It’s barely two days to March 8, the deadline set by the National Privacy Commission for the registration of personal data processing systems (DPS) of personal information controllers (PICs) and personal information processors (PIPs). How are you doing with your registration?

Based on a forum I attended two weeks ago, a lot of PICs/PIPs have not yet started the registration process. Among the reasons are problems encountered with the NPC’s DPS registration portal. Understandably, with the deluge of registrants accessing the platform, the portal will have performance issues.

Manual registration

If you are having difficulty completing the registration on the portal, note that the PICs/PIPs do have the option of doing a manual registration with the NPC. That is actualy the route that one of my clients is taking since they have not received their access codes as of last week.

The NPC has not issued guidelines on the manual registration. I’ve searched the NPC website and it does not appear that the NPC has prepared a form/template through which the manual registration may be done. However, a deadline is a deadline. And it is always better to submit the requirements on time and address any deficiencies later rather than miss the statutory deadline. So what I did was to reduce the questions on the NPC portal into an MS Word document. While it may not be the “official” form, my client IS submitting the required information and is doing so WITHIN the deadline. You may consider that approach as well, especially since whenever questions on the deadline have been raised to NPC officials they have stressed that PICs/PIPs can always take the manual route of submission.

Deadline extension?

A lot of people are asking whether, given the NPC portal’s performance issues, the NPC will be extending the deadline for DPS registration. So far, the NPC has stood firm on the deadline. In a casual conversation, I did hear about the registration deadline being extended for INDIVIDUAL PICs/PIPs. In the past two days, I’ve scoured the NPC website as well as the social media accounts and there has been no issuance on such an extension. I did find on my online search a blogpost on the SeriousMD.com blog, which posted a letter from May Arboleda-Cuevas from the Office of NPC Commissioner Liboro that the deadline for individual PICs/PIPs is being moved back four months to July 2, 2018.

I hope the NPC clarifies the deadline as soon as possible. Apart from saving people from a lot of distress, an early announcement of the reprieve will also mean people won’t be incurring unnecesary expenses in overtime pay, etc. just to meet the March 8 deadline.

#personaldataprocessingsystem #nationalprivacycommission #compliance