Manila Water Data Privacy Statement and Policy

DATA PRIVACY STATEMENT:

Manila Water Company, Inc. and its subsidiaries (the ‘Company’) commit to protect the privacy of the personal information of our clients, employees, or any other individuals in connection with the water, used water and sanitation services we provide in accordance with the Data Privacy Act of 2012.

DATA PRIVACY POLICY:

This Privacy Policy will help our customers and relevant stakeholders understand: (i) what Personal Information we collect; (ii) how we collect, hold, use and disclose that information; and (iii) the purposes of such collection, holding, use and disclosure.

To what does this Privacy Policy apply?

This Policy is addressed and applies to our customers and relevant stakeholders including all of our facilities as well as all the Services that we offer.

This Policy does not apply to any website, product or service of any third-party organization even if the website links to (or from) our Website. Please review the privacy practices of any third-party organization at all times before deciding whether to provide any information.

By using our Services, you accept the practices described in this Policy. Continued use of our Services will signify your acceptance of this Policy.

What information do we collect and process?

When you apply for and/or use our Services, we collect your Personal Information.

The term “Personal Information”, as used in this Policy, refers to any data (whether by itself or when linked with other information) in the possession of, or likely to come into the possession of the Company, that can be used to identify a specific living person.

Your Personal Information we collect and process includes:

Personal details such as your name, address (including nearest landmarks), contact details, and signature;
Personal Information connected with your Manila Water Customer Account such as your Customer Account Number,
Sensitive Personal Information such as your government-issued identification number (e.g. SSS, TIN, etc.), which we use for identity verification purposes. If you are a senior citizen , we collect your OSCA/DSWD ID to establish your qualification for a senior citizen discount.

Why do we collect your Personal Information?

We collect your Personal Information for the following purposes:

To be used as basis for the assessment of whether your application meets requirements for a new water/sewer service application;
To obtain government permits necessary for the installation of a new water/sewer service connection;
To install the requested new water service connection through our service providers;
To create, administer and maintain your customer account with the Company;
To be used as reference for communication related to the application process, consumption and billing and other related services.;
To enable the Company to respond to service, billing, and other customer concerns;
To be used in continually improving the Company’s Services;
To comply with government and other regulatory requirements; and
To establish, exercise, or defend legal claims.

How do we collect your information?

Broadly speaking, we collect your personal information only when you provide it directly to us.

Specifically, we collect Personal Information from you through your New Water Service Connection Application Form, the documents and forms bearing your personal information that you submit to us or was acquired by us with your authorization, and through physical or electronic communication with Company representatives. If you are a senior citizen, we also collect information through your Senior Citizen Discount Application Form. We also collect information when you communicate with us through mail, phone, e-mail, fax, social media platforms such as website, facebook, twitter and/or other means of communication chosen and utilized by the Company.

To whom do we disclose your Personal Information?

Subject to the provisions of the Data Privacy Act of 2012 (DPA), and with your consent, we may share, preserve, transfer, and disclose your Personal Information to the following:

Third party suppliers and service providers that help us provide our Services, to the extent needed to perform their duties and their functions; and
Government authorities and such entities that may have a legitimate and legal interest in the information, in response to a legal request such as a search warrant, court order or subpoena, if we believe in good faith that we are required to do so under the law.

Your Personal Information will be shared for the following purposes:

To install your new water or sewer service connection;
To perform meter reading and billing services;
To communicate and to respond to service, billing, and other customer concerns;
To carry out data collection and analysis for the continuous improvement of the Company’s Services;
To conduct company audits or investigate a complaint or security threat;
To carry out digitization and storage processes;
To respond to law enforcement authority or other government regulatory bodies’ requests;
To comply with government and other regulatory requirements;

To facilitate the establishment, exercise, or defense of legal claims.

What are your rights as a data subject?

As a data subject whose Personal Information has been and will be collected and processed by us, you are entitled to the following rights, pursuant to Section 16 of the DPA, and Section 34 of its Implementing Rules and Regulations:

Right to be informed
Right to Object
Right to Access
Right to Rectification
Right to Erasure or Blocking
Right to Damages

No Personal Information shall be collected without your consent. If you wish to withdraw consent to the collection of your Personal Information, kindly give us reasonable notice to allow time to cease any and all processing.

In the event that you refuse to give consent, your Personal Information shall no longer be processed, unless:

The Personal Information is needed pursuant to a subpoena;
The collection and processing are for obvious purposes, including, when it is necessary for the performance of or in relation to a contract or service to which the customer is a party; or
The information is being collected and processed as a result of a legal obligation.

Any information to be provided by you shall always be in clear and plain language, to ensure that the information is easy to understand and access.

Why do we retain your personal information?

We have a variety of obligations to retain the Data that you provide to us, including but not limited to: (a) ensuring that transactions can be appropriately processed, settled or refunded; (b) helping identify fraud; and (c) complying with anti-money laundering and other laws and rules that apply to us and to our financial service providers. There may also be residual Data that will remain within our databases and other records, which will not be removed.

Whatever Personal Information given to us by you or pertaining to you shall only be retained for as long as necessary or for as long as the above-stated purposes shall have been satisfied.

Personal Information provided to us by you shall be disposed or discarded in a secure manner that would prevent further processing, unauthorized access, or disclosure to any other party, or prejudice the interests of our customers.

How do we protect your personal information?

We use reasonable organizational, technical and administrative measures to protect your Personal Information within our organization which include but are not limited to:

Employee Data Security Awareness and Training. This is a basic required training program for all new employees. In addition, refresher courses are conducted especially to units who handle the personal information involving clients.
Access Management. We manage user access strictly with regular reviews and prompts for change passwords.
Data Sharing Contracts. When personal information is required to be shared to service providers and partners, this privilege is explicitly defined in a contract stating the conditions around data sharing, the limitations of usage, and the diligence required for its storage.
Physical Storage. All paper-based documents containing your personal information are kept in locked filing cabinets and/or in secure warehouses maintained by third party service providers while the digital/electronic files are kept in secured cloud storage and onsite premise computers provided and installed by the Company.
Monitoring for Security Breaches. The Company monitors its information systems for security breaches.

Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If the customer has reason to believe that his interaction with us is no longer secure (for example, if the customer feels that the security of his account has been compromised), please contact our Data Protection Officer (DPO) immediately. His contact details are provided below.

What about changes to this Policy?

The Company reserves the right to amend, modify or supplement this Policy at any time.

How can you reach us?

If you have any questions or suggestions about this Privacy Policy or would like to access or seek correction of your Personal Information, or if you have any complaints regarding our privacy practices, you may reach our DPO on the following information :

Office Address: MWSS, Administration Building, 489 Katipunan Road, Balara QC
Contact Number: 9175900 local 1501
Email Address: dpo(at)manilawater.com

Please note that you, as the requesting party, would have to pay the reasonable costs and expenses incurred by the Company for producing the requested information.

Because email communications are not always secure, you are asked to not include credit card or other sensitive data (such as racial or ethnic origin, political opinions, religion, health, or the like) in emails sent to us.