PRIVACY STATEMENT FOR SUPPLIERS AND CONTRACTORS

LRMC is committed to maintaining the accuracy, confidentiality, and security of your personal information. In this Privacy Policy, we explain how we ensure that your data privacy rights are respected and protected.

1.         APPLICATION

LRMC has adopted a Privacy Policy with a series of Privacy Statements to address the privacy concerns of certain groups of individuals and some issues on the use of our website. These are all available in our website https://lrmc.com.ph/privacy.

This Privacy Statement applies to you as a contractor and supplier of LRMC, including your owners, directors, partners, employees or any other individuals who may interact with LRMC.

2.         POLICY OF COMPLIANCE

It is our policy to comply with Republic Act No. 10173 or the Data Privacy Act of 2012 and its Implementing Rules and Regulations (“DPA”).

3.         WHAT IS PERSONAL DATA?

Personal Data includes any information which identifies or can identify an individual. Personal Data does not include anonymous or non-personal information which cannot be associated with or traced back to a specific individual.

4.         WHAT PERSONAL DATA DO WE COLLECT?

We collect and maintain different types of personal information in respect of our contractors and suppliers, including the personal information (such as names, contact numbers, e-mails, business address, etc.) contained in:

• materials you provide us when you market or offer to supply us with certain products or services;
• documents submitted to bid for goods and services (including proposals and curriculum vitae submitted as part of the bid or tender process);
• registration forms filled out at the time you become a registered/accredited contractor or supplier of LRMC, including registering as a supplier or contractor;
• work permit or delivery permit application forms and other applications with LRMC to enable you to perform the services and/or supply the goods to LRMC;
• contracts, invoices, policies and other correspondences sent to LRMC;
• e-mails sent to LRMC, business cards or information given during telephone calls or face to face discussions; and
• security guard log books when you visit LRMC’s offices or surveillance cameras (CCTV).

From time to time, we may use the services of third parties and may also receive personal information collected by those third parties in the course of the performance of their services (e.g., your details are passed on by other parties within the industry or clients as a potential supplier or contractor). Where this is the case, we will take reasonable steps to ensure that such third parties have represented to us that they have the right to disclose your personal information to us.

Where permitted or required by applicable law or regulatory requirements, we may collect and process information about you without your knowledge or consent.

5.         WHY DO WE COLLECT PERSONAL DATA?

We sometimes need to collect your personal information so that we can establish, manage, administer and facilitate the provision of products and/or services by or to you LRMC. These uses include:

• contacting you about potential supply or service agreements with you;
• responding to any inquiries or feedback received from you;
• performing our obligations to you under supply or service contracts, including processing of payments to you
• taking legal or administrative action in relation to our supply or service contracts, including enforcing the terms of such contract or resolving any disputes;
• undertaking financial management, planning and reporting within LRMC;
• undertaking health and safety activities and checks;
• keeping in touch with you for any future business opportunities; and
• such other purposes as are reasonably required by LRMC.

As a company operating a public utility, we may sometimes need to process your personal information to pursue our legitimate interests, like protection of health, security or safety of individuals.

6.         HOW DO WE USE YOUR PERSONAL DATA

We may use your personal information:

• for the purposes described in this Privacy Statement; or
• for any additional purposes which we will tell you about and only do so if we get your consent, when your consent is required by law.

We may use your personal information without your knowledge or consent only when we are permitted or required by law or regulations to do so.

If, in the future, we intend to process your personal data for a purpose other than that which it was collected, we will provide you with details of such purpose and any other relevant information.

7.         WHEN DO WE DISCLOSE YOUR PERSONAL DATA?

We will only disclose information about you to third parties if we are legally obliged to do so or where we need to comply with our obligations to you. For instance, we may need to pass on certain information to our banks and other payment processing service providers who process our payments to you, our external consultants such as accountants, auditors, legal advisers and insurance brokers, and any technology service providers, including internet service providers, software suppliers, maintenance and support service providers.

Further, your personal information may be disclosed:

• when necessary to protect LRMC’s rights and property;
• when necessary to protect your safety or other person’s safety during emergency situations;
• when the personal information is publicly available; or
• with your consent, when such consent is required by law.

8.         NOTIFICATION AND CONSENT

Privacy laws do not generally require us to obtain your consent before collecting, using, or disclosing your personal information. In addition, we may collect, use or disclose your personal information without your knowledge or consent, when we are permitted or required by law or regulations to do so.

Unless you advise us otherwise and to the extent that your consent is required, we will obtain your consent for the collection, use, and disclosure of your personal information for the purposes stated above and any other purposes stated or reasonably implied at the time such personal information was collected from you.

Where your consent was required for our collection, use, or disclosure of your personal information, you may at any time withdraw your consent, subject to legal or contractual restrictions and reasonable notice. All communications as to withdrawal or variation of consent should be in writing and addressed to our Privacy Officer.

9.        HOW IS YOUR PERSONAL DATA PROTECTED?

We endeavor to maintain physical, technical, and procedural safeguards that are appropriate to the sensitivity of your personal information. These safeguards are designed to protect your personal information from loss and unauthorized access, copying, use, modification or disclosure

10.        HOW LONG IS YOUR PERSONAL DATA RETAINED?

Except as otherwise permitted or required by law or regulations, we endeavor to retain your personal information only for as long as we believe is necessary to fulfill the purposes for which your personal information was collected (e.g., meeting any legal, accounting or other reporting requirements or obligations). Instead of destroying or erasing your personal information, we may make it anonymous such that it cannot be associated with or traced back to you.

Our Finance Department keeps records for ten years. Surveillance camera footage is kept for 90 days, after which it is erased, unless an investigation needing the footage is ongoing.

11.        UPDATING YOUR PERSONAL DATA

It is important that your personal information found in our records is both accurate and up-to-date. If any of your personal information happens to change during the course of your dealings with LRMC, please keep us informed of such changes.

In some circumstances we may not agree with your request to change your personal information and will instead append an alternative text to the record in question.

12.         ACCESS TO AND RECTIFICATION OF YOUR PERSONAL DATA

You have the right to see and access your personal information in our possession. You also have the right to request from us the rectification or deletion of your personal data, the right to restrict processing, the right to object to processing, as well as, in certain circumstances, the right to data portability (or to transfer your personal information from one controller to another).

If you wish to review, verify, delete, or correct your personal information, please contact the office of our Privacy Officer using the contact information set out below. Any such communication to our Privacy Officer must be in writing.

When requesting access to your personal information, you may be required to provide some information to enable us to verify your identity and to search for and provide you with your personal information. To access your personal information, we may charge you with a reasonable fee which you will be informed of in advance. If you require assistance in preparing your request, you may contact the office of our Privacy Officer.

Your rights with respect to your personal information are not absolute. There are instances when laws or regulations allow or require us to withhold from you some or all of your personal information. In addition, the personal information may also be destroyed, erased or made anonymous in accordance with our record retention obligations and practices.

In the event that we cannot provide you with access to your personal information, we will endeavor to inform you of the reasons, subject to any legal or regulatory restrictions.

13.         INQUIRIES OR CONCERNS?

If you have any questions about this Privacy Statement or concerns about how we manage your personal information, please contact the office of our Privacy Officer by e-mail. We will endeavor to answer your questions and advise you of any steps taken to address your issues and concerns. If you are unsatisfied with our response, you may make a written submission to the National Privacy Commission.

14.        PRIVACY OFFICER

We have appointed a Privacy Officer to oversee compliance of our Privacy Policy.

You may contact our Privacy Officer through any of the following:

Postal address:	Mezzanine, Engineering Building, LRTA Compound, Aurora Boulevard, Pasay City
Telephone number:	(02) 5318-5762 loc. 5726
Email address:	dataprivacy@lrmc.com.ph

15.        REVISIONS TO THIS PRIVACY POLICY

We may, from time to time, make changes to our Privacy Policy to reflect changes in our legal obligations or in the manner by which we deal with your personal information. We will communicate any change made to our Privacy Policy.

Any change to our Privacy Policy will be effective from the time they are communicated. However, in cases where your consent is required, any change as to the collection, use or disclosure of your personal information will not apply to you, until we have obtained your consent to such change.

This Privacy Statement was last reviewed on December 3, 2018.

16.         INTERPRETATION OF THIS PRIVACY POLICY

Interpretation of this Privacy Policy will be made by our Privacy Officer.

This Privacy Policy includes examples, but is not intended to be restricted in its application to such examples. Therefore, where the word “including” is used, it shall mean including without limitation.

This Privacy Policy does not create or confer upon any individual any right, or impose upon LRMC any right or obligation outside of, or in addition to, rights or obligations imposed by the DPA. Should there be, in a specific case, any inconsistency between this Privacy Policy and the DPA, this Privacy Policy shall be interpreted, in respect of that case, to give effect to, and comply with, the DPA.