NPC notice

DRAFT, pending review by counsel. Not yet in effect. We wrote this notice from the Data Privacy Act of 2012 (Republic Act No. 10173) so that anyone listed on ffide can see now what we hold and how to act on it. A lawyer has not reviewed it yet. Where a fact still needs confirming, the text says "[to be confirmed by counsel]". The reviewed version will replace this one here.

1. Who we are

ffide is operated by BP Labs OPC, a One Person Corporation registered in the Philippines. In this notice "we" and "us" mean that company. For the directory described here, we are the personal information controller.

• SEC registration: 2026060255699-04
• Registered office: Unit 10-01, One Global Place, 5th Avenue cor. 25th Street, Bonifacio Global City, Taguig 1634
• Data Protection Officer: [to be confirmed by counsel]
• Privacy contact: privacy@bp-labs.tech

2. Who this notice is for

This notice is mainly for insurance professionals listed on ffide who never signed up. ffide is a free public directory of insurance professionals licensed by the Insurance Commission of the Philippines (the "IC"). Anyone can search it without an account.

If you claimed your ffide listing, or you visit ffide to search, write a review or send an enquiry, our Privacy Policy also applies to you.

3. Where your information comes from

The IC publishes rosters of the insurance professionals it licenses, as public documents. We take your listing from those public rosters. We did not collect it from you, and we did not ask your permission first. This notice is how we tell you, as the Act asks us to.

4. What we publish about you

From the IC roster, and nothing else unless you claim your listing:

• your name, as the roster gives it;
• the insurance company each licence is with, and the licence type;
• the licence status, and its expiry date where the roster gives one (a listing nobody has claimed shows only a current licence; past and lapsed licences are withheld);
• the date of the roster the details come from.

We do not publish a licence number, a photograph, a home address, a phone number or an email address for a listing you have not claimed, and nobody can send you a message through it.

If you claim your listing, you choose what else appears (for example a photo, a short biography, the areas you serve and your links). Our Privacy Policy explains that part.

5. Why we publish it

So that a member of the public who is offered insurance can check, quickly and for free, that the person offering it is licensed by the IC.

We do not sell your information, and we do not use the roster to send you marketing.

6. Our legal basis

We rely on our legitimate interest (Section 12(f) of the Act), and the public's, in being able to verify that an insurance professional is licensed, using information a regulator already publishes. Licence details issued by a government agency can count as sensitive personal information under the Act; where they do, we rely on the processing being provided for by existing law and regulation, the IC's own publication of the roster (Section 13). [to be confirmed by counsel]

7. Your rights, and how to use them

Under the Data Privacy Act you have the right to:

• be informed that your information is processed: this notice;
• access what we hold about you and learn where it came from;
• correct it if it is wrong or out of date;
• object to our processing, and ask us to block, remove or destroy your listing;
• data portability, a copy in a common electronic format, where it applies;
• damages, if your rights are violated;
• complain to the National Privacy Commission (privacy.gov.ph).

To remove your listing or correct it, email privacy@bp-labs.tech with the name on the listing and its ffide page address. You do not need an account, a reason or a lawyer.

• Removal. We take the listing down and record your request, keeping only the least we need to recognise you, so that a later IC roster does not quietly put it back.
• Correction. The roster itself is the IC's and only the IC can change it, but you do not have to go to them first: we correct, note or remove our copy.

We may ask you to confirm who you are, only as far as we need to, before we act on a request. We do not charge for it. We answer within the period the law sets [to be confirmed by counsel].

8. Who can see it, and where it is kept

Your listing is public on ffide.com, which is the point of the directory. Search engines can find it. Our servers, database and file storage are in Singapore; we stay accountable for your information wherever it is processed (Section 21 of the Act).

9. How long we keep it

• Your listing: while you appear on the IC's published rosters, unless you ask us to remove it.
• Our record of each IC roster we imported: kept, because it is the record of a public source.
• After a removal request: only what we need to keep your listing removed.
• Any other period: [to be confirmed by counsel].

10. Security

We protect what we hold with access controls, encryption in transit and a record of administrative actions. If a personal data breach puts you at real risk, we notify you and the National Privacy Commission as the law requires.

11. Changes to this notice

When this notice changes, the new version appears on this page with its version number. This version is a draft and is not yet in effect.

Questions: privacy@bp-labs.tech