DIGITAL PRIVACY STATEMENT

Digital Web and Mobile Privacy Statement

Southwestern University PHINMA (SWU PHINMA) is committed to respecting your privacy. This privacy statement governs the collection and use of information collected through official SWU PHINMA websites and other SWU PHINMA digital properties.

This is a general statement of SWU PHINMA’s position on data privacy specifically in the context of digital privacy. For information about the Republic of the Philippines Data Privacy Act of 2012 (DPA) and SWU PHINMA’s responses to its Implementing Rules and Regulations, and other National Privacy Commission (NPC) relevant policies, including all other issuances of the National Privacy Commission, please refer to SWU PHINMA DPA policy page.

On This Page:

• Personally Identifiable Information
• Non-Personally Identifiable Information
• Cookies
• Sharing Your Information
• Behavioral Advertising
• Security
• Third Party Sites
• Changes to this Privacy Statement
• Questions

Personally Identifiable Information:

SWU PHINMA will not collect personally identifiable information about you when you visit our websites or digital properties unless you voluntarily provide us with that information. SWU PHINMA may request personally identifiable information from you if you wish, for example but not limited to, to submit an inquiry, apply for online enrollment, access a password-protected website, join a mailing list, engage in a payment transaction. SWU PHINMA may use that information for such purposes as fulfilling your requests for our information or services, communication information that may be of interest to you, and conducting research surveys. SWU PHINMA will not share your information with third parties except as set forth below under “Sharing Your Information.“

Non-Personally Identifiable Information

When you visit SWU PHINMA websites and other SWU PHINMA digital properties, we may automatically collect and store information sent by your web browser, such as IP addresses (i.e., the Internet address of your computer) in server logs. We also collect standard information about your computer (such as your web browser and operating system) and about your usage of our websites and digital properties (such as pages visited, length of visit, and search queries). This information, which does not identify your personally, is aggregated and used to help diagnose problems and suggest points for improving parts of our website and digital properties. For example, we utilize statistical software to identify which parts of our website are most heavily used and which portion of our audience comes from within SWU PHINMA and other schools of the PHINMA EDUCATION network.

Cookies

Like many other websites, portions of SWU PHINMA’s websites and digital properties may use cookies. Cookies are text files that may be transferred to your computer or mobile device through your web browsing software. These cookies are used to remember your preferences or to track statistics on usage of various portions of SWU PHINMA websites and digital properties. Our use of cookies does not involve the collection of personally identifiable information.

You can choose not to accept cookies by selection settings on your web browser that block or restrict the use of cookies. You can also delete cookies that have been placed on your computer or device. For more information about the use of cookies by third parties, see below under “Behavioral Advertising.“

Sharing Your Information

In cases when SWU PHINMA has personally identifiable information (PII) about you, we will not sell, rent, or share that PII and will treat it in compliance with our Personally Identifiable Information Policy and with other related institutional policies and the applicable Republic of the Philippines laws and regulations.

Behavioral Advertising

SWU PHINMA may contract with third party vendors to show our advertisements on non-SWU PHINMA websites and digital properties. SWU PHINMA and third party vendors with whom we contract may use cookies and web beacons to serve our ads based on your prior visit(s) to SWU PHINMA websites and digital properties and to assess the effectiveness of our ads. This is also called Targeted Advertising or Interest-Based Advertising. These techniques use only non-personally identifiable information.

Security

SWU PHINMA has implemented reasonable physical, technical, and administrative procedures to safeguard and secure all information we collect online against loss, misuse, or alteration of the information under our control. This includes the use of encryption when collecting or transferring sensitive data. Please note that while we work hard to protect the security of your information, SWU PHINMA cannot provide an absolute guarantee as to the security of any information you transmit through our websites or digital properties, and that you do so at your own risk.

Third Party Sites

SWU PHINMA websites and digital properties may link to external sites that are not controlled by SWU PHINMA. Your use of such websites will be subject to the privacy statements of those websites, which we encourage you to read. SWU PHINMA is not responsible for the privacy practices or the content of such websites and does not make any representations about them.

Changes to this Privacy Statement

We reserve the right to modify this Privacy Statement in whole or in part at any time. The modified policy will be posted on this page with an updated effective date.

Questions

If you have questions about this Privacy Statement or the privacy practices of SWU PHINMA websites or digital properties, please contact the SWU Data Protection Officer at [email protected] .

Effective Date: March 3, 2021

SWU PHINMA DATA PRIVACY MANUAL Version 2.1

SWU PHINMA DPA policy

• What is the DPA?
• What areas of SWU PHINMA may be impacted?
• How is SWU PHINMA responding?
• Data request process
• Notices
• Procurement
• Where can I find out more?

What is the DPA?

The DPA is the data protection law that applies broadly to the processing of personal information about Philippines’s residents and visitors. Generally speaking, the regulation applies to all personally identifiable data that is collected, used, stored or otherwise processed about individuals in the PHILIPPINES under certain circumstances, by any method including electronic and paper records.

The DPA requires institutions to process personal data according to a set of fundamental principles:

• Process personal information fairly and in a transparent manner.
• Collect personal information for specific and legitimate purposes.
• Limit the use of personal information to what is necessary and for defined purposes.
• Keep accurate and up-to-date all personal information.
• Retain personal information for as long as is necessary and secured.
• Ensure that all processing meets one of certain legal bases that are specified under the DPA.
• Provide data subjects with certain individual rights including the right to receive detailed notices about the collection and the use of their data and to access and amend personal data that is collected about them.
• Engage in data protection impact assessments for activities that pose a high risk of harm to
• individuals and to incorporate “privacy by design and default” into all of its processing activities.
• Notify the applicable regulatory authority and individuals in the event of certain data breaches and,
• Maintain detailed records of its data processing activities and appoint a Data Protection Officer.

What areas of SWU PHINMA may be impacted?

The DPA applies to the processing of personal information in the context of organizations

established in the PHILIPPINES, which includes PHINMA EDUCATION’s Philippines’ companies such as: The head office, any satellite office, all registered schools, universities and university branches; and in the present case, to SWU PHINMA.

The DPA also applies to the processing of data by organizations outside the Philippines, where

those activities are related to offering of goods or services to individuals in the Philippines, or

monitoring of behavior of individuals that takes place in the PHILIPPINES. For example, this may

include processing of data by SWU PHINMA in the context of recruiting prospective students who are located outside the Philippines but will eventually study in the Philippines.

Any department or school that collects, uses, or otherwise processes personal information about people while they are in the Philippines may be impacted by the DPA.

How is SWU PHINMA responding?

The President of Southwestern University, Inc. has designated Atty. Godwin Denzil B. Manginsay as the Data Protection Officer (DPO) for Southwestern University, Inc. on August 16, 2017 and this is duly registered with the NPC with number “PIC-002-620-2019”

The DPA compliance resources are currently located in a shared Google drive that will be made

available to relevant data privacy process owners as applicable.

SWU PHINMA Created a Data Privacy Manual that is being updated at the beginning of every new school year or whenever necessary.

Each sections of the SWU Data Privacy Manual provides details on how SWU PHINMA is responding to the DPA.

 

Data request process

If individuals in the Philippines (including students, alumni, and employees) wish to exercise their rights under DPA please download the SWU PHINMA Personal Data Request Form, fill it out, and send it via email [email protected] together with supporting documents.

Data Privacy Notices

SWU PHINMA will implement additional notices from time to time as necessary; they will be published here if applicable for the SWU PHINMA websites, sent via email directly to students or employees, or be printed and given to students or employees as attachment to other set(s) or document(s) as needed to comply with the DPA and DPA Implementing Rules and Regulations.

Data Privacy Notice: Data consent Form

Procurement

Under the DPA, SWU PHINMA has an obligation to have agreements with organizations that are processing personal data covered by the DPA on SWU PHINMA’s behalf.

These agreements are “Data Sharing Agreement” in the cases where the third party vendor will process Personally Identifiable Information (PII) and “DPA Consent Forms” for all other cases. Those agreements include provisions to ensure that personal data is being appropriately processed and protected in compliance with the DPA.

Where can I find out more?

For additional information, read the full text of the DPA and the DPA IRR

Republic of the Philippines National Privacy Commission: https://www.privacy.gov.ph/

For inquiries about DPA implementation at SWU PHINMA, email the Data Protection Officer at [email protected] or go to Urgello Street, Sambag II, Cebu City, Cebu 6000

SWU DPA Policy:

Effective Date: March 3, 2021

SWU PHINMA DATA PRIVACY MANUAL Version 2.1