Privacy Statement for Visitors, Guests and Applicants

DBA Global Shared Services, Inc., (“DBA”, “we”, “us,” “our”) respects the privacy of any person visiting our offices or any DBA-owned premises, whether scheduled or unplanned, by invitation, upon authorization, or on their own initiative, including applicants who have been invited for a face-to-face job interview or were required to submit their pre-employment requirements personally, and is committed to protecting the data we collect from you once you enter our offices or any DBA-owned premises pursuant to the provisions set forth in Republic Act No. 10173 or the Data Privacy Act of 2012 (DPA).

For security purposes, all DBA offices and respective surrounding premises are monitored by Closed Circuit Television (CCTV) cameras, which capture and record footages to determine the identity, actions and whereabouts of visitors or guests, whilst inside or around our offices or any DBA-owned premises.

The Information We Collect and Hold

We collect personal information with relevance to your visit directly from you at the point of collection in our office or any DBA-owned premises, during the course of our business with you or of your purpose for visiting, or from information about you as provided by third parties or other sources that you have given consent to disclose such information separately or as a legal requirement prior to your visit, or by any third-party agency conducting background checks as instructed by the Company, within or outside the Philippines.

The information we collect includes:

  1. Your name, address, contact information, vehicle type and plate number or conduction sticker number, as collected in our logbook,
  2. Identification card details, including government-issued identification information, when you deposit a proof of identification (ID) as a requirement for verification purposes,
  3. Images or video recordings captured by our CCTV installed in and around our premises, including entrance and exit points, and
  4. Your health information, including recent travel history, when you complete our online Visitors Health Checklist, which is accessible through a dedicated QR Code.

For applicants, we will also collect data from:

  1. Statements you provide during the course of your face-to-face job interview,
  2. Relevant information from the pre-employment requirements that you will personally submit, which includes your records from the National Bureau of Investigation (NBI), the results of your pre-employment medical examination, documents confirming your educational background and work history, and documents relating to your dependents or beneficiaries.


Why We Collect Your Information

We collect, store, process, use, and analyze your data primarily to establish your identity and monitor your whereabouts whist inside our office or any DBA-owned premises. The data we collect will also be used for maintaining the safety and security of our office or any DBA-owned premises, and for data analysis and security and safety improvement purposes.

Specifically, we will collect, store, process, use, and analyze your personal data to:

  1. Ensure the safety and well-being of our employees and the people we transact with.
  2. Facilitate your entrance to and exit from our office or premises, including your vehicle.
  3. Monitor your location and activities inside the office or premises.
  4. Conduct investigations in case of violation of our policies and other applicable laws.
  5. Comply with contact tracing requirements.

For applicants, we will also collect, store, process, use, and analyze your personal data to:

  1. Comply with the Department of Labor and Employment (DOLE) policies and procedures.
  2. Facilitate the recruitment process as to your employment application.


Keeping Information Secure

DBA is committed to ensuring that the security of your personal information is held at the highest standard, and with regular monitoring of possible threats and hazards being implemented in all DBA related and independent entities. We utilize robust precautions to protect the confidentiality and security of your data by employing technological, physical, and administrative security safeguards, such as firewalls and Secure Socket Layer (SSL) technology. Despite the process and means of security that we implement for the protection of your data, we nevertheless cannot guarantee full and absolute security of your data.


Confidentiality

Only authorized employees who have a need for your information in the performance of their functions shall have access to such information. For Applicants, the Human Resources and recruitment staff and the IT and Administration staff have specific responsibilities that require access to your personal information.

All DBA employees have sufficiently received the necessary training as to our privacy and security policies and are required to sign non-disclosure agreements as to the strict confidentiality of Confidential Information, which includes Company information, our Clients’ information, and the information provided by visitors or guests and applicants, before and during their visit to our office or any DBA-owned premises.


How Information Is Used and Disclosed

Personal Information

We will only use or disclose your personal information for the purpose for which it was collected:

  • to provide the availed Services based on our contractual arrangement
  • to render client support, including IT services
  • to improve our Services
  • to assist in the operation of our business
  • for necessary research
  • for correspondence

In respect of the privacy and confidentiality of all applicants’ personal information and to comply with legal obligations, your information will only be collected, recorded, processed, used, and stored by the Company’s recruitment and HR team and IT and Administration Division in the performance of their functions in relation to the employee onboarding process, and will only be disclosed for the purpose for which it was collected, which includes:

  • to evaluate your qualifications and suitability for employment
  • to verify information and conduct reference checks
  • to provide the Client with information relative to the review and assessment of your application for employment
  • for compliance requirements relative to the operation of our business
  • for the provision of the tools necessary for the completion of your duties and responsibilities
  • to give you the necessary access or login credentials to the Clients’ software or system or any asset required, relative to the performance of your functions

You may opt not to provide your personal data. We cannot, however, guarantee full implementation of our Services for lack of data.

As an outsourcing company, some information collected from you may be disclosed to our related entities. These related entities have their own legal structures, and they operate hand-in-hand with us. We do not share any information, for example, with our independent Legal and Audit teams unless the sharing of information is with your consent, or the information is necessary for the execution of our contractual agreement. Our related entities with whom we share your personal information may operate outside of the Philippines. Where this occurs, we take all reasonable and necessary steps to protect your personal information against misuse or loss, ensure that the overseas recipient complies with the relevant privacy laws in the Philippines (specifically RA 10173, or the DPA), and may enter into an enforceable contractual arrangement with the overseas recipient that they will handle all personal information accordingly. In addition, a regular compliance check is being implemented to all our overseas related entities.

For applicants, collected information may also be disclosed to our Clients overseas for assessment purposes if applying for a dedicated role or position, which requires the final approval of the Client regarding employment suitability and advancement.

We may also share your information with third-party providers, such as cloud storage services that store your personal data. We take the utmost precaution and verification that our third-party providers are able to deliver the highest security in storing your data before any transfer is made.

We will also use or disclose your personal information if required to do so by law, such as those relating to Republic Act No. 9510 and Republic Act No. 9160, as amended, or the Anti-Money Laundering Act.

Further, we will process or disclose data collected by our CCTV to relevant units to aid in the prosecution of any crime committed against our offices and any DBA-owned premises, or against neighbouring or nearby facilities, offices, or organizations.

Health Information

Although the Coronavirus Disease (COVID-19) is now considered an established and ongoing health issue that is no longer a public health emergency of international concern, DBA maintains its health monitoring and safety protocols, which includes the collection of your health conditions, COVID-19 vaccination information, and travel history.

We will only use or disclose your health information for the following purposes:

  • to conduct effective health monitoring and contact tracing
  • to comply with the Department of Labor and Employment (DOLE) Occupational Safety and Health (OSH) reporting requirements
  • to comply with Republic Act No. 11332 or the Mandatory Reporting of Notifiable Diseases and Health Events of Public Health Concern Act
  • to comply with Republic Act No. 11058 or An Act Strengthening Compliance with Occupational Safety and Health Standards and Providing Penalties for Violations Thereof.
  • to comply with local health and safety legislation
  • to assist the local government in providing timely response to manage the spread of the disease

In compliance with the OSH Standards set by the DOLE, DBA is required to continue providing monthly reports of illnesses, diseases, and injuries in the workplace, which includes reporting probable COVID-19 cases. To meet this compliance requirement, we will share your health information with the relevant DOLE Regional Office using the Work Accident/Illness Report (WAIR) COVID-19 form.

We may also share your information with the local health authorities with jurisdiction over the relevant office or DBA-owned premises that you are visiting or have visited and, for foreign visitors or guests, the hotel or accommodation that you have secured while in the country, as mandated by RA 11332. For local visitor or guests, this includes your respective Barangay Health Emergency Team (BHERT).Further, we may also share your health information with our affiliate hospitals or relevant local hospital if, upon your declaration of your conditions or whilst you are inside our office or any DBA-owned premises, we have determined that you are in need of immediate medical attention.

How Long We Retain Your Data

All information that has been collected will be retained on the basis of the retention period provided by law or regulation, or until it is necessary for the fulfillment of our contractual arrangement. You have the right to direct us to delete your personal data unless there exists a legal requirement for the retention of the information.

Please advise if you require us to delete your data for either of the following reasons: (1) it is already inapplicable for the purpose for which it was collected; (2) withdrawal of consent; and (3) your data was unlawfully processed.

For data collected by our CCTV, all images and video footage will be recorded for thirty (30) days unless there is a security or legal matter where it will be of use to, which will require your footage to be recorded for a longer period or processed in other means, when necessary.

What You Are Consenting To

DBA is committed to ensuring your rights as a data subject is protected and that you have received complete and accurate information about this Privacy Statement for Visitors and Guests, whether from a link to this Statement through a dedicated QR code, or from a copy of this Statement as posted on our website or displayed at the point of collection in our office or any DBA-owned premises.

By signing our logbook, you are providing your consent to our collection, storage, processing, use and analysis of the information you provide with relevance to your visit to our office or any DBA-owned premises, pursuant to the provisions set forth in RA 10173.

Similarly, by completing our online Visitors Health Checklist, which is accessible through a dedicated QR Code, you are providing consent to our collection and disclosure of your health information, pursuant to the provisions of RA 11332 and RA 11058.

Moreover, by entering our premises, you are already providing your consent to capture, record, process and disclose information directly and indirectly obtained by our CCTV cameras, including but not limited to, images and video recordings of your actions and whereabouts while inside or around our premises.

DBA will endeavor to place, post, or display other privacy notices in our office or any DBA-owned premises, on our website, or on our social media channels to remind you of how we collect, store, process, use, and analyze information that you provide with relevance to your visit and for the legal purposes stipulated in this Statement.

Further, should we require the collection, storage, processing, use and analysis of your information for other legal and compliance purposes not included in this Statement, DBA will take all reasonable efforts to obtain your consent through a separate form, whether online or printed, which may require you to affix your signature as proof of your agreement and consent.

Keeping Information Accurate and Up to Date

Reasonable steps are taken to ensure that all information is accurate, up-to-date, and complete. Please contact us immediately should you require an update, correction, or addition of new information in your data.

Access to Your Data

Upon request, access to your data will be provided to you so you can easily amend, correct, or delete your personal data. You may also opt to provide us information with the corrections, if necessary, and we will amend any incorrect information for you. We could also provide you with the means of collection and the reasons why we have collected your data.

Changes In The Statement

We update our Privacy Statement for Visitors and Guests, on a periodic basis as we deem appropriate to reflect changes to any of the relevant laws as mentioned in this Statement or when new laws, legislation, rules, and regulations have been passed with respect to data privacy.

Feedback

DBA welcomes feedback and complaints about privacy issues. We will endeavor to resolve all complaints within 30 days. Please address all questions and complaints through:

Email: info.ph@dbaadvisory.com

Telephone: (047) 250 0901

If the matter has not been resolved, the aggrieved party may file complaints to the nearest relevant commission or authority.

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