The Asia Internet Coalition (AIC), US-ASEAN Business Council and Information Technology Industry Council (ITI) and our members (“We”) wishes to express our sincere gratitude to the Committee on Information and Communications Technology, for the opportunity accorded in August to submit comments on the amendments to the Philippines Republic Act No. 10173 (the Substitute Bill on Data Privacy Act) under House Bill Nos. 01188 and 05612.
As responsible stakeholders in this policy formulation process, we appreciate the ability to engage with the Technical Working Group (TWG) on key elements of the data protection framework in the Philippines. Collectively, we represent the internet industry and have partnered with the Government of Philippines to promote stakeholder dialogue and best practices on ICT and the digital economy.
Although we appreciate the Philippines government efforts towards developing the DPA, we believe that there are concerns regarding its provisions, aspects of which contradict widely implemented regulations such as the EU GDPR. Furthermore, existing provisions would significantly alter the landscape for digital companies and make it difficult for them to provide their services to citizens and businesses in the country. We strongly recommend that the DPA should have more parity with the best practices, on the grounds that standardization of national data protection regime to help improve compliance and improve the business environment. It is useful and important to recognise that many of the ambitious conversations in this area are the subject of in-depth, evidence-based, and lengthy policy research and exchanges, where a panoply of policy solutions are being explored rather than a single legislative route or a limited set of questions.