Privacy Notice for use of Dashboard Cameras in Company Vehicles and Closed Circuit Television (CCTV) Cameras

This Privacy Notice informs your organization about PRIMEX’s policy regarding the data that we collect, use, or otherwise process – your personal data.

PRIMEX commits to keeping the personal data of the members of your organization private and protected. We respect your right to privacy and aim to comply with the requirements of all relevant privacy and data protection laws, particularly the Data Privacy Act (DPA) of 2012. As in the case of the National Privacy Commission (NPC), we also seek to protect the personal privacy of the members of your organization and the free flow of information, especially when pursuing our legitimate interests and when necessary to carry out our responsibilities as a management consulting firm.

Information We Collect, Acquire, or Generate

We collect, acquire, or generate your personal data in many forms. These may consist of written records, photographic and video images, digital material, and even biometric records.

When you provide your personal and sensitive information, we collect, among others: (1) directory information, like your name, email address, telephone number, and other contact details; (2) data about your personal and professional background, such as your employment history and other relevant circumstances, previous schools attended, and academic performance; and (3) and any or all information obtained through interviews and/or during verbal conversations as well as video imagery captured via dashboard cameras placed in company vehicles and CCTV cameras placed in various locations in the PRIMEX office.

How We Use Your Information

To the extent permitted or required by law, we use your personal data to pursue our legitimate interests as a management consulting firm, including a variety of procurement activities and/or purposes of project activities. For example, we may use the information we collect for the following purposes, among others:

  1. Preparation of incident reports for documentation for reports required by law enforcement agencies in cases of vehicle accidents and threats to privacy and security of PRIMEX personnel;
  2. Support documentation for PRIMEX’s records and directory of suppliers, third party service providers and associates;
  3. Compiling and generating reports for statistical and research or contractual purposes; and
  4. Sharing marketing and promotional materials in corporate functions, events, projects, and activities.

We consider the processing of the personal data of the members of your organization for these purposes to be necessary for the performance of our contractual obligations to you, for our compliance with a legal obligation, to protect your vitally important interests, and, for the performance of tasks we carry out in the public interest (e.g., public order, public safety, etc.), or for the pursuit of the legitimate interests of PRIMEX or a third party.
We understand that the DPA imposes stricter rules for the processing of sensitive personal information and privileged information, and we are fully committed to abiding by those rules.
If we require your consent for any specific use of your personal data that is not mentioned in the purposes above, we will collect it at the appropriate time.
Please note further that we will not subject any personal data to any automated decision-making process without your prior consent.

How We Share, Disclose, or Transfer Your Information

To the extent permitted or required by law, we may also share, disclose, or transfer your personal data to other persons or organizations to uphold your interests and/or pursue our legitimate interests as a management consulting firm. For example, we may share, disclose, or transfer your personal data for purposes such as:

  • Reporting and/or disclosure of information to the NPC and other government bodies or agencies; and
  • Complying with court orders, subpoenas, and/or other legal obligations.

How We Store and Retain Your Information

The personal data of the members of your organization are stored and transmitted securely in a variety of paper and electronic formats, including databases that are shared between PRIMEX’s different units or offices. Access to personal data is limited to PRIMEX personnel who have a legitimate interest in them for the purpose of carrying out their contractual duties. Rest assured that our use of your personal data will not be excessive.

Unless otherwise provided by law or by appropriate company policies, we will retain relevant personal data for a period of 10 years for historical and statistical purposes. Where a retention period is provided by law and/or a company policy, all affected records will be securely disposed of after such period.

Your Rights with Respect to Your Personal Data

We recognize your rights with respect to your personal data, as provided by the DPA. If you wish to exercise any of your rights, or should you have any concern or question regarding them, this Notice, or any matter involving the PRIMEX and data privacy, you may contact the company’s Data Protection Officer at:
Email: dpo@primexinc.org
Landline: +63 2 86339052
Website: www.primexinc.org
Address: 502 & 504 Manila Luxury Condominium, Pearl Drive, Ortigas Center, San Antonio, Pasig City, Philippines 1600