1. Introduction
This Privacy Notice explains how LKY Group of Companies, acting as the Personal Information Controller under the Philippine Data Privacy Act of 2012 (RA 10173) and its Implementing Rules and Regulations, collects, uses, stores, shares, and protects your personal data through our Human Resource Information System (the “HRIS”).
By using the HRIS, whether through the web portal, mobile application, or biometric kiosk, you acknowledge that you have read and understood this Notice.
2. Legal Basis for Processing
We process your personal data on one or more of the following bases:
- Contract — processing is necessary to perform our employment contract with you, in accordance with the Labor Code of the Philippines.
- Legal obligation — tax withholding under the National Internal Revenue Code, SSS (RA 11199), PhilHealth (RA 11223), Pag-IBIG (RA 9679), and DOLE compliance requires us to collect and report specified data.
- Legitimate interest — workforce administration, payroll processing, attendance verification, fraud/buddy-punching prevention, and internal reporting.
- Consent — where required, such as for optional data or non-essential communications, we obtain your explicit consent.
3. Personal Data We Collect
Depending on your role and the modules you interact with, we may collect the following categories of data:
- Identity and contact information — name, date of birth, gender, civil status, nationality, religion, blood type, mobile number, email address, and home address (city, province, ZIP code).
- Employment information — position, department, company, employment type, date hired, regularization and separation dates, contract terms, and salary rate.
- Government identifiers — SSS, PhilHealth, Pag-IBIG, TIN, and Solo Parent ID (where applicable).
- Biometric data & Timekeeping:
- Fingerprint biometrics: Fingerprint templates are stored locally on the biometric hardware devices only. No raw fingerprint images are stored, extracted, or transmitted to central servers.
- Face detection: Any real-time face detection performed by the system is processed transiently on-device to verify presence; facial biometric geometry/templates are not extracted, mapped, or stored.
- Location data — for web and mobile punches: GPS latitude, longitude, accuracy, IP address, user agent, and, where enabled, periodic location heartbeats recorded at 30-second intervals while you are clocked in.
- Images and signatures:
- Profile photo and digital signature.
- Timekeeping punch selfies: Captured during clock-in/clock-out via web or mobile portal solely as visual attendance verification proof. These images undergo no facial classification, profiling, or biometric template extraction.
- Financial information — bank name and account number for payroll disbursement, salary details, deductions, loans (SSS, HDMF, MP2, salary, emergency, and others), and issued cash disbursements.
- Communications — in-app chat messages, sanction incident reports, and bug reports, including any device information you submit.
- Emergency contacts — name, relationship, mobile number, and address of your designated emergency contact or contacts.
- Recruitment data (applicants only) — résumé, application photo, signature, references, and interview notes.
- 201 file documents — uploaded scans of certificates, identification documents, contracts, and other HR records.
4. How We Collect Your Data
We collect your data through the following means:
- Directly from you — through the employee portal, mobile application, onboarding forms, camera punch selfies, and 201 file uploads.
- From your interactions with the system — through biometric device synchronization, web and mobile punch scans, geolocation tracking, and chat messages.
- From HR administration — through data entered on your behalf by authorized HR personnel, including profile details, contracts, sanctions, filings, and payroll runs.
5. How We Use Your Data
We use your data for the following purposes:
- Attendance verification, biometric timekeeping, and prevention of fraudulent attendance (e.g., buddy punching).
- Payroll computation, including basic pay, overtime, allowances, deductions, loans, retroactive adjustments, 13th-month pay, and withholding tax.
- Remittance of government contributions and taxes to the BIR, SSS, PhilHealth, and Pag-IBIG.
- Administration of leave applications, filings, and approval workflows.
- Sanction escalation and disciplinary tracking.
- Workforce reporting and analytics (aggregated and de-identified where practicable).
- Security and audit purposes (all actions are logged with the acting user, timestamp, and IP address).
- Legitimate business communications, including chats, notifications, and announcements.
6. Data Sharing and Disclosure
We share your personal data only when necessary, and only with the following categories of recipients:
- Government agencies — BIR, SSS, PhilHealth, Pag-IBIG, and DOLE, as required by law.
- Payroll banks and disbursement partners — for salary and cash disbursement.
- External auditors — for annual financial and compliance audits, subject to confidentiality obligations.
- Law enforcement and courts — only upon a valid subpoena, court order, or other lawful requirement.
- Service providers — hosting, backup, and technical support providers bound by a written Data Sharing or Outsourcing Agreement requiring protections equivalent to those under the Data Privacy Act.
We do not sell your personal data, and we do not share it with third-party marketers or advertisers.
7. Data Retention & Deletion
- Active employees — employment and profile data is retained for the duration of your employment.
- Separated employees — data is retained for at least three (3) years following separation in accordance with the Labor Code, and up to ten (10) years for payroll and tax records pursuant to Section 235 of the National Internal Revenue Code.
- Punch selfies — retained only for the active payroll cutoff period and in all cases for no more than thirty (30) days, after which they are automatically and permanently purged from the system.
- Geolocation records — retained for the current and immediately preceding payroll cutoff, after which they are subject to archival or deletion.
- Biometric templates — deleted from the biometric device within thirty (30) days of separation.
- Audit logs — retained for security and compliance investigation purposes, subject to periodic review.
8. Security Measures
We implement organizational, physical, and technical measures to safeguard your personal data, including:
- Encryption of all web traffic using HTTPS with TLS 1.2 or higher.
- Password hashing using the Bcrypt algorithm.
- Restricted database access limited to authorized systems and administrators.
- Role-based access control (RBAC), with every module gated by explicit permissions.
- Comprehensive audit logging of all data modifications.
- Regular backups with tested restoration procedures.
- Physical security controls over servers and biometric devices.
9. Your Rights as a Data Subject
Under the Data Privacy Act of 2012, you have the right to:
- Be informed — of the collection and processing of your personal data, as set out in this Notice.
- Access — obtain a copy of the personal data we hold about you, through your Employee Portal profile or by written request to HR.
- Object — object to processing based on consent, subject to legal and contractual limitations.
- Rectify — correct inaccurate or outdated data through your profile or through HR.
- Erasure or blocking — request the removal or blocking of data that is no longer necessary, subject to the retention obligations described above.
- Claim damages — claim compensation for damages sustained due to inaccurate, incomplete, or unlawfully obtained or used personal data, pursuant to Section 16(f) of the Act.
- Data portability — obtain an electronic copy of your data in a structured, commonly used, and machine-readable format.
- Lodge a complaint — file a complaint with our Data Protection Officer or directly with the National Privacy Commission at privacy.gov.ph.