaw) is one of the largest law firms in the Philippines...

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This bulletin is on recent Philippine legal developments in data privacy, fintech and digital banks.

PhilippinesPrivacy

This bulletin is on recent Philippine legal developments in data privacy, fintech and digital banks.

PRIVACY UPDATE

Caring about Sharing: New Rules on Data Sharing Agreements

On December 23, 2020, the Philippine data privacy regulator, the National Privacy Commission (NPC) issued NPC Circular No. 2020-03 on data sharing agreements (2020 DSA Circular).1 The circular supersedes NPC Circular No. 16-02 which specifically applied to data sharing agreements (DSAs) among government agencies, although the NPC had pointed to 16-02 as a source of guidance for personal information controllers (PICs) in the private sector. The 2020 DSA Circular applies to PICs in all sectors.

The Data Privacy Act of 2012 or the DPA (the Philippines' principal data privacy statute) and its implementing rules (IRR) generally categorize transfers of personal data subject to the DPA into outsourcing agreements and DSAs. Outsourcing agreements are those where data is transferred from a PIC

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