Privacy and protection of household’s data and personal information

As commitment to public trust, we, the Philippine Statistics Authority (PSA), uphold confidentiality of information and data privacy in the conduct of 2022 Community-Based Monitoring System (CBMS).  All city and municipal local governments that will implement the PSA protocols are enjoined to exercise the same level of commitment in ensuring that 2022 CBMS data are protected, secured, and used for the right purpose.

In this privacy notice, we provide details on the importance of your cooperation and your information. We also enumerate all the steps that we take to make sure your information and your privacy are respected.

Why we collect household data and personal information

The 2022 CBMS is being implemented in the Philippines to:

1. generate updated and disaggregated data necessary in identifying beneficiaries for social protection programs of the government;

2. conduct more comprehensive poverty analysis and needs prioritization;

3. inform and contribute to evidence-based design of appropriate policies and interventions particularly on poverty alleviation and disaster risk reduction and management;

4. provide mechanism for government program impact monitoring over time;

5. provide information that will enable a system of public spending that warrants government allocation on areas and populace that are most wanting;

6. establish CBMS database at the national and city/municipal levels that could be updated periodically to capture important snapshots of the demography of communities; and

7. generate relevant statistics at higher levels that will complement and supplement the local level data.

In order to achieve the goals of the CBMS for our nation, we request all persons and households to actively participate in the activity by sharing truthful information to the authorized CBMS personnel.  We collect information from you through a questionnaire under our mandate to produce quality and reliable statistics and information that serve the public good.

Participation in the conduct of CBMS is purely voluntary. Agreeing to be interviewed means that you are willing to provide data to PSA and the local government unit (LGU) for official statistics purposes. Moreover, agreeing to sign the waiver/consent form means that you are giving permission to the PSA and LGU to share your personal information and that of your household members’ to national government agencies (NGAs) with social protection programs that can benefit the local communities.

Nevertheless, the right to privacy of every respondent remains inviolable. Hence, our interviewers shall be able to fully inform you of the nature and extent of processing intended for your household and personal data.  They shall let you decide on your participation to the 2022 CBMS.

Truthful and complete responses to the CBMS data collection forms are important for the LGUs and NGAs to craft appropriate policies and programs for inclusive and equitable development. Thus, the information listed below are collected by CBMS Enumerators using the Computer-Assisted Personal Interview (CAPI) approach through an Android application developed for this purpose. The same data items are also in the paper questionnaire which may be utilized in cases when the CAPI cannot be used.

1. Geographic location of housing units/buildings

2. Contact number and email address of respondent

3. Demographic characteristics

4. Migration

5. Education and literacy

6. Community and political participation

7. Economic characteristics

8. Entrepreneurial and household sustenance activities

9. Agricultural and fishery activities

10. Family income

11. Food consumption

12. Food security

13. Financial inclusion

14. Health

15. Climate change and disaster risk management

16. E-commerce and digital economy

17. Crime victimization

18. Social protection program

19. Water, sanitation, and hygiene

20. Housing characteristics

Republic Act (RA) No. 11315[1] details the duties and responsibilities of the PSA as the lead implementing agency of the CBMS.  It also mentions the mandate of the CBMS to undertake geotagging activities[2] to record status of government projects, housing units, service facilities, and natural resources. The Act also provides for the regular and synchronized conduct of the CBMS every three (3) years.

As per Section 4 of RA 11315, each city and municipality is the primary data collecting authority within its locality.  For this purpose, city/municipal LGUs have an active role in the CBMS operations. In particular, CBMS focal teams in the LGUs closely collaborate with the PSA field offices to undertake various training programs, provide spaces for CBMS local headquarters and other materials and ICT equipment necessary in the conduct of the 2022 CBMS. In cities and municipalities that are not covered by the PSA for funding, the city/municipal LGUs take charge in hiring of enumerators and data processors, as well as in providing materials and equipment for data collection and processing.

Data that you provide to the 2022 CBMS will also be used by PSA and entities that are permitted by the CBMS Council to carry out research and produce statistics that will serve the public good.

Recording of personal information is necessary in the conduct of field interview to safeguard the interest of the respondents and interviewers, and in order to facilitate tracking of questionnaires, as well as in progress monitoring in data collection and processing. Copies of signed waiver/consent forms are kept by PSA for documentation purposes only.  Rest assured that we will hold the minimum amount of personal information needed to meet these purposes.

If you provide feedback to the PSA, we will save your personal details, but we will not share them with anyone else. The feedback you give us will be used to improve PSA procedures, products, and services.

 

Why we collect information from LGUs

As primary partners of the PSA in the 2022 CBMS, all cities, municipalities and barangay LGUs covered in 2022 CBMS operations are required to respond to the 2022 CBMS Barangay Profile Questionnaire and City/Municipal LGU Data Sheet.  The data collection forms will enable the government to collect information that will help:

1. Assess availability of basic service facilities and infrastructure in cities, municipalities and barangay;

2. Supply data as basis for new programs/projects or in finetuning existing infrastructure, programs and projects; and

3. Record location and status of government projects.

These data can also be used to supply information for local government monitoring of the Department of the Interior and Local Government (DILG).  Data that you provide to the 2022 CBMS will also be used by PSA, DILG, and those that are permitted by the CBMS Council to carry out research and produce statistics that will serve the public good.

Recording of personal information of LGU respondents is necessary in the conduct of field interview in order to facilitate tracking of questionnaires, as well as in progress monitoring in data collection.

Since these two data collection forms will be implemented via Computer-Aided Web Interview (CAWI) application platform, we in PSA will collect information about how people fill in their questionnaires online so we can improve our online services and other online data collection tools.

 

Who can access CBMS information

During the CBMS field operations, the PSA and LGUs will employ enumerators or interviewers, team and area supervisors, who will work under the instruction of the Head CBMS Area Supervisors who are employed by and will work under the close supervision of PSA provincial offices.

All authorized CBMS hired personnel are required to wear their official CBMS identification cards.  They shall also be able to present a questionnaire that is cleared under the PSA’s Statistical Survey Review and Clearance System (SSRCS).  SSRCS-cleared data collection tools like the CBMS have survey clearance numbers printed on them.

To verify their identification, you may contact the nearest PSA office for inquiries. You may refer to through the official directory published in the PSA website.  In cases of LGU-funded CBMS areas, please contact your city/municipal LGU for questions. Fictitious claims of PSA or CBMS affiliation will be dealt with seriously and legally by the PSA.

During the CBMS data processing phase, the PSA and LGUs will employ data processors and supervisors, who will work under the instruction of the PSA focal persons who are employed by and will work under the close supervision of PSA provincial offices.  They shall use a 2022 CBMS Data Processing System application to encode and check consistencies in data and responses.  Any data needing validation will be consulted with CBMS hired personnel or, if necessary, the household respondents or LGU respondents themselves. These CBMS data processors and supervisors are not permitted to take data files outside the data processing centers. After being certified by the PSA central office, these data files in the desktop computers used for data processing will be deleted.  The desktop computers will not be used by the LGU for any other purpose until such time clearance from PSA is obtained.

All CBMS data collection and data processing systems and applications that are developed by the PSA are secured.  The PSA has undergone internal privacy impact assessment for the 2021 Pilot CBMS and have setup additional policies and infrastructure to ensure compliance with RA No. 10173 or the Data Privacy Act of 2012 and RA No. 11315.  These laws underscore protection of your rights as respondents to the CBMS.

After these data files are validated and verified, the PSA will give the city/municipal LGUs and provincial LGUs access to their territory-specific data in accordance with Section 8 of RA No. 11315[3].

Pursuant to Section 9 of RA No. 11315[4], national government agencies with social protection programs will also be given access to certain data needed for their identification of beneficiaries. The extent of data that will be shared to them shall undergo a review and approval process by the CBMS Council, which is composed of the PSA, DILG and the Department of Information and Communications Technology (DICT).  Anonymized datasets[5] and aggregate statistics[6] will be readily accessible to public users and researchers.  A data sharing protocol for CBMS will be issued to provide details on these.  Any data transformations undertaken by the LGUs themselves or other organizations/entities thereafter will be the responsibility of the LGUs or other organizations/entities concerned.

In the 2022 CBMS portal to be developed, all documented uses of the CBMS data will be published.  It is our responsibility to share with you and the general public the fruits of your cooperation and support to the CBMS. 

 

How long will CBMS personal data be kept

RA No. 10173 requires that personal information be kept for no longer than is needed to fulfill the purposes for which they were originally collected. Nevertheless, CBMS data must be kept for long periods of time in order to serve the purpose of analyzing the impacts of government projects and interventions to households and communities over time.

In recognition of principles of data privacy and confidentiality, the CBMS Council has the mandate under RA No. 11315 to implement measures to withhold certain information that are not needed by NGAs and other data users.  Further, the PSA is mandated to keep all CBMS data as the national repository of poverty data and shall need these data for official statistical purposes.

The PSA shall keep these datasets in electronic format with personal information in the National CBMS Databank permanently in order to achieve the objectives of the CBMS Act and for official statistics purposes.  LGUs will keep the datasets in electronic format for six (6) years or until such time these data are found to be of no use in poverty alleviation. But accomplished paper questionnaires will be retained, archived, and destroyed in accordance with PSA policy for retention of accomplished questionnaires.  As of 14 May 2022, the PSA policy for retention of accomplished paper questionnaires is two years. The National Archives of the Philippines shall be notified before the destruction of said paper questionnaires that were administered by PSA.

 

How the law protects your information

The Data Privacy Act of 2012[7] and the CBMS Act[8] serve as basis for the procedures in collecting and processing personal data through the CBMS, as well as sharing the CBMS data to its stakeholders.  These laws exist to ensure that the data you provide will be secure and safely managed.  These laws also provide for your rights as a data subject or a household respondent.

Given these laws, only those households whose respondents have signed the CBMS Form 3 will have their data shared with the NGA that provides social protection programs for them, as provided under Section 10 of RA No. 11315.  Otherwise, those data collected from households whose respondents have not signed the CBMS Form 3 will be processed only for purposes of generating aggregated statistics at the city/municipal and barangay levels.

Personal information of barangay, city and municipal LGU respondents shall also be kept confidential and shall be used only for follow-up/callbacks and reference of the PSA hired personnel for the geotagging exercise.

Oath of Privacy is also accomplished by PSA regular personnel, and PSA/LGU-hired enumerators and supervisors before they proceed to collect data using the CBMS applications and tools. Penalties will be applied according to the contract and based on pertinent laws that sanction negligence, breach of confidentiality of information, improper disposal, behavior with malicious intent, unauthorized access or the intentional breach, and unauthorized disclosure of CBMS data.

The PSA is established pursuant to RA No. 10625 or the Philippine Statistical Act.  The organization is primarily responsible for all national censuses and surveys, sectoral statistics, community-based statistics, consolidation of selected administrative recording systems, and compilation of national accounts. We value integrity in our work and handling information given to us by our data providers and respondents like you.  We also observe the highest standards of professional independence. With your support and participation in CBMS, we will be able to provide a precise status of the Filipino society and economy and contribute to evidence-based policies and programs.

The Philippine Statistical Act ensures that PSA personnel treat personal information from the censuses and surveys securely.  Any person, including parties within the PSA, who breach the confidentiality of information and use confidential information for profit will be held liable under the law.

 

Legal basis for processing your household data

Section 4(e) of RA No. 10173 states that the right of privacy does not apply to “information necessary in order to carry out the functions of public authority, which includes the processing of personal data for the performance by the independent agencies of their constitutionally and statutorily mandated functions.” Moreover, Section 12(e) of this Act states that the processing of personal information shall be permitted only if not otherwise prohibited by law, and when the processing is necessary to fulfill functions of public authority, which necessarily includes the processing of personal data for the fulfillment of its mandate.

In this regard, the PSA and LGUs shall process information in accordance with the CBMS Act and Philippine Statistical Act, and to achieve the objectives of these policies.

We shall also process data and redact information as necessary based on the needs of the NGAs, which will further process your data to identify possible beneficiaries for social protection programs. Per Section 9 of RA No.11315, NGAs shall use the data generated by the CBMS in prioritizing timely, relevant and much-needed social protection programs of government in areas identified to have the highest incidence of poverty.

 

Your rights as household respondent

Section 10 of RA No. 11315 recognizes that “the right to privacy of every respondent remains inviolable.” As a data subject or as a respondent to the household interview in CBMS, you may refuse to participate in the survey, refuse to answer any question or reveal any information at any point, or terminate data collection activities with no further action needed. You may choose to respond to the CBMS but opt not to share such information to NGAs with social protection programs.

You also have rights available to you under the Data Privacy Act of 2012. If you wish to exercise any of these rights, kindly send a message or letter to the PSA data protection officer and the city/municipal LGU data protection officer.

You have the right to be informed about the objectives of the CBMS, how we collect and will process your data.  You also have the right to be informed about what types of information will be collected from you and your household, and to whom will these data be shared. We usually issue press releases about CBMS online via the PSA website and social media pages.

You may also request access to your own household’s information from PSA and the LGU.  By sending a letter to PSA and LGU, you may also:

1. propose correction of an error in the personal information

2. suspend, withdraw or order the blocking, removal or destruction of personal information in the CBMS database intended for data sharing

3. be indemnified for any damages sustained due to such inaccurate, incomplete, outdated, false, unlawfully obtained or unauthorized use of personal information.

You can get further information on the rights as a data subject and the circumstances under which you can exercise them from the National Privacy Commission (NPC).

 

Personal information controllers

A personal information controller refers to a person or organization who controls the collection, holding, processing, or use of personal information, including a person or organization who instructs another person or organization to collect, hold, process, use, transfer or disclose personal information on his or her behalf. For the 2022 CBMS, the PSA and the city/municipal LGU are jointly the personal information controllers.

You can contact the PSA through:

Telephone number: (632) 8462-6600 locals 839, 833 and 834; (632) 8376-1909
E-mail address: info@psa.gov.ph; cbms@psa.gov.ph

 

For ease in transaction, you may reach the PSA regional and provincial offices through their published contact information in the PSA official directory. 

If you wish to reach the PSA Central Office, you may send a letter or visit:

Philippine Statistics Authority
PSA Complex, East Avenue
Diliman, Quezon City

 

How to contact the data protection officer

The PSA Data Protection Officer (DPO) is the official in-charge of monitoring the PSA’s compliance with the Data Privacy Act of 2012, its IRR, issuances by the NPC and other applicable laws and policies.  They provide the Community-Based Statistics Service and all operating units of the PSA with advice and guidance on how to best protect the information that we collect from censuses, surveys and other data collection tools.  They are involved in all the major decisions such as on privacy impact assessments and in data sharing.  You may contact the data protection officer of the PSA if you have any queries or concerns regarding PSA’s use of your data or wish to exercise any of your rights.

You can contact the PSA data protection officer through:

Telephone number: (632) 8938-5273
E-mail address: legal.staff@psa.gov.ph

Post:
Data Protection Officer
TAM Building, PSA Complex
East Avenue, Diliman
Quezon City, 1101

Note that each city/municipal LGU processing personal data is required by the Implementing Rules and Regulations (IRR) of the Data Privacy Act of 2012 to assign their own DPO. In our memoranda of agreement with these LGUs, the designation of a DPO is compulsory to ensure safe and secure management of CBMS data files. In this regard, you may reach each city/municipal LGU DPO for any concerns with your rights as a data subject or household respondent. The city/municipal LGUs are obliged to give information to the PSA on concerns raised by data subjects directly to them.

All other NGAs processing personal data are also obliged to assign a DPO pursuant to the IRR of the Data Privacy Act of 2012.  In this regard, please reach out to the DPOs of NGAs that further processed the CBMS data files if your concern pertains to their processing of CBMS data for the identification of program beneficiaries.  

 

CLAIRE DENNIS S. MAPA, Ph.D.
Undersecretary
National Statistician and Civil Registrar General              

 

[1] RA No. 11315, also known as the Community-Based Monitoring System Act, which was signed into law on 17 April 2019, mandates that the PSA shall serve as the lead agency in the implementation of the CBMS. Key functions of the PSA include the setting of standards, review, and development of data collection forms; capacitating the cities and municipalities in the collection of the poverty data at the local level; monitoring of data collection activities of the LGUs; act as the national repository of poverty data collected from the CBMS; and processing and generation of poverty statistics using CBMS data collected from the CBMS, among others. 

[2] Section 3(b) of RA No. 11315 also stipulates that the CBMS involves geotagging activities. “Geotagging refers to the process of adding metadata about government projects, households/housing units, service facilities, and natural resources to various media and of uploading to a web-based application. This enables the mapping of all areas in the Philippines and allows the government, the citizenry, and other stakeholders to check the progress of projects in real-time.”  The PSA through its Geospatial Management Division (GMD) “shall be in charge of the development and implementation of operational plans for the creation, continuous updating, and improvement of CBMS digital maps and data visualizations. It shall likewise manage and maintain the geospatial information system for CBMS.”

[3] Section 8. Storage and Access of Data.— The cities and municipalities are allowed to maintain their own CBMS database for use in local level planning and program implementation. The PSA shall receive and store all aggregated data gathered by the cities and municipalities to create a national CBMS databank of collated information. It shall undertake measures to ensure the integrity and safety of the gathered information against unnecessary leakage and access by unauthorized persons. Provinces shall have access to their respective local and territory-specific data.

[4] Section 9. Prioritizing Social Protection Programs.— The appropriate national government agencies shall use the data generated by the CBMS in prioritizing timely, relevant and much-needed social protection programs of government in areas identified to have the highest incidence of poverty.

[5] Anonymized datasets are household level or barangay level datasets without personally identifiable information.

[6] Examples of aggregate statistics include those presented in tables, figures/visualizations, maps and charts/graphs as totals, averages/means, ranges, percentages, etc.  No personally identifiable information will be in these aggregated statistics presentation formats.

[7] RA No. 10173, also known as Data Privacy Act of 2012, stipulates that “It is the policy of the State to protect the fundamental human right of privacy, of communication while ensuring free flow of information to promote innovation and growth. The State recognizes the vital role of information and communications technology in nation-building and its inherent obligation to ensure that personal data in information and communications systems in the government and the private sector are secured and protected.”

Corollary to the above, Section 19 of RA No. 10173 states that “the personal information shall be held under STRICT CONFIDENTIALITY and shall be used only for the declared purpose. Likewise, the provisions on data privacy are not applicable to processing of personal information gathered for the purpose of investigations in relation to any criminal, administrative or tax liabilities of a data subject.”

[8] Section 10 of RA No. 11315 recognizes that “the right to privacy of every respondent remains inviolable. The citizen participating in the data collection shall be fully informed of the nature and extent of processing intended for his or her personal data. Participation in all data collection activities is purely voluntary. Notwithstanding Section 4 of this Act, respondents may refuse to answer any question or reveal any information at any point or terminate data collection activities with no further action needed.”