Privacy Statement – Employee

Privacy Statement for prospective, active, and separated employees, as well as on-the-job trainees

We value your data 

We value the privacy of our employees and their dependents as well as our job applicants, on-the-job trainees and retirees. We collect and maintain their personal data in connection with our prospective, active, and previous contracts with them, whether for employment or training agreements. We ensure that their information are up-to-date and kept confidential even until their separation from Meralco. 

Collecting your personal data 

We collect your personal data in the course of, or incidental to the conduct of, our business with you. This data include any other information that you voluntarily provide to us for a legitimate purpose declared at the point of collection, as well as information about you that we received from third parties and other sources where the disclosure was subject to a consent that you gave separately, as the result of a legal requirement, or any legitimate purpose made known to you.

Transparency in processing. Whenever we collect personal data, we provide just-in-time privacy notices and consent forms, when applicable, at the point of collection. 

Data minimization. The data we collect is only as much as is relevant and necessary to meet our processing purpose. We collect this personal data in the course of or incidental to our business with you. 

The data we collect. Generally, we collect the following information: 

1. Information you submit when you apply at MERALCO for work or training, including what is contained in your resume or curriculum vitae and application form (e.g., work references). 
2. Information we collect during the processing of your application, such as testing results, employment offer, results of character investigation, and pre-employment medical assessment. 
3. Information we collect and maintain during your employment, such as your personal information, addresses, education records, professional licenses and permits, and government-issued identification information; payroll information, including but not limited to government mandated and third party remittances like SSS, Philhealth, and Pag-ibig membership and contributions, taxes, bank account information; wages; entitlements and benefits; medical and dental care records; emergency contact information; training and certifications; performance evaluation; sanctions; and employment changes / work history.
4. Information we collect and maintain to facilitate your use of tools, equipment, and software that are related to the performance of your duties and responsibilities; to assist you in any work-related issues that you may encounter as you perform your duties and responsibilities, including troubleshooting of technical problems; to develop ways to improve your work conditions, such as automation of transactions and processes.
5. Information you provide about your dependents/beneficiaries for purposes of but not limited to administration of health maintenance plan, insurance claims, or profiling.
6. Information you provide when you participate in our surveys related to internal business processes, such as but not limited to employee engagement events, sustainability efforts, post-training assessments, climate surveys.
7. Information we retain after your separation from service, such as but not limited to pension information, retiree eligibilities and other benefits, bank account information, addresses, beneficiaries, and emergency contact information.
8. Information we may record as you perform your duties and responsibilities, which may include photos and videos of you in the workplace or in other Meralco-sponsored programs that capture your image or voice. When necessary for documentation, communication, or official business purposes, these recordings may also include your name and/or position.
9. Information required to comply with occupational safety and health standards under Republic Act No. 11058, an Act Strengthening Compliance with Occupational Safety and Health Standards, including but not limited to medical assessments and health surveillance for high-risk roles, training records on safety procedures, PPE issuance and compliance logs, incident and accident reports, and participation in safety programs and committees. 

Purpose of Processing 

We store, process, and analyze the collected personal data for legitimate purposes related to, or incidental to, our business operations, including maintaining safety and security within the company premises. 

Specifically, we may store, process, and analyze your personal data for the following and any other legitimate purposes related to the fulfillment thereof: 

1. To handle your application for employment or training. We process your personal data to evaluate your eligibility for employment or training, including the verification of your qualifications, employment history, and character references (background checking).
2. To manage our employer-employee or training relationship. We process your data to maintain your employment, on-the-job training and/or personal records, including your contact information, for operational or administrative efficiency. Specifically for employees, we collect, store, and process your data to administer your pay, statutory and salary deductions, entitlements, and benefits, and those of your dependents or beneficiaries, to conduct your performance reviews and grant rewards, to establish appropriate training and/or developmental interventions including your membership with professional or industry organizations, to monitor your work performance and use of company resources, and to conduct internal investigation and/or administer disciplinary action and sanction as necessary. 
3. To address or enforce legal claims or obligations arising from employment contract or training relationship. We process your data to comply with applicable statutory and regulatory requirements and submissions, including the processing of your work or labor-related claims (e.g. worker compensation, insurance claims, etc.). Your personal data may also be processed to enforce our claims or defend our rights in any proceeding arising from our relationship. 
4. To improve your welfare, productivity, safety, and security at work. We process your data to develop your health and wellness programs, including provision of your medical benefits; to conduct employee engagement activities; to create and maintain user accounts that serve as your personalized work credentials and access rights; and to facilitate and maintain overall productivity, safety, and security in the workplace and in all business operations. We also facilitate corporate social responsibility and other Company programs and events, including the payment of your donation to foundations or charitable institutions through deduction from your payroll account. In compliance with RA 11058, we also process your data to ensure a safe and healthful working environment, including monitoring of workplace hazards, implementation of safety protocols, issuance and tracking of personal protective equipment (PPE), and documentation of safety-related incidents and trainings.
5. To maintain our post-employment relationship. We process your data to administer your pension, retiree eligibilities and other benefits.
6. To prepare publications that feature Meralco. We process your images or voice that we may have recorded in the workplace or during your participation in Meralco-sponsored activities to give the general public previews on the work culture and workplace environment in Meralco. 

How do we process your personal data

1. Data Subject – Prospective, active, and separated employees, as well as on-the-job trainees
2. As needed / as applicable
3. When applicable, data sharing or outsourced processes are covered by DSA, NDA, and/or OAs
4. Engagement – Onboarding, company activities, duties and responsibilities as a Meralco employee, payroll, filing of government mandatories (BIR, DOLE, etc.), benefits processing, etc.

Note: Privacy Notice is process specific while the Privacy Statement is a public commitment to data privacy

Read the diagram as text

The diagram follows the data subject, Meralco, its subsidiary and third parties through the personal-data lifecycle.

1. Collect. Meralco publishes the Privacy Statement and prepares the Privacy Notice and Consent/Acknowledgment Form. You read the privacy notice, statement, notice terms and conditions, and provide consent if you agree (as needed / as applicable). You provide personal information through forms, employment requirements, consent form (as needed / as applicable), etc. Meralco receives the accomplished forms.
2. Store. Meralco properly secures and stores the personal information.
3. Use. Meralco carries out the following processes in the order shown:
   1. Application & Assessment Process
   2. Employee Engagement
   3. Retirement/Resignation/Separation Process
4. Transfer.
   • A subsidiary processes a request/service in fulfillment of the contract. Meralco provides information.
   • Government may request personal data for audit, examination, or investigation (as needed / as applicable). Meralco provides information.
   • Contractors request personal data for background investigation. Meralco provides information.
   The provision of information is subject to note 3 above.
5. Dispose. Meralco conducts the retention and disposal procedure. The diagram routes the final use process and the provision of information to this procedure, then ends.

Sharing your personal data 

Unless you provide specific consent or in instances allowed under law, we do not share your personal data with our business partners or other third parties for their own commercial purposes or benefit. 

Additionally, we do not use your personal data to enable third-party targeted advertisements that are unrelated to our business. 

When data is shared, especially across borders and jurisdictions, we ensure your data is protected through appropriate Data Sharing Agreements. 

In the processing of your personal information, we may have to disclose your data to parties acting as personal information processors, which may fall across these broad categories:

• Authorized Representatives and Consultants. We ensure that our authorized representatives and consultants adhere to the same standards as our employees and trainees, and require them to commit to observing the company’s privacy policies. We require our Authorized Representatives and Consultants to sign a Non-Disclosure Agreement (NDA), to ensure that they process your data confidentially in a manner consistent with the purpose of their employment or engagement. 
• Contractors and Business Partners, including Auditors. We require our contractors, subsidiaries, and business partners to secure and keep your data confidential through appropriate contractual and operational controls. We do not allow our contractors, subsidiaries, and business partners acting as personal information processors to disclose or share your data with others or use it for their own purposes. We take punitive or legal action in cases of proven misconduct. 

In the processing of your personal information, such personal information may nonetheless be disclosed when legally required or when necessary to complete our commitment to provide services to you. 

These entities to whom your personal data may be disclosed include:

• Government entities. Your information may also be disclosed to government entities pursuant to and in compliance with applicable laws and regulations, subpoena or court order.
• Authorized Third Parties for Occupational Safety and Health Compliance. In accordance with Republic Act No. 11058, we may disclose your personal data to accredited health and safety service providers, personal protective equipment (PPE) suppliers, and training institutions engaged by the Company to support the implementation of workplace safety and health programs. These disclosures shall be limited to what is necessary for the fulfillment of such programs and shall be governed by appropriate data sharing or processing agreements.
• Foundations and Charitable Institutions. We may disclose your information to the One Meralco Foundation, the social development arm of Meralco, for the purpose of facilitating your donations made through payroll deductions, in support of corporate social responsibility programs and other Company-led initiatives. 

Keeping your data secure 

We are committed to ensuring the integrity, confidentiality, availability, and security of your information. We implement reasonable organizational, physical, and technical security measures in collecting, processing, transmitting, storing, and disposing your personal data such as using secure servers, firewalls and security controls and ensuring regular conduct of audit and testing of our security protocols. We only store your personal data in Meralco-owned and/or controlled data storage solutions.

For an enhanced online experience, our services are available through compatible devices, such as laptops, PCs, tablets, and mobile phones. For your added security, we recommend that you install anti-virus software on any such device before accessing the internet.

You are responsible for the security of your information once it reaches you or your representative in any medium, including but not limited to written correspondences, bills, emails, system applications, and on-line accounts. 

You should take appropriate measures to ensure that any medium or device you use to monitor or manage your account is secure and not accessible to anyone without permission.

Retaining your personal data 

We keep your personal data only for as long as necessary to fulfill the declared, specified, and legitimate purposes outlined above, or until the processing relevant to those purposes has been completed or terminated. We may also retain your data for the establishment, exercise, or defense of legal claims, or for other business purposes that align with standards established or approved by regulatory agencies governing Meralco.

For further information on our retention rules for documents with personal data, you may refer to our DP FAQ 2021-01 Retention of Documents Containing Personal Data.

Thereafter, your personal data shall be disposed of or discarded in a secure manner that would prevent further processing, unauthorized access, or disclosure to any other party or the public.

Your data subject rights 

If you wish to request a copy of your personal data, or have it corrected or deleted, or to exercise your rights as data subject, you may reach out to us through our Data Privacy Office (DPO). Meralco DPO will promptly respond to your request or questions and also review any feedback that you may have about our Privacy Statement. 

We uphold your right to be informed whenever we provide a link to or a copy of this Statement prior to collecting your personal data or as soon as reasonably practicable after collection. In processing your data for the specific purposes we discussed in this Statement and those that may be related to such purposes, we shall endeavor to prepare privacy notices that remind you how we collect, use, disclose, and process your personal data in the manner described in this Statement, including our procedures relating to cookies, IP addresses and log files. As to any other purpose that you may not find or cannot infer from this Statement, we shall take all reasonable efforts to obtain your permission through a separate consent form that may either require your signature or contain a button that you could click as proof of your consent. 

About this Statement 

From time to time, we may update this Statement to comply with applicable laws, rules, and regulations; to reflect any changes to the foregoing; to align with industry practices; or for other legitimate purposes. 

You may view past versions of the Statement below.