CTSI DATA PRIVACY POLICY

Definitions

For the purposes of this policy:

  • Clients – manning agencies, shipping companies, offshore companies, construction companies, other training providers and other companies that require safety and skills training for their personnel.
  • Consolidated Training Systems, Inc. – CTSI, “we,” “us” or “our.” CTSI is the leading provider of safety and skills training for sea-based and land-based personnel, both local and foreign.
  • Data Subjects – refer to all clients, trainees / delegates, employees, suppliers, service providers and other individuals or companies whose personal data information will be provided to CTSI.
  • Personal information controller or PIC – refers to the person who or organization that controls the collection, holding, processing / using of personal information.
  • Personal information processor or PIP – refers to any persons or organizations to whom a PIC may outsource the processing of the personal data information.
  • Suppliers / service providers – people or companies who provide products and services essential to CTSI operation.
  • Third-party accreditation organizations – companies who audit and accredit CTSI like MARINA and OPITO. Such organizations may or may not require the sharing of personal data information.
  • Trainees / Delegates – people who will undergo training at CTSI and whose payment is sponsored by the clients
  • Walk-in Trainees / Delegates – people who will undergo training at CTSI and will pay for their own training

Your Rights as Data Subjects

  • You have the right to be informed about the existence of your rights as data subjects and how we process your personal data information.
  • You have the right to reasonable access to your processed personal data information, to the contact details of the institution we shall be sharing your personal data information and to the identity of our personnel who processed your personal data information.
  • You have the right to object to the processing of your personal data information, unless:
    • needed pursuant to a subpoena
    • collected and processed for obvious purposes
    • collected and processed as a result of a legal obligation
  • You have the right to request for the removal of your personal data information from our filing system if it is inaccurate, incomplete, outdated, false or unlawfully obtained/ processed or we have violated your rights.
  • You shall be indemnified for any damages sustained due to inaccurate, incomplete, outdated, false, unlawful obtaining or unauthorized use of your personal data information.
  • You have the right to file a complaint to us or to the National Privacy Commission if you think that your personal data information is inaccurate, incomplete, outdated, false, unlawfully obtained or used for purposes you have not authorized.
  • You have the right to request for the rectification of any inaccurate personal data information from the PIC.
  • You have the right to data portability. Data portability allows you to obtain a copy, manage and transfer your personal data information from one PIC to another. You can send a formal letter of request (via email or by visiting our office) to us to provide you with the electronic copy of your personal data information.

Giving consent to collect your personal data information

Prior to collecting your personal data information, CTSI shall seek your consent to allow us to collect, process, use and share your personal data information according to this Data Privacy Notice.

Withdrawal of consent

You have the right to withdraw your consent at any time should you think we have violated your rights and processed your personal data information not in accordance to this Data Privacy Notice. The withdrawal of your consent shall not affect the lawfulness of processing based on consent before its withdrawal. Contact our Data Protection Officer to process the withdrawal of your consent.

How to Contact Us

Attention to: Data Protection Officer
Email: it.developer@ctsi.com.ph
Contact No.: 0917.867.1354
Telephone: (632) 524.0572 local 143
Or you may visit us in our Head Office: 4F S&L Building, 1500 Roxas Boulevard, Ermita, Manila.

COLLECTION OF PERSONAL DATA INFORMATION

What personal data information do we collect?

CTSI collects (but is not limited to) the following personal data information essential to our operations:

  • Full name
  • Signature
  • Date of birth
  • Blood type
  • Permanent/ Current addresses/ Company Address
  • Marital status
  • Contact number
  • Email address
  • Gender
  • Video recording via CCTV
  • Contact details of family member in case of emergencies
  • Video/ Photo documentation of training
  • Medical certificate/ Health information/ Waiver
  • Rank/ Rating/ Position
  • Pictures (enrollment/ MARINA certificate)/ ID pictures
  • Government-issued IDs/ Other acceptable IDs
  • TIN/ SSS/ Pag-IBIG Fund/ PhilHealth numbers
  • For employment: documentary requirements
  • For newly-hired: bank account details, if available
  • For suppliers: government permits/ certifications

When and how do we collect your personal data information?

CTSI collects personal data information during the following activities (When) and through the following methods (How):

Data Subjects When Do We Collect? How Do We Collect?
Trainees / Delegates
  • Enrollment
  • Face-to-face interaction with CTSI Registration staff
  • Picture taking
  • Video recording thru CCTV
  • Training endorsement form, if applicable
  • Conduct of training
  • Video recording thru CCTV
  • Video/ Photo documentation of the training
  • Email address, if needed
  • Personal inquiry at CTSI office
  • Face-to-face interaction with CTSI Registration or Marketing staff
  • Video recording thru CCTV
  • Participation in course evaluation
  • Course evaluation questionnaire facilitate by the admin assistant or Quality Auditor or other authorized staff  (OPTIONAL: Writing of name)
  • Course inquiry
  • Phone conversation / email / CTSI online inquiry form
Clients / Suppliers / Service Providers
  • Meetings, outside CTSI
  • Face-to-face interaction with CTSI representative
  • Meetings, CTSI premises
  • Face-to-face interaction with CTSI representative
  • Video recording thru CCTV
  • Course inquiry (clients)
  • Phone conversation / email / CTSI online inquiry form
  • Course reservation (clients)
  • Web-based CTSI Client Portal
  • Email
  • Training reservation form
  • Prior to issuance of the first statement of account (clients)
  • Submission of TIN
  • Prior to the preparation of first payment (supplier/ service providers)
  • Submission of government permits/ accreditation
  • Participation in surveys
  • Survey forms
Employees

/ On-call Training Specialists / Applicants

  • Pre-employment process
  • Face-to-face interaction with CTSI representative
  • Video recording thru CCTV
  • Fill out of application form, for applicants
  • Submission of documentary requirements, for applicants
  • During office hours
  • Video recording thru CCTV
  • Video/ Photo documentation of the training
Government and Third-party Accreditation Organizations
  • Meetings, outside CTSI
  • Face-to-face interaction with CTSI representative
  • Meetings, CTSI premises
  • Face-to-face interaction with CTSI representative
  • Video recording thru CCTV
  • Before scheduled audit
  • Phone conversation / email
  • During audit
  • Video recording thru CCTV
  • Video/ Photo documentation of the on-going audit, if necessary

USAGE OF AND ACCESS TO COLLECTED PERSONAL DATA INFORMATION

Why do we collect your personal data information and who have accessed to it?

CTSI collects your personal data information to:

Data Subjects Who Have Access? Uses of Collected Personal Data Information
Trainees / Delegates
  • Registration Department
  • Comply with the requirements of MARINA, OPITO, GWO, TESDA for recording of trainees’ / delegates’ personal data information and for recording of training history
  • Form part of our database for easy creation of reports / data to be submitted to the said organizations
  • Submit evidence of course completion to the said organizations
  • Establish contact (text message, call or email) regarding the training
  • Have a means to contact family member in cases of emergencies
  • Marketing Department
  • For marketing collaterals (brochures, calendar)  and for posting on the website (photos/ videos collected during conduct of training)
  • Posting of positive feedback (from email and CEQ) on CTSI website (Testimonials)
  • Business Development and HSSEQ Departments
  • Documentation of training thru photos/ videos collected during conduct of training)
  • Accounting
  • For walk-in trainees: To process tax and issuance of official receipts
Clients / Suppliers / Service Providers
  • Marketing Department (clients)
  • Registration Department (clients)
  • Admin Department (Suppliers / Service Providers)
  • Establish contact (text message, call or email) regarding our training and services (for clients)
  • Establish contact (text message, call or email) regarding the products and services we require from our suppliers and service providers
  • Maintain database for easy access of contact details
  • Accounting
  • For clients: To process tax, statement of accounts/ official receipts
  • For suppliers/ service providers: To process payment, issuance of official receipts and submission of government reports
Employees /

On-call Training Specialists

  • HR Department
  • BDD and Training Departments (On-call TS/ Applicant TS)
  • Verify identity and qualification
  • Form part of the 201 file
  • Have a means to contact family member in cases of emergencies
  • Establish contact (text message, call or email) regarding work
  • Maintain database for easy access of contact details
  • Marketing Department
  • For marketing collaterals (brochures, calendar) and for posting on the website (photos/ videos collected during conduct of training)
  • Business Development Department and HSSEQ Department
  • For documentation of training thru photos/ videos collected during conduct of training
  • Accounting
  • To process payment for tax and contributions for SSS, Pag-IBIG Fund and PhilHealth
  • To process and submit for personal loan application and visa application, if required
Applicants
  • HR Department and Department heads
  • Verify identity and qualification
  • Establish contact (text message, call or email) regarding application
Third-party Accreditation Organizations
  • BDD, Quality, Admin Departments
  • Establish contact (text message, call or email) regarding audit-related activities and other inquiries
  • Photo/ Video documentation of the audit
  • Accounting
  • To process payment
Government Organizations
  • Accounting
  • To process payment for permits/ accreditation

STORAGE AND RETENTION OF COLLECTED PERSONAL DATA INFORMATION

CTSI stores the collected personal data information in two (2) ways: hard copies and electronic copies.

Active and / or valid hard copies are stored in the Central File Access (CFA) Manila office and in each concerned Department’s filing cabinets for easy retrieval, if deemed necessary.

Inactive and / or hard copies beyond validity period are stored in the CFA Capipisa site within the designated retention period.

The electronic copies are stored in CTSI’s in-house data center for a retention period of 20 years.

DISCLOSURE/ SHARING OF COLLECTED PERSONAL DATA INFORMATION

CTSI employees who collect and / or receive the collected personal data information ensure the lawful processing of the said data and the disclosure/ sharing to other authorized employees and third-party organizations.

CTSI shares the trainees’ / delegates’ personal data information to the following third-party organizations:

  • OPITO – training records of delegates who completed OPITO-accredited courses are entered into the Central Register for Oil and Gas Certification system. You may visit OPITO website for its Privacy Policy (https://www.opito.com/privacy-policy).
  • MARINA – enrollment reports and Training Completion and Records of Assessment (TCROA) are sent to the email addresses provided by MARINA.
  • GWO – training records of delegates who completed GWO courses are entered into the WINDA system. You may visit GWO’s website for its Data Privacy Policy (https://www.globalwindsafety.org/winda/winda-data-privacy-policy).
  • TESDA – trainees personal data information are entered into the Online TESDA Training Management Information System (T2MIS)
  • Department of Labor – for request of employment-related documents (i.e., pay slip)
  • SSS/ Pag-IBIG Fund/ PhilHealth – for processing of membership contributions and personal loan application, as applicable
  • Bank – for personal loan application of employees/ for payment transactions for supplier/ service providers and third-party accreditation organizations, where applicable
  • BIR – for processing of tax
  • Foreign Embassies – for visa application

DISPOSAL/ DESTRUCTION OF COLLECTED PERSONAL DATA INFORMATION

After the designated retention period, collected personal data information shall be:

  • Hard copies – shredded and disposed of properly
  • Electronic copies – removed/ deleted from CTSI’s in-house data center

COOKIES

Cookies are text files placed on your computer to collect standard Internet log information and visitor behavior information. This information is used to track visitor use of the website and to compile statistical reports on website activity, allowing us to improve the website.

Most browsers are initially set to accept cookies. If you prefer, you can set your browser not to accept cookies, and remove cookies from your browser, or inform you when they are set. However, in a few cases some of our website features may not function as a result.

This Policy may be amended without prior notice. Notification shall be made thru our website and / or via email.


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