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PRIVACY POLICY

LEPANTO CONSOLIDATED MINING COMPANY (Lepanto) is committed to protecting the privacy of its data subjects and ensuring the safety and security of personal data under its control and custody. This policy is intended to provide information on the kind of personal data gathered and kept by Lepanto  from various Data Subjects, namely: its past, current, and prospective employees; directors;  past and current stockholders; scholars and applicants for scholarships; community members; consultants;  covered external providers;   as well  as how these data are used and processed, secured, and how and when they will be disposed of.  This information is provided in accordance with the Philippine Republic Act No. 10173 or the “Data Privacy Act of 2012” (DPA) and its Implementing Rules and Regulations (DPA-IRR).

 

Lepanto also has a Privacy Policy for the Lepanto Hospital.

Information Collected

 

Lepanto collects, stores, and processes personal data from:

 

A.  Its past, current, and prospective employees, starting with the information provided at application through information collected in the course of employment and up to retirement, even post-retirement, in the case of pensioners. These data are collected, stored and processed for the purposes of (1) talent acquisition, sourcing and selection; (2)determination and delivery of benefits to current employees, including health benefits, and to pensioners and their beneficiaries; and (3) talent management and career development . These data include various:

 

  • Contact information;

  • Personal information such as date and place of birth; nationality; immigration status; religion; civil status; ethnic affiliation; gender; height; weight; government-issued IDs; SSS, BIR, Pag-Ibig and Philhealth Nos., etc.

  • Names of spouse, parents, children and if necessary, siblings

  • Educational background such as year graduated, course, schools attended, honors and distinctions received, copies of transcript of grades and diplomas

  • Work experience such as previous employments with inclusive dates, position, salaries and name of immediate supervisor as well as reason for leaving last employer

  • Skills, professional licenses and certification, and record of engagement in business

  • Health information such as blood type, surgeries and treatmentsundergone, whether smoker or non-smoker

  • Character information such as criminal record and references, record on bankruptcy and involvement in civil and criminal cases

  • For prospective employees, record on suspension or dismissal by employer; and police, barangay and NBI clearances

  • For current employees and pensioners, bank account number and names of beneficiaries

  • For selected candidates for employment, physical examination details, laboratory findings and medical recommendations

  • For current employees, performance rating, salaries and benefits, career movements

B.  Its past and current stockholders for the purposes of (1) issuance of stock certificates; (2) lodgment or upliftment of shares; (3) conversion of shares;(4) determination of entitlement to cash dividend/stock dividend; (5) printing of cash dividend checks and printing of name and address on dividend notice; (6) distribution of cash dividend check, stock dividend certificate, and notices; (7) annotation of lien, levy, or garnishment order over the shares of the company, if any; (8) validation and tabulation of proxy votes; (9) validation of requests for transfer of shares to heirs; (10) withholding and remittance of tax, if any is due, on amounts to be received from Lepanto; (11) preparation of relevant reports required by law and regulatory agencies such as the Philippine Stock Exchange and the Securities and Exchange Commission; and (12) such other processing or disclosures that maybe required under pertinent laws, rules, or regulations. These data include:

 

  • Contact informationsuch as, name, addresses, telephone numbers, email addresses and other contact details

  • Personal information such as date and place of birth, nationality, civil status, gender,government-issued IDs, and signature

  • Names of spouse, parents, children and if necessary, siblings

  • For foreign stockholders who request Lepanto to sell their shares in the market, bank account details for purposes of remittance of proceeds of sale.

C.  Past/Present Scholars and Applicants; Community members. The Community Relations Department collects and processes personal information of applicants for scholarshipsand scholars for eligibility assessment and delivery ofprogram services and assistance. Personal information from sampled communities are also collected as part of a survey/profiling activity to review and rationalize community relations programs. Collected personal information may include:

 

  • Contact information such as name, address, telephone numbers, email addresses and other contact details

  • Personal information such as date and place of birth, nationality, ethnicity, civil status, gender, and signature

  • Household information, including personal and financial information

  • Academic information and extra-curricular participation

  • Employment history, if any

 

 

D.  Past and Present External Providers.The Purchasing Department acquires personal information from external providers for processing of their accreditation, forevaluation, and to facilitate the procurement process.

 

E.   Other interested parties.Those who submit or file complaints, comments, inquiries or requests (“Concerns”) through any of the modes indicated in our “Contact Us” page in our website. The collected personal information is utilized only to address their Concerns and is shared only with authorized personnel of the Company. All concerned departments shall develop and implement measures to ensure that all its staff who have access to personal data will strictly process such data in compliance with the requirements of the DPA-IRR. These measures may include drafting new or updating existing policies and procedures and conducting learning sessions to educate employees and agency-contractors on data-privacy related concerns.

 

Information Sharing

 

Personal data of employees under the custody of Lepanto shall be disclosed only to authorized recipients of such data such as the concerned staff of the Human Resource Department and Office of the Treasurer. We will share your personal data with third parties other than your parents and/or guardian on record, only with your consent, or when required or permitted by our policies and applicable law, such as with:

 

  • Regulatory authorities, courts, and government agencies, e.g., SSS; Pag-ibig and PhilHealth, etc.

  • Service providers in respect ofhealth/hospitalization benefits; group life insurance; employees’ compensation

 

Personal data of stockholders are stored and processed principally by Lepanto’s stock transfer agent, which has its own Data Privacy Policy compliant with the DPA and the DPA-IRR.

 

Data Transfer

 

Where Lepanto considers it necessary or appropriate, for the purposes of data storage, processing, providing any service, we may transfer personal data to third parties within or outside of the Philippines, under conditions of confidentiality and similar levels of security safeguards.

 

Rights of Data Subjects

 

Data Subjects have the following rights:

 

  • Gain reasonable and secure access to their personal data at reasonable times;

  • Object or withhold consent;

  • Suspend, withdraw or order the blocking, removal or destruction of their personal data;

  • Claim compensation for damages suffered arising from any violation of their rights and freedoms as data subject;

  • Correct personal data;

  • Obtain data in a secure manner; and

  • Lodge a complaint before the National Privacy Commission.

 

Security

 

We are putting in place organizational, administrative, technical, and physical security measures to safeguard your personal data.

 

Only authorized personnel have access to your personal data;  we require a non-disclosure agreement and/or data sharing agreement with them, in compliance with the DPA and the DPA-IRR. Your paper and digital files are securely stored. We employ physical security measures  to safeguard the paper files and technical security to protect the digital files.

 

 

 

For inquiries and concerns regarding rights as data subjects, please  email the Office of the Data Protection Officer at lcmc.dpo@lepantomining.com

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