Privacy Policy & Employee Privacy Notice
Last updated: November 2026. This policy outlines how employee personal data is collected, processed, and safeguarded across the Islatel HRIS platform.
1. Information We Collect
In our capacity as a Personal Information Controller (PIC), we collect and process employee personal and sensitive personal information strictly required for employment administration and Philippine statutory compliance:
- Personal 201 Identifiers: Full legal name, residential address, personal contact details, civil status, date of birth, emergency contact information.
- Government Identification (SPII): Social Security System (SSS) number, PhilHealth ID, Pag-IBIG (HDMF) number, and Tax Identification Number (TIN).
- Attendance & Shift Data: Biometric timeclock punch timestamps (In/Out), scheduled shift rosters, approved Official Business (OB) slips, and leave records.
- Compensation & Financials: Daily wage rates, basic salary, bank account details for payroll disbursement, overtime records, and cash advance balances.
2. Lawful Basis for Processing
Under Sections 12 and 13 of Republic Act No. 10173, the processing of employee personal information by the employer is legally justified without separate consent when:
- Processing is necessary for the fulfillment of the employment contract (attendance tracking, compensation computation, shift management).
- Processing is necessary for compliance with legal and statutory obligations (mandatory employer contributions and tax withholdings under SSS, PhilHealth, Pag-IBIG, and the National Internal Revenue Code).
3. Data Security & Cryptographic Safeguards
We implement defense-in-depth organizational, physical, and technical controls to protect records against unauthorized disclosure, alteration, or theft:
- AES-256-CBC Encryption: Sensitive government IDs and bank account numbers are encrypted at rest with industry-standard 256-bit symmetric encryption.
- Default UI Masking: Sensitive numbers are masked by default (`•••• •••• 1234`) and require explicit authorized actions to reveal.
- PostgreSQL Row Level Security (RLS): Enforces strict multi-tenant boundaries at the database engine level, preventing any cross-tenant data leakage.
- Wage Privacy Controls: Authorized executives (Admin, HR, Group HR, GM) can toggle compensation masking (`₱•••••`) during operational meetings and screen-shares. Team Leaders can view the overall roster plan across all departments, but are strictly restricted from seeing individual salaries or member wages.
4. Data Retention & Offboarding
Under Rule X, Book III of the Philippine Labor Code, employers are required to preserve payroll records and daily time registers for at least three (3) years for DOLE verification.
Following resignation or termination, former employees maintain secure, read-only mobile access to their historical payslips for thirty (30) calendar days, after which the account is permanently archived and deactivated.
5. Employee Rights Under RA 10173
Employees retain all statutory rights granted under the Data Privacy Act:
- Right to be Informed: To know the purpose, scope, and methods of personal data processing.
- Right to Access: To inspect personal 201 profile records, attendance logs, and generated payslips via the Employee Self-Service portal.
- Right to Rectification: To request immediate correction of inaccurate or outdated contact, emergency, or personal information.
6. Data Protection Inquiries & Breach Escalation
In the event of a verified security incident or data breach involving personal identifiers, the organization adheres strictly to the 72-hour notification protocol established by National Privacy Commission Circular 16-03.
For data privacy inquiries, corrections, or exercise of data subject rights, employees may contact the appointed Data Protection Officer (DPO) or Human Resources Department.
