To set privacy measures to a maximum and better ensure the safety of data subjects, the National Privacy Commission (NPC) said it will now pseudonymize names in cases it publishes on its website.
This is enforced through the NPC’s issuance in June of Advisory 2020 – 01 or the “Protocols for the Publication of Decisions, Resolutions and Orders on the NPC Website.”
The advisory specifically prohibits the disclosure of complete names of data subjects in a case and orders that pseudonymized initials replace the names instead. In cases where the mention of the address is material, only the province or city shall be cited.
To pseudonymize something is to anonymize or replace it with artificial identifiers.
“Publishing our cases to the public not only promotes transparency but also contributes in educating the public of data privacy. However, to better perform our mandate of protecting data subjects, we found the need to further sanitize published case decisions of personal information that distinctly identify a data subject,” NPC commissioner Raymund E. Liboro said.
“This will prevent any possible safety risks posed by the disclosure of personal information,” he added.
In addition to pseudonymizing published cases, the NPC will also limit the publication of cases, orders, and resolutions that have not been disposed with finality.
Specifically, these cases include:
- Those decided on the basis of compromise agreements, mediated settlement agreements, quitclaims and other modes of alternative dispute resolutions, as these are not decided on the basis of merit and therefore lack teaching value for the public.
- Interlocutory decisions, orders and resolutions that do not dispose of the case or breach notification with finality.
- Decisions, orders and resolutions that may be subject of a motion for reconsideration, unless the reglementary period to file such has lapsed.
Notwithstanding the enumeration of unpublishable cases, the guidelines still provide the NPC its own discretion to publish certain decisions, orders, and resolutions where public or educational interests prevail.