Privacy Policy

Data Privacy Consent 
 
NightOwl Consulting Philippines Inc. – (hereinafter referred to as “NightOwl” “Company” “Us”, “Our”, and “We”) has a strong commitment to protect our applicants’ and employees’ personal information from any breaches or unauthorized use of personal information in compliance with the Data Privacy Act (DPA) of 2012, otherwise known as Republic Act (R.A.) 10173 as governed by the National Privacy Commission (NPC). 
 
I acknowledge that the Company holds personal information, including sensitive personal information (as defined by the Data Privacy Act), relating to its prospective, current, and former employees (collectively, “Employee Data”) in its capacity as employer and in the conduct of its business.
 
We use Pinpoint, an online software product provided by The Infuse Group Ltd (t/a Pinpoint Software), to assist with our recruitment process. We use Pinpoint to process personal information as a data processor on our behalf. Pinpoint is only entitled to process your personal data in accordance with our instructions
 
What is Sensitive Personal Information?

 Personal information includes applicants’ and employees’ name, address, contact details, birthdate, and any other information which may reasonably identify her/him. Sensitive personal information includes race, ethnic origin, gender, age, marital status, health information, education, employment information, financial information, SSS, PhilHealth, PagIbig, TIN, and other government ID numbers, tax returns, and other information classified as “sensitive personal information” under the Data Privacy Act.
 
I. LEGITIMATE PURPOSE FOR THE COLLECTION AND USE OF EMPLOYEE DATA
 
We may collect personal information, including sensitive personal information, for the following purposes:
 
⮚      evaluation and processing of applications for recruitment and employment; 
⮚      financial criminal background checks; 
⮚      health screening and drug tests;
⮚      Workforce management
⮚      Compensation-related activities, including equity compensation-related activities, compensation analysis and administration.
⮚      Payroll processing (including management of salaries, expenses, taxes, required notification to governmental authorities and the like);
⮚      Remittances and employee contribution to government agencies;
⮚      Performance and absence management; job grading; benefits and personnel administration;
⮚      HR Reporting
⮚      Compliance with legal and regulatory requirements;
⮚      monitoring and enforcing compliance with Company policies and procedures and with legal and regulatory requirements; 
⮚      monitor quality of service; 
⮚      manage employee interactions with the various facilities and services offered by the organization (e.g. physical access); 
⮚      business continuity and disaster recovery;
⮚      establish a contact point in the event of emergencies;
⮚      employee engagement, training and development, performance improvement, and productivity;
⮚      internal audits, client, audits, and third-party audits;
⮚      organization, implementation and participation charitable initiatives;
⮚      compliance with the Company and its client information security requirements and in response to clients and customer complaints;
⮚      processing necessary for the purposes of preventive or occupational medicine, for the assessment of the working capacity of the employee, medical diagnosis, recording on an employee’s file any health issues that may affect an employee’s ability to work or of which Company needs to be aware of; 
⮚      authentication and validation of submitted medical or hospital documents including abstracts, medical certificates, etc.;
⮚      providing IT support and services as well as providing and hosting IT infrastructure; 
⮚      protecting the security of Employee Data, client information as well as NightOwl’s data, systems, property, and premises;
⮚      and for any other purposes directly or indirectly related to those listed above.
 
II. DISCLOSURE AND TRANSFER OF EMPLOYEE DATA
 
Your personal information may be shared through email or by any other means available by any of our authorized employees across the company’s entities or organizations as deemed necessary for our business purpose such as: 
 
●        Company's parent, subsidiaries, affiliates, and their representatives and agents;
●        Company's Clients and including client’s affiliates, representatives, agents and vendors;
●        Third party vendors that assess applicant skills, evaluate, or process applications; that conduct financial and criminal background checks; that conduct health screening and drug tests; payroll providers, banks, HMO and healthcare/clinic/hospital providers, and similar service providers;
 
We may disclose your information to law enforcement, regulatory, government agencies, insurance companies, professional bodies and other third parties, as required by and/or in accordance with applicable laws or regulations. 
 
This may include disclosures outside the country, if necessary. As part of our commitment to protect your personal information, we will review your personal information to determine whether disclosure is required or permitted. 
 
 
 
 
III. RETENTION AND DISPOSAL OF PERSONAL INFORMATION
 
We will keep your personal information for 12 Months from the date of your last transaction with us or for as long as required by laws or regulations.

 After the retention period, the Company is no longer responsible to keep and provide you with your personal information/documents. As authorized, our designated custodian will purge your personal information through shredding of paper files and/or deletion of electronic files in our computer system, or in any other manner, which would prevent further retrieval, processing, or access of your personal information. 
 
IV. YOUR RIGHTS AS DATA SUBJECT 
 
The Company acknowledges your rights as a Data Subject. Thus, you are entitled to the following: 
  
●        the right to be informed; 
●        the right to access;
●        the right to object; 
●        the right to erasure and blocking; 
●        the right to rectify; 
●        the right to file a complaint; the right to damages;
●        and the right to data portability

 Details of these rights may be found on the National Privacy Commission’ website https://privacy.gov.ph/data-subject-rights/