Privacy Policy

1. Introduction

The City Government of Davao ("the City" or "we"), through Project Doctrack and its integrated digital systems, is firmly committed to upholding the highest standards of data privacy and security in accordance with Republic Act No. 10173, also known as the Data Privacy Act of 2012, and its Implementing Rules and Regulations.

This Privacy Policy serves as a comprehensive disclosure of our data processing activities, delineating the manner in which personal and sensitive personal information is collected, processed, stored, disclosed, and disposed of across all systems developed and maintained under the City Internal Operations Unit (CIOU). This Policy reflects our commitment to transparency, accountability, and the protection of data subject rights.

2. Scope and Coverage

2.1 Applicability

This Privacy Policy applies comprehensively to all information systems, digital platforms, and applications developed, maintained, and operated by the City Internal Operations Unit (CIOU) under Project Doctrack, including but not limited to:

• Document Tracking System (Doctrack)
• City Supplier Registry
• SuRA and Supplier Randomizer
• City Infrastructure Monitoring System
• CEMA (City Employee Mobile Application)
• DocMobile
• City Inventory Tracker (CIT)
• City Asset Tracking System (CATS)
• Project Cleansing
• Checkerist System
• Taxifier
• BACTrack
• City Analytics and Monitoring Portal (CAMP)

2.2 Data Subjects

This Policy applies to all natural persons whose personal information is processed by our systems ("Data Subjects"), including but not limited to:

• City Government Employees: All regular, contractual, and casual employees
• Suppliers and Contractors: Business owners, representatives, and authorized signatories
• System Users: Authorized personnel accessing any covered system
• Third-Party Stakeholders: External parties whose information is processed in relation to City operations

2.3 Definitions

For purposes of this Policy, the following terms shall have the meanings ascribed to them:

• Personal Information: Any information from which the identity of an individual can be reasonably and directly ascertained, or when put together with other information would directly and certainly identify an individual.
• Sensitive Personal Information: Personal information about an individual's race, ethnic origin, marital status, age, color, religious, philosophical or political affiliations, health, education, genetic or sexual life, or any proceeding for any offense committed or alleged to have been committed.
• Processing: Any operation or set of operations performed upon personal information including collection, recording, organization, storage, updating, retrieval, consultation, use, consolidation, blocking, erasure, or destruction.

3. Personal Information Collection and Processing

3.1 Legal Basis for Processing

We process personal information based on the following lawful grounds:

• Legal Obligation: Compliance with laws, regulations, and government mandates including COA circulars and directives
• Performance of Public Authority: Exercise of official functions vested in the City Government
• Legitimate Interests: Necessary for the proper administration of government operations and public service delivery
• Consent: Where explicitly provided by the data subject for specific processing activities

3.2 Categories of Personal Information Collected

The following categories of personal and sensitive personal information may be collected and processed:

• City Government Employees:
  • Basic identification data (full name, employee number, contact information)
  • Employment information (position, office assignment, employment status, work history)
  • Compensation data (salary grade, allowances, deductions)
  • Biometric data (photographs, facial recognition for authentication)
  • Transaction and activity logs within City systems
  • Performance evaluation records
• Suppliers and Contractors:
  • Business registration details and corporate information
  • Tax identification numbers and compliance certificates
  • Business permits and licenses
  • Contact information of authorized representatives
  • Performance history and evaluation records
  • Financial and banking information (for payment processing)
  • Eligibility and qualification documents
• System Users and Administrators:
  • User credentials and authentication data
  • IP addresses and device information
  • System access logs and timestamps
  • Activity history and audit trails
  • Submitted forms, feedback, and communications

3.3 Purpose of Processing

Personal information is processed exclusively for the following legitimate purposes:

• Facilitate efficient and transparent internal government operations
• Ensure regulatory compliance with Commission on Audit (COA) requirements
• Support accountability, monitoring, and reporting mechanisms
• Enable secure authentication and access control
• Process payroll, procurement, and financial transactions
• Maintain accurate records and documentation as required by law
• Generate statistical reports and analytics for operational improvement
• Respond to inquiries, feedback, and service requests

4. Data Sharing, Disclosure, and Access Control

4.1 Internal Access

Access to personal information is governed by the principle of least privilege and is strictly limited to authorized personnel on a need-to-know basis. Role-based access controls ensure that users can only access information necessary for the performance of their official functions.

4.2 Internal Data Sharing

Personal information may be shared among authorized City Government offices and departments for legitimate operational purposes, including but not limited to:

• General Services Office (GSO) – for asset and inventory management
• City Accounting Office – for financial processing and disbursement
• City Budget Office – for budget preparation and monitoring
• Bids and Awards Committee (BAC) – for procurement processes
• City Engineering Office – for infrastructure monitoring and management
• Human Resource Management Office – for personnel administration
• City Mayor's Office and Executive Offices – for reporting and decision support

4.3 External Disclosure

Disclosure of personal information to external parties is strictly prohibited except in the following circumstances:

• When required by law, regulation, or valid court order
• To comply with audit requirements of government oversight agencies (e.g., COA, CSC, DBM)
• When necessary for law enforcement or legal proceedings
• With the explicit written consent of the data subject
• In anonymized or aggregated form that does not permit identification of individuals

In all cases of external disclosure, only the minimum necessary information shall be shared, and appropriate data sharing agreements or memoranda of understanding shall be executed where applicable.

5. Data Security and Protection Measures

The City implements appropriate organizational, technical, and physical security measures to protect personal information against unauthorized access, accidental loss, destruction, alteration, or disclosure. These measures include:

5.1 Technical Safeguards

• Encryption: Implementation of industry-standard encryption protocols for data at rest and in transit
• Access Controls: Multi-factor authentication and role-based access control (RBAC) systems
• Network Security: Firewalls, intrusion detection systems, and secure network architecture
• Audit Logging: Comprehensive activity logging and real-time monitoring of all data access and modifications
• Biometric Authentication: Photo verification and facial recognition where applicable (e.g., CEMA)
• Secure Development: Application of secure coding practices and regular security assessments

5.2 Organizational Safeguards

• Privacy Training: Mandatory data privacy awareness and training for all personnel
• Confidentiality Agreements: Execution of non-disclosure and confidentiality agreements
• Incident Response: Established protocols for data breach detection, response, and notification
• Privacy Impact Assessments: Regular evaluation of privacy risks for new systems and processes
• Third-Party Management: Due diligence and contractual safeguards for service providers

5.3 Physical Safeguards

• Controlled access to server rooms and data storage facilities
• Environmental controls and disaster recovery infrastructure
• Secure disposal procedures for physical and electronic media

6. Rights of Data Subjects

In accordance with the Data Privacy Act of 2012, data subjects are afforded the following rights:

6.1 Right to Be Informed

Data subjects have the right to be informed whether their personal information is being, has been, or will be processed, including the purpose, scope, recipients, and retention period.

6.2 Right to Access

Data subjects have the right to reasonable access to their personal information upon reasonable notice, and to obtain copies thereof in a structured, commonly used, and machine-readable format.

6.3 Right to Object

Data subjects have the right to object to the processing of their personal information, including processing for direct marketing, automated processing, or profiling, subject to legal limitations.

6.4 Right to Rectification

Data subjects have the right to dispute the inaccuracy or error in their personal information and have the City correct such inaccuracy or error immediately, unless the request is vexatious or unreasonable.

6.5 Right to Erasure or Blocking

Data subjects have the right to suspend, withdraw, or order the blocking, removal, or destruction of their personal information from the City's filing systems upon discovery and substantial proof of:

• Incomplete, outdated, false, or unlawfully obtained data
• Data being used for unauthorized purposes
• Data no longer necessary for the declared and specified purpose
• Withdrawal of consent or expiration of consent

6.6 Right to Damages

Data subjects have the right to be indemnified for any damages sustained due to inaccurate, incomplete, outdated, false, unlawfully obtained, or unauthorized use of their personal information.

6.7 Right to Data Portability

Data subjects have the right to obtain and reuse their personal information for their own purposes across different services, where technically feasible.

6.8 Right to File a Complaint

Data subjects have the right to lodge complaints before the City Data Protection Officer or the National Privacy Commission regarding alleged violations of their data privacy rights.

6.9 Exercise of Rights

To exercise any of these rights, data subjects may submit a written request to the City Data Protection Officer using the contact information provided in Section 10 of this Policy. Requests will be processed within fifteen (15) calendar days from receipt, subject to extension for complex requests.

7. System-Specific Data Handling

a. CEMA

Collects personal photo and employee number for account verification used for payroll and feedback.

b. City Supplier Registry

Stores registration documents and eligibility credentials for compliance monitoring.

c. Doctrack

Public-facing portal shows only essential transaction data (e.g., tracking number and status).

8. Data Retention and Disposal

8.1 Retention Period

Personal information shall be retained only for as long as necessary to fulfill the declared, specified, and legitimate purposes for which it was collected, or as required by applicable laws, regulations, and government retention schedules.

8.2 Retention Guidelines

• Employee Records: Retained in accordance with Civil Service Commission guidelines and COA retention schedules
• Financial Records: Retained for a minimum period as prescribed by COA and applicable accounting regulations
• Transaction Logs: Retained for audit and security purposes, typically not less than five (5) years
• Supplier Records: Retained for the duration of the business relationship and prescribed retention periods thereafter

8.3 Secure Disposal

Upon expiration of the retention period, personal information shall be disposed of in a secure manner that prevents unauthorized access, reconstruction, or retrieval. Disposal methods include:

• Secure deletion and overwriting of electronic data
• Physical destruction of storage media (shredding, degaussing, incineration)
• De-identification or anonymization where archival preservation is required

Disposal activities shall be documented and subject to verification by the Data Protection Officer.

9. Data Breach Notification

In the event of a personal data breach that is likely to result in risk to the rights and freedoms of data subjects, the City shall:

• Notify the National Privacy Commission within seventy-two (72) hours from knowledge of the breach
• Notify affected data subjects without undue delay when the breach is likely to result in high risk
• Document all data breaches, including facts, effects, and remedial actions taken
• Implement immediate containment and remediation measures

Notifications shall include a description of the nature of the breach, the categories and approximate number of data subjects affected, the likely consequences, and measures taken or proposed to address the breach.

10. Policy Review and Updates

This Privacy Policy is subject to periodic review. Updates will be communicated through official channels.

12. Acknowledgment and Consent

By accessing and using any of the systems covered by this Privacy Policy, data subjects acknowledge that they have read, understood, and agreed to the terms and conditions set forth herein. For processing activities requiring explicit consent, separate consent mechanisms are implemented within the respective systems.