Unit 506 – 510, Aspire Corporate Plaza, Lot 2 Road 3, CBP 1A MOA Complex Brgy. 76, Zone 10 Pasay City
PRIVACY POLICY
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 / learners / participants, 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, OPITO, TESDA, BV. Such organizations may or may not require the sharing of personal data information.
Trainees / Learners / Participants – people who will undergo training at CTSI and whose payment is sponsored by the clients
Walk-in Trainees / Learners / Participants – people who will undergo training at CTSI and will pay for their own training
Zoom, Viber and other applicable applications – applications that can be used to conduct online training or meetings
Central Register (OPITO), WINDA (GWO), MISMO (MARINA) and T2MIS (TESDA) are systems from course accreditation bodies that serve as repository of trainees’ / learners’ / participants’ information and training records.
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: o needed pursuant to a subpoena o collected and processed for obvious purposes o 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.
Or you may visit us in our Head Office: Units 506-510 Aspire Corporate Plaza Lot 2, Road 3, CBP-A, MOA Complex, Brgy. 76 Zone 10, Pasay City 1300.
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 or Zoom application
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 / Learners / Participants
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 recording/ screenshot thru Zoom application for online training/ Screenshot
Video / Photo documentation of the training
Email address, if needed
Conduct of internal and external audits
Video recording thru CCTV
Video recording thru Zoom application for online training/ Screenshot
Video/ Photo documentation of the training
Training records
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 / text messaging / email / CTSI online inquiry form / Chat messaging
Clients / Suppliers / Service Providers
Meetings, outside CTSI
Face-to-face interaction with CTSI representative
Meetings via Zoom, Viber or other applications
Video recording/ Screenshot
Meetings, CTSI premises
Face-to-face interaction with CTSI representative
Video recording thru CCTV
Course inquiry (clients)
Phone conversation / text messaging / email / CTSI online inquiry form / chat messaging
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
Meetings via Zoom, Viber or other applications
Video recording/ Screenshot
During office hours
Video recording thru CCTV
Video/ Photo documentation of the training
Conduct of internal and external audits
Video recording thru CCTV
Video recording thru Zoom application for online audits/ Screenshots
Video/ Photo documentation of the audit
Government and Third-party Accreditation Organizations
Meetings, outside CTSI
Face-to-face interaction with CTSI representative
Meetings via Zoom, Viber or other applications
Video recording/ Screenshot
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 / Learners / Participants
Registration Department
Comply with the requirements of MARINA, OPITO, GWO,TESDA for recording of trainees’ / learners’ / participants’ 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
Client Services Department
For marketing collaterals (brochures, calendar) and for posting on the website and CTSI Facebook pages (photos/ videos collected during conduct of training)
Posting of positive feedback (from email and CEQ) on CTSI website (Testimonials) and CTSI Facebook Pages
Business Development
Documentation of training thru photos/ videos collected during conduct of training (including video recording of online training via Zoom application)
Posting on the website and CTSI Facebook Pages (photos/ videos collected during conduct of training)
HSSEQ Departments
Internal audit purposes
Document evidence of compliance to CTSI Management System
Accounting
For walk-in trainees / learners / participants: To process tax and issuance of official receipts
Training Department
Safekeeping of the video recording of online training via Zoom application
Posting on the website and CTSI Facebook Pages (photos/videos collected during conduct of training)
Document evidence of audits conducted by certifying bodies
Clients / Suppliers / Service Providers
Marketing Department (clients)
Client Services Department (clients)
Registration Department (clients)
Admin Department (Suppliers / Service Providers)
Establish contact (text/ chat messaging, call or email) regarding our training and services (for clients)
Establish contact (text/ chat messaging, call or email) regarding the products and services we require from our suppliers and service providers
Maintain database for easy access of contact details
Documentation of meetings conducted via Zoom, Viber or other applications
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
Training Department (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/ chat messaging, call or email) regarding work
Maintain database for easy access of contact details
Marketing Department
Client Services Department
For marketing collaterals (brochures, calendar) and for posting on the website and CTSI Facebook Pages (photos/ videos collected during conduct of training)
Business Development Department
Documentation of training thru photos/ videos collected during conduct of training (including video recording of online training via Zoom application)
Posting on the website and CTSI Facebook Pages (photos/videos collected during conduct of training)
HSSEQ Department
Internal audit purposes
Document evidence of compliance to CTSI Management System
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
Department Head responsible for meetings via Zoom, Viber or other applications
Documentation of meetings conducted via Zoom, Viber or other applications
Document evidence of audits conducted by certifying bodies
Applicants
HR Department and Department heads
Verify identity and qualification
Establish contact (text message, call or email) regarding
Third-party Accreditation Organizations
BDD, Quality, Admin Departments
Establish contact (text message, call or email) regarding auditrelated activities and other inquiries
Photo / Video documentation of the audit
Documentation of meetings conducted via Zoom, Viber or other applications
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) CTSI Pasay 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’ / learners’ / participants’ personal data information to the following third-party organizations:
OPITO – training records of learners 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. Enrollment reports are also uploaded in MISMO.
GWO – training records of participants 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
Employees’ collected personal data information may also be disclosed/ shared to clients and certifying bodies, upon request, during audits.
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
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