Data Privacy
Whistleblower Application Privacy Notice
Equicom Savings Bank. ("EqB," "we," "us") values your privacy and is committed
to protecting personal data in compliance with Republic Act No. 10173, otherwise
known as the Data Privacy Act of 2012, its Implementing Rules and Regulations,
and relevant issuances of the National Privacy Commission. This Privacy Notice
explains how personal data is collected and processed in relation to the use of
EqB’s Whistleblower Application.
Purpose
EqB’s Whistleblower Application (the "System") is used to securely receive and
process reports of suspected violations, misconduct, unethical behavior, or other
acts detrimental to the Company, its employees, clients, or stakeholders.
Legal Basis for Processing
Personal data collected through the System is processed based on:
Legitimate Interest – for the detection, prevention, investigation, and resolution of
violations and misconduct;
Compliance with Legal Obligations; and
Employment Relationship, where applicable.
Voluntary Reporting and Anonymity
Use of the System is voluntary. Reports may be submitted anonymously or with
identifying information. Providing contact details may assist in the investigation
but is not required.
Personal Data Collected
Depending on the report, the following data may be processed:
Reporting person’s name, contact details, and relationship to EqB’s (if voluntarily
provided);
Personal data of persons involved, witnesses, or relevant individuals, limited to
what is necessary for the report.
Access, Use, and Disclosure
Personal data is accessed only by authorized EqB’s personnel on a
need-to-know basis and treated with strict confidentiality. Data may be disclosed
to law enforcement or regulatory authorities only when required by law or lawful
order.
The system provider is engaged solely for technical maintenance and has no
ownership over the data.
Data Security
EqB implements appropriate organizational, physical, and technical security
measures, including encrypted communications and restricted access controls, to
protect personal data processed through the System.
Data Retention
Personal data is retained during active investigation and for five (5) years
post-resolution to satisfy BSP and statutory record-keeping mandates, after
which it is securely destroyed or anonymized.
Data Subject Rights
Data subjects may exercise their rights to be informed, access, correct, object,
request erasure or blocking, data portability, and damages, or lodge a complaint
with the National Privacy Commission.
Vendor & Processing Roles
The platform provider acts as a Personal Information Processor strictly under
EqB's documented instructions. EqB retains exclusive ownership of all master
and transaction data. The provider is bound by confidentiality, cannot engage
sub-processors without EqB consent, and is subject to BSP and audit inspection.
Whistleblower Protection
EqB guarantees strict confidentiality of the reporter's identity and protects
good-faith whistleblowers against retaliation, discrimination, or adverse
employment actions.
Contact Information
For questions or concerns regarding this Privacy Policy or the processing of
personal data, you may contact:
Data Protection Officer
Equicom Savings Bank
Email Address: dpo@equicomsavings.com.ph