Privacy Statement for prospective, active, and separated employees, as well as on-the-job trainees
We value the privacy of our employees and their dependents as well as our job applicants, on-the-job trainees and retirees. We collect and maintain their personal data in connection with our prospective, active, and previous contracts with them, whether for employment or training agreements. We ensure that their information are up-to-date and kept confidential even until their separation from Meralco.
We collect your personal data in the course of, or incidental to the conduct of, our business with you. These data include any other information that you voluntarily provide to us for any legitimate purpose declared at the point of collection as well as information about you that we received from third parties and other sources where the disclosure was subject of a consent that you gave separately or a legal requirement.
We will be collecting the following information from you:
Information you submit when you apply at MERALCO for work or training, including what is contained in your resume or curriculum vitae and application form (e.g., work references);
Information we collect during the processing of your application, such as testing results, employment offer, results of character investigation, and pre-employment medical assessment;
Information we collect and maintain during your employment, such as your personal information, addresses, education records, professional licenses and permits, and government-issued identification information; payroll information, including but not limited to government mandated and third party remittances like SSS, Philhealth, and Pag-ibig membership and contributions, taxes, bank account information; wages; entitlements and benefits; medical and dental care records; emergency contact information; training and certifications; performance evaluation; sanctions; and employment changes / work history;
Information we collect and maintain to facilitate your use of tools, equipment, and software that are related to the performance of your duties and responsibilities; to assist you in any work-related issues that you may encounter as you perform your duties and responsibilities, including troubleshooting of technical problems; to develop ways to improve your work conditions, such as automation of transactions and processes;
Information you provide about your dependents/beneficiaries for purposes of but not limited to administration of health maintenance plan, insurance claims, or profiling;
Information you provide when you participate in our surveys related to internal business processes, such as but not limited to employee engagement events, sustainability efforts, post-training assessments, climate surveys;
Information we retain after your separation from service, such as but not limited to pension information, retiree eligibilities and other benefits, bank account information, addresses, beneficiaries, and emergency contact information; and
Information we may record as you perform your duties and responsibilities, strictly limited to photos and videos of you in the workplace or in other Meralco-sponsored programs that contain your image or voice.
We store, process, and/or analyze the personal data collected for some legitimate purpose, related or incidental to the conduct of our business, including maintaining safety and security within the Company premises.
Specifically, we may store, process, and/or analyze your personal data for the following and any other legitimate purposes related to the fulfillment thereof:
To handle your application for employment or training. We process your personal data to evaluate your eligibility for employment or training, including the verification of your qualifications, employment history, and character references (background checking);
To manage our employer-employee or training relationship. We process your data to maintain your employment, on-the-job training and/or personal records, including your contact information, for operational or administrative efficiency. Specifically for employees, we collect, store, and process your data to administer your pay, statutory and salary deductions, entitlements, and benefits, and those of your dependents or beneficiaries, to conduct your performance reviews and grant rewards, to establish appropriate training and/or developmental interventions including your membership with professional or industry organizations, to monitor your work performance and use of company resources, and to conduct internal investigation and/or administer disciplinary action and sanction as necessary.
To address or enforce legal claims or obligations arising from employment contract or training relationship. We process your data to comply with applicable statutory and regulatory requirements and submissions, including the processing of your work or labor-related claims (e.g. worker compensation, insurance claims, etc.). Your personal data may also be processed to enforce our claims or defend our rights in any proceeding arising from our relationship.
To improve your welfare, productivity, safety, and security at work. We process your data to develop your health and wellness programs, including provision of your medical benefits; to conduct employee engagement activities; to create and maintain user accounts that serve as your personalized work credentials and access rights; and to facilitate and maintain overall productivity, safety, and security in the workplace and in all business operations. We also facilitate the payment of your donation to foundations or charitable institutions through deduction from your payroll account and implement corporate social responsibility and other Company programs or events.
To maintain our post-employment relationship. We process your data to administer your pension, retiree eligibilities and other benefits.
To prepare publications that feature Meralco. We process your images or voice that we may have recorded in the workplace or during your participation in Meralco-sponsored activities to give the general public previews on the work culture and workplace environment in Meralco.
1Data Subject - Prospective, active, and separated employees, as well as on-the-job trainees
2 As needed / as applicable
3 When applicable, data sharing or outsourced processes are covered by DSA, NDA, and/or OAs
4Engagement – Engagement - Onboarding, company activities, duties and responsibilities as a Meralco employee, payroll, filing of government mandatories (BIR, DOLE, etc.), benefits processing, etc.
Note: Privacy Notice is process specific while the Privacy Statement is a public commitment to data privacy
Employees, Authorized Representatives, Trainees, and Consultants
We ensure that our employees and trainees commit to observe the privacy policies of the Company. We require our Authorized Representatives and Consultants to sign a Non-Disclosure Agreement (NDA), to ensure that they process your data confidentially in a manner consistent with the purpose of their employment or engagement.
Contractors, and Business Partners, including Auditors
We require our contractors, subsidiaries, and business partners, through a Data Processing, Data Sharing, or Outsourcing Agreements, as applicable, and/or Non-Disclosure Agreement (NDA), to secure and keep your data confidential. We take your privacy seriously so punitive or legal action will be initiated in case of proven misdeed. Moreover, we do not allow our contractors, subsidiaries, and business partners to disclose or share your data to others, or to use it for their own purposes, without your consent.
Your information may also be disclosed to government entities pursuant to and in compliance with applicable laws and regulations, subpoena or court order.
Unless you provide specific consent or except in instances allowed under the DPA, we will not:
Share your personal data with our business partners and other third parties for their own commercial purpose or benefit;
Use your personal data to enable third-party targeted advertisements which are not related to our business.
In case data sharing, including cross-border transfer, is allowed, we shall ensure the protection of your data through appropriate Data Sharing Agreements and commit to give you prior notice to any such transfer and processing of your data.
We are committed to ensure the integrity, confidentiality, availability, and security of your information. We implement reasonable organizational, physical, and technical security measures in collecting, processing, transmitting, storing, and disposing your personal data such as using secure servers, firewalls and security controls and ensuring regular conduct of audit and testing of our security protocols.
For an enhanced online experience, our services are available through compatible devices, such as laptops, PCs, tablets, and mobile phones. For your added security, we recommend that you install anti-virus software on any such device before accessing the internet.
You are responsible for the security of your information once it reaches you or your representative in any medium, including but not limited to written correspondences, bills, emails, system applications, and on-line accounts. You should take appropriate measures to ensure that any medium or device you use to monitor or manage your account is secure and not accessible to anyone without permission.
We keep your personal data only for as long as necessary:
for the fulfillment of the declared, specified, and legitimate purposes provided above, or when the processing relevant to the purpose has been completed or terminated;
for the establishment, exercise, or defense of legal claims; or
for other business purposes, that are consistent with standards established or approved by regulatory agencies governing Meralco.
Thereafter, your personal data shall be disposed of or discarded in a secure manner that would prevent further processing, unauthorized access, or disclosure to any other party or the public.
Since the outbreak of the coronavirus disease in 2019 (COVID-19), Meralco has actively cooperated and coordinated with government authorities in containing the spread of the virus and ensuring the safety and well-being of the persons it services, employs, and otherwise transacts with. The occupational safety of its employees and the general well-being of its data subjects are now among the primary concerns of Meralco, which prompted the Company to formulate policies and develop solutions for health monitoring of all its data subjects, as necessary. In collecting health information from its data subjects, Meralco shall always inform them about why, how, and where they will be used and shared, as discussed below.
We will be collecting the following health information from you as well as other relevant information:
Information you provide in Health Declaration Forms and Contact Tracing Forms as required by the Department of Trade and Industry (DTI) and Department of Labor and Employment (DOLE) Joint Memorandum Circular (JMC) No. 20-04-A Series of 2020, such as your full name, complete address, mobile or phone number, email address, signature, symptoms declaration, COVID-19 exposure, and travel history
Information you provide in interviews to determine close contacts of a probable or confirmed COVID-19 case; and
Information you provide for the provision of COVID-19 vaccine and health advice, including prescription of medicines, related to the treatment of the effects of COVID-19 or other infectious diseases such as your full name, complete address, age, sex, birthdate, civil status, contact number, employment information, and your health conditions.
We store, process, and/or analyze your personal data for the following purposes:
To conduct effective contact tracing and prevention and management of the spread of the disease in the workplace
To assist the government in providing effective response during the COVID-19 pandemic including case investigations, treatment, and control and containment
To provide accurate and timely health information about notifiable diseases, and health-related events and conditions; and
To provide health-related benefits and services such as check-ups and consultations, vaccines, and leaves and other entitlements.
DTI-DOLE JMC No. 20-04-A
The DTI-DOLE JMC No. 20-04-A requires all private establishments to implement all necessary workplace safety and health programs, including COVID-related programs, at no cost to the employees. This includes remote management of cases and close contacts, isolation and referral, contact tracing, COVID-19 testing, occupational safety and health committees, notification and reporting, and disinfection and closure of buildings/workplaces.
Republic Act No. 11332
Under RA 11332, all public and private physicians, allied medical personnel, professional societies, hospitals, clinics, health facilities, laboratories, institutions, workplaces, schools, prisons, ports, airports, establishments, communities, other government agencies, and NGOs are required to accurately and immediately report notifiable diseases and health events of public health concern as issued by the DOH.
Republic Act No. 11058
RA 11058 requires all establishments, projects, sites, and all other places where work is being undertaken in all branches of economic activity to ensure a safe and healthful workplace for all working people by affording them full protection against all hazards in their work environment. This includes submitting all safety health reports, and notifications prescribed by the DOLE.
Unless you provide specific consent or except in instances allowed under the DPA, we will not:
Department of Health (DOH) and its partner agencies
We will share your information with DOH and its partner agencies for purposes of conducting contact tracing or management of probable, suspected, and confirmed COVID-19 patients. Meralco is mandated to report COVID-19 test results in the workplace in accordance with DOH Administrative Order No. 2020-0013, entitled “Revised Guidelines for the Inclusion of COVID-19 in the List of Notifiable Diseases for Mandatory Reporting to the Department of Health.”
Local government units (LGUs) or other authorized persons
We will also share your information to the local health office having jurisdiction over the workplace and the Barangay Health Emergency Team (BHERT) of your place of residence, in accordance with DOH DM No. 2020-0189.
We submit monthly reports of illness, diseases and injuries in the workplace to the Regional Office of the DOLE in accordance with the DTI-DOLE Interim Guidelines on Workplace Prevention and Control of COVID-19 using the Work Accident/Illness Report (WAIR) COVID-19 form.
Meralco Corporate Wellness Center (CWC)
We may share your information to the Meralco CWC in our mandate to conduct contact tracing via the CodeLight Bot and to direct symptomatic individuals to the nearest healthcare facility.
We may collect personal data and other information electronically through digital or online forms
CodeLight Bot, as a paperless contact tracing form, generates daily personal status reports on the health of Meralco employees based on their responses.
It also determines, through automated processing, whether or not the employee is allowed to enter company premises.
MyHRExpress SAP houses the Meralco COVID-19 Vaccine Pre-Registration Form. It shall classify vaccine eligibility of the employees and their dependents according to their available health data.
All other data collection forms
We may collect personal data and other information electronically through digital or online forms with privacy notices that provide a link to this Statement or a copy thereof placed at the point of data collection in a readable font and in an easy-to-understand presentation.
All personal data collected for contact tracing shall be retained only for the period allowed by existing government issuances. The DTI-DOLE JMC provides that personal data collected through the health declaration form or the contact tracing form shall be stored only for thirty (30) days from date of accomplishment.
All other personal data collected for the management of probable, suspected, and confirmed COVID-19 patients shall be stored only for as long as necessary or when the purpose for processing still exists. Thereafter, your personal data shall be disposed of or discarded in a secure manner that would prevent further processing, unauthorized access, or disclosure to any other party or the public.
As an individual whose information we collect and store to fulfill our legitimate purposes, you have rights as a data subject under the DPA.
You have the right to be informed about how and why we collect your personal data. You also have the right to access a copy of your personal information in our possession; the right to withdraw consent that you previously gave; the right to have your information corrected if you believe that it is inaccurate or incomplete; and the right to erase or block your information from our databases.
We also recognize your right to data portability, also known as your right to obtain and electronically move, copy, or transfer personal data for further use. Furthermore, we also respect your right to file a complaint with the National Privacy Commission and your right to be indemnified for any damages sustained due to inaccurate, incomplete, outdated, false, unlawfully obtained or unauthorized use of your personal information.
If you wish to request for a copy of your personal data, or have it corrected or deleted, or to exercise your rights as data subject, you may reach out to us through our Data Privacy Office. Meralco DPO will promptly respond to your request or questions, and also review any feedback that you may have about our Privacy Statement.
Data Privacy Office
Office: Lopez Building, Meralco Center, Ortigas Avenue, Brgy. Ugong, Pasig City, 1600
We uphold your right to be informed whenever we provide a link to or a copy of this Statement prior to collecting your personal data or as soon as reasonably practicable after collection. In processing your data for the specific purposes we discussed in this Statement and those that may be related to such purposes, we shall endeavor to prepare privacy notices that remind you how we collect, use, disclose, and process your personal data in the manner described in this Statement, including our procedures relating to cookies, IP addresses and log files. As to any other purpose that you may not find or cannot infer from this Statement, we shall take all reasonable efforts to obtain your permission through a separate consent form that may either require your signature or contain a button that you could click as proof of your consent.
From time to time, we may update this Statement to comply with applicable laws, rules, and regulations; to reflect any changes to the foregoing; to align with industry practices; or for other legitimate purpose.
You may view past versions of the Statement here.
This Statement shall be reviewed annually or as necessary, in light of the following:
changes to the DPA and its IRR
new issuances from the NPC
changes to the Company’s data processing activities
others that may impact this Statement