DPO Practice Docket RA 10173 · Philippines

Reference · Current as of August 2026

Index of Issuances

Every authority cited in this project, what it does, and why it matters to a DPO. Official texts live at privacy.gov.ph.

One

The statute

ReferenceSubject
RA 10173Data Privacy Act of 2012. Took effect 8 September 2012.
IRRImplementing Rules and Regulations, 2016 as amended 2023. Rule XI covers the DPO; Rules VI–VIII cover security measures; Rule IX covers outsourcing.
Const. Art. IIISecs. 2 and 3 of the 1987 Constitution — privacy of communication and correspondence, and freedom from unreasonable searches. Worth one sentence if asked where the right comes from.

← swipe tables sideways

Reading the numbering

The Act has sections. The IRR has rules. So "Rule XI" is never a section of the Act, and "Sec. 21" is never part of the IRR. Mixing the two is a common tell that someone has only skimmed.

Two

Sections worth citing by number

Sec.Subject
3Definitions — PI, SPI, privileged, PIC, PIP, processing
4Scope, and the information-specific exclusions
6Extraterritorial application
7Functions of the NPC
11Three general data privacy principles
12Six lawful bases for personal information
13Grounds for sensitive personal and privileged information
14Subcontracting
16Rights of the data subject
17Transmissibility of rights to heirs
18Right to data portability
20Security of personal information; 20(f) is breach notification
21Accountability — the DPO's foundation
25–34Criminal offences
35Large-scale aggravation — data of 100 or more persons
36Offence by a public officer — disqualification
37Restitution
44Liability of the PIP
Three

Circulars

Circulars are binding rules. When one applies to your situation, it is not optional guidance.

CircularSubjectWhy it matters
16-03Personal Data Breach ManagementThe 72-hour rule, breach report contents, and the Annual Security Incident Report
20-01Processing for loan-related transactions (am. by 2022-02)Lending sector; the NPC's response to abusive collection apps
20-02Rules on Cease and Desist OrdersThe procedure behind the NPC's sharpest tool
2020-03Data Sharing AgreementsRead alongside Advisory 2025-01, not on its own
2021-01NPC Rules of ProcedureHow complaints, investigations, and adjudication actually run
2021-02Processing during public health emergencies—
2022-01Guidelines on Administrative FinesThe fine tiers and the ₱5M cap. Effective 27 August 2022, prospective only
2022-02Amending Circular 20-01—
2022-03Private security agencies handling customer and visitor information—
2022-04Registration, ADM notification, DPO designation, SealYour registration obligations. Verify the Annex thresholds yourself
2023-01Schedule of fees and charges—
2023-05Philippine Privacy Mark certificationVoluntary certification; useful to raise as a maturity goal
2024-02CCTV systemsRepealed and replaced Advisory 2020-04
2025-01Body-worn cameras—
Four

Advisories

Advisories are interpretive guidance. Not binding in the same way as a circular, but they tell you exactly how the regulator reasons — which makes them extremely useful in an interview.

AdvisorySubjectWhy it matters
2017-01Designation of Data Protection OfficersIndependence, conflict of interest, COPs, qualifications — the core of your role
2017-03Guidelines on Privacy Impact AssessmentsHow to actually run a PIA
2024-04Application of the DPA to AI systemsConfirms there is no AI carve-out. Cite this the moment AI comes up
2025-01Clarification on Circular 2020-03 (DSAs)DSAs are optional; no NPC approval required; the sharing activity is still reviewable
2025-02Privacy Engineering in Systems Life Cycle ProcessesThe five SDLC phases. Your strongest differentiator for a software role
2026-01Data Scraping of Publicly Available Personal DataPublic does not mean free to process
2026-02Breach notification via the DBNMSPostponement, exemption, alternative notification, and extension requests

NPC–IC Joint Advisory 2025-001 covers privacy-enhancing technologies in insurance — relevant only if the employer is an insurer.

Five

Enforcement worth citing

DateMatterHolding
8 Oct 2025 Cease and desist order against Tools for Humanity (World App), on biometric iris collection Financially incentivised consent is not freely given consent. The NPC examined the quality of consent, not merely its existence
Why one case is enough

You do not need a catalogue. Naming a single recent action, correctly dated, with the point it established, signals that you follow the field rather than only the textbook. Most candidates cannot name any.

Six

If you only have one evening

Read these three, in this order.

  1. NPC Advisory 2025-02 — short, and it is your edge for anything involving software.
  2. NPC Circular 2022-01 — the fine structure. Interviewers ask for numbers.
  3. Secs. 11, 12, 13, 16, 20, and 21 of RA 10173 — the load-bearing provisions. Everything else hangs off them.
Standing caution

The registration thresholds in Circular 2022-04 are the most commonly misquoted numbers in Philippine privacy practice. Check the Annex against the official text before you cite them in an interview.

Current as of August 2026. Issuances land regularly — check privacy.gov.ph for anything published since. This is interview preparation, not legal advice.