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Crime and Risk in the Philippines

Data Privacy

BCC Group of Companies and CAT Security Group Privacy Statement

Welcome to BCC Group of Companies and CAT Security Group's Privacy Statement, where the terms "we," "us," and "our" refer to BCC Group of Companies and CAT Security Group. Clients, vendors, partners, employees, and other stakeholders of BCC Group of Companies and CAT Security Group are referred to as "you" and its derivatives.

This Privacy Statement addresses both our privacy practices and our entire approach to protecting the Personal Data that you provide to us. This supplemented the Privacy Notice, which is available at specific data collection methods, offers a more detailed information about the categories of Personal Data we collect, the purpose and extent of their processing, and the safeguards in place to protect them.

BCC Group of Companies and CAT Security Group value personal data confidentiality, respect your data privacy rights, and adhere to the Data Privacy Act of 2012.

We make every effort to ensure that all personal data collected from clients, vendors, employees, and other stakeholders are managed and processed in accordance with the general data privacy principles.

Transparency

Transparency is essential for developing trust with you. As such:

We will provide you with clear and accessible information in the form of a Privacy Notice that describes:

• Your collected and processed Personal Data;
• The purpose and legal basis for processing;
• How we safeguard your Personal Data;
• Your rights as a data subject; and
• Contact details for privacy concerns

Except as required by law, you will be provided an option to enable us to process your Personal Data.

When your consent is required to legitimately handle Personal Data, we will ask you to read the Privacy Notice and express your consent before collecting and processing your Personal Data.

Legitimate Purpose

We will only use your Personal Data for legitimate reasons that do not violate the law, morality, or public policy. Furthermore, your Personal Data will only be processed if one or more of the following lawful processing exist:

• You willingly provided your express consent;
• Processing is required to fulfill our relationship with you;
• Processing is required for us to comply with legal obligation;
• Processing is required to safeguard your vital interests;
• Processing is required to maintain public order and safety; or
• Processing is required for us to pursue our legitimate business interests.

Proportionality

We shall only process your Personal Data in proportion to the clear, stated, and reasonable purpose for which it was collected.

• We shall only collect your Personal Data in methods that are appropriate and not excessive to the purposes for which it was obtained.
• We shall only use, share, and retain your Personal Data as necessary to fulfill our purposes.
• Your Personal Data will be securely disposed of after the purposes have been fulfilled, unless we are compelled to store them for legal reasons;
• We shall limit access to your Personal Data to authorized personnel. This access is limited to what is required to fulfill our purpose.

Your Rights as a Data Subject

We respect your rights as a data subject, which are outlined in the DPA as follows:

• You have the right to access the information we have on file for you, subject to supplying us with valid identification. To the extent authorized by law, we may withhold personal data that you request.
• You have the right to object to us using your Personal Data for profiling you or making automated decisions about you.
• You have the right to transfer your data in a manner that is mutually agreeable.
• You have the right to have your data deleted by requesting that we suspend, withdraw, remove, or destroy your Personal Data if we no longer need it for the indicated objectives which also includes appropriate legal purposes.
• You have the right to lodge a complaint about our use of Personal Data. However, please notify us first so that we can resolve your concerns. If we fail to meet your expectations, you may file a complaint with the National Privacy Commission.
• You have the right to be indemnified if your personal data is inaccurate, incomplete, false, unlawfully obtained, or used unauthorizedly.

Accountability

We will be accountable for adequately safeguarding your Personal Data in order to avoid its abuse and subsequent harm.

• We analyze the risks of systems that handle your Personal Data using our Internal Quality Audit while we follow the requirements of ISO 9001:2015 and employ suitable security measures to secure them.
• In the event that we outsource, subcontract, or share your Personal Data with any company in order to achieve the purposes stated herein, we:
• Limit their processing to what is absolutely necessary for the stated reasons;
• Require them to give the same level of privacy protection; and
• Evaluate their compliance in offering these safeguards.
• When a data breach occurs, we will take quick action to avoid additional harm and will notify you of the situation.

Personal Data We Collect

Personal data is defined as information that may be used alone or in conjunction with other information to identify, contact, or locate a specific person or an individual in context.

Ways we collect your Personal Data

We may collect and store your Personal Data in a variety of ways:

• When you use any of our products and avail security services.
• When you communicate with our Client Development team by email, phone, or in-person meetings.
• When you submit information via manual forms and online forms on our digital assets (i.e. websites, applications), or when you contact us via social media (e.g., Facebook)
• When you register for, utilize, or maintain our digital platforms, including mobile apps.
• When you visit our premises that are equipped with CCTV surveillance cameras for the protection and security of our clients, guests, and employees.
• When you disclose Personal Data in response to inquiries, requests, or complaints.
• When you participate in surveys, promotions, and other marketing activities.
• When submitting a job application.
• When other parties or business partners refer you to us.
• When you provide us with your Personal Data for any other reason.

Uses of Personal Data

General uses of your Personal Data

We may utilize your Personal Data for various legitimate reasons and business purposes. Among the general uses are:

Providing you with the product and services, including client service that you have requested.

Improving your client experience by providing product services that correspond to your preferences and demands.

Providing appropriate products and services, as well as advice and response to your questions, requests, and concerns.

Complying with legal requirements, such as court orders and legal proceedings; averting immediate danger to the public; and guaranteeing public security, safety, and order.

Crime prevention, detection, and investigation.

Other commercial risks are being assessed and managed; and

Information processing for statistical, analytical, and research purposes.

When you are a vendor, prospective vendor, or contractor

• Conducting adequate due diligence checks.
• Evaluating your proposal and doing the necessary background checks.
• Evaluating your vendor viability and processing your accreditation.
• Communicating with you about our products and services.
• Other acts required or desired in the execution of our contract.

When you apply for employment or become our employee

• Conducting necessary background checks, reference checks, pre-employment medical exams, and interviews;
• Communicating your candidacy's status;
• Processing of your pay, allowances, and expense reimbursement, as well as tracking your attendance and leaves;
• Enrolling in our benefit programs, such as health insurance, medical insurance, a retirement plan, and social security;
• Helping you advance professionally through performance management, career development, seminars, workshops, and training;
• Making you a part of our employee engagement activities and initiatives, such as events, employee surveys, and bonuses and discounts available with management approval;
• Complying with our legal commitments as mandated by government organizations and local government entities; and
• Facilitating your departure interview, clearances, and other processes required to process your final pay once you leave the company.

Disclosure of Personal Data with Other Parties

Fulfillment of Legitimate and Business Purposes

We may share your Personal Data to the following parties in order to accomplish the specified purpose/s to which you consented:

• Our Employees and Internal Quality Auditors;
• Members of BCC Group of Companies and CAT Security Group;
• Banks and their respective service providers;
• Suppliers or subcontractors, third-party service providers, consultants hired by us to provide financial, and support services such as information technology, payroll, accounting, procurement, training, background investigation, and other services.

Retention and Disposal of Your Personal Data

We shall retain physical documents containing your Personal Data (including electronic documents):

• To the extent that we are required by law to do so;
• To the extent necessary or in accordance with our contract; and
• If we believe the documents may be relevant to any existing or future legal actions to establish, exercise, or defend our legal rights, we may request them (including providing information to others for purposes of fraud prevention).

How we safeguard your Personal Data

We also put in place protections such as:

• Utilization of secure servers behind modern threat prevention appliances, firewalls, encryption, and other security solutions;
• Access to your Personal Data is restricted to those who are qualified and authorized to process it. All such individuals, regardless of where they are based, are obligated to maintain the security and privacy of your Personal Data in accordance with our privacy policies and procedures; and
• Our information systems and infrastructure are subjected to vulnerability assessment and penetration testing to guarantee that your Personal Data is adequately safeguarded.

Management and Security

BCC Group of Companies and CAT Security Group is committed to regularly reviewing, monitoring, and improving its Privacy Management Program.

To that end, we have a designated Data Protection Officer for our companies to oversee and secure the handling of your Personal Data in accordance with the Data Privacy Act of 2012 and this Privacy Statement.

Personal Data breaches are taken extremely serious by BCC Group of Companies and CAT Security Group, and mechanisms are in place to deal with them.

Surveillance Camera Policy

We deploy a CCTV system to capture photographs and videos of employees, applicants, and visitors in order to monitor security, crime, and emergency occurrences or situations on our premises. The CCTV data is maintained in secured locations and is accessible only to authorized employees for lawful purposes. It may also be shared with competent authorities for investigative purposes.

Individuals recognized on the CCTV system have the right to request access to footage, subject to confirmation and permission by the management of BCC Group of Companies and CAT Security Group

Updates to the Privacy Statement

We will amend this Privacy Statement from time to time as part of our efforts to secure and ensure the security and protection of your Personal Data. We may also amend this Privacy Statement to reflect changes in the Data Privacy Act of 2012, as well as changes in our business operations. Any updates will be displayed with a date stamp on our website so that you are informed of the latest update.

Contact Us

If you have any comments, questions, or requests about this Privacy Statement, or if you have any concerns about your rights under this Privacy Statement, please send your inquiries addressed to the following:

Aldous James B. Tanyag, CDPO
Data Protection Officer
Data Privacy and Protection
Email: DPO@bccgroup.com.ph
Mobile No.: +639178312336
Local: 1122

This Privacy Statement was last updated on March 03, 2023 at 10:15AM.