Privacy Notice

Palawan South Daily Time Record (DTR)

Last updated: October 20, 2026

1. Who is responsible?

The system is being developed for the Palawan South Program Operations workflow. During development, questions about the DTR application may be directed to the designated DTR system administrator through the official channel provided by the relevant office. The administrator is a temporary operational contact, not a substitute for the responsible personal information controller or the DSWD Data Protection Officer.

Before production, the responsible office must identify and publish the appropriate personal information controller, verified privacy/DPO contact details, and an approved channel for data-subject requests. No unverified email address or phone number is provided here.

2. What personal information may be processed?

• Identity and account data: Google account email, employee ID, display name, official DSWD email where applicable, and information needed to verify access.
• Employment and authorization data: assigned office or municipality, role, supervisor, active/account status, and registration request and approval decisions.
• Attendance data: attendance event (morning time-in, noon time-out, afternoon time-in, or end-of-day time-out), server-assigned date and time, and record status.
• Photo data: a selfie captured for an attendance event and associated file metadata.
• Location data: GPS latitude and longitude, reported GPS accuracy, and calculated distance from the assigned office for geofence validation.
• Security and audit data: records of account registration decisions, attendance actions, administrative review, corrections, and other system actions needed for accountability and security.

The system is not intended to collect unrelated personal information. Do not upload real employee data, selfies, or location information during development or testing unless the responsible office has specifically authorized the test and approved the safeguards.

3. Why would this information be used?

The intended purposes are to authenticate an account, check whether a staff member is authorized to use the system, review personal Gmail registration requests, record attendance, validate whether an attendance submission is within the assigned office geofence, support supervisor review and authorized corrections, investigate discrepancies, maintain audit trails, and protect system integrity.

Personal information must be processed only for specified and legitimate purposes and in accordance with the applicable requirements of the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its implementing rules, and other applicable government policies. The responsible office must determine and document the appropriate lawful basis and any applicable conditions before production processing. This notice does not independently establish that lawful basis.

4. How does account access work?

• An authenticated @dswd.gov.ph account may skip the separate personal-account registration request, but it is not automatically entitled to use attendance functions. The account must match an active, authorized staff record and is subject to role-based permissions.
• A personal Gmail account must submit a registration request. It remains blocked from attendance until an authorized administrator verifies the request and approves and links the account to the appropriate employee record.
• Other email domains are not permitted under the intended staff access policy unless the responsible office formally authorizes a different policy.

A Google sign-in alone does not establish employment or attendance authorization. Access decisions must be enforced on the server, not merely by hiding or showing controls in the browser.

5. Where is information stored and who may access it?

The current design uses Google Sheets for staff registry, attendance records, registration decisions, and audit logs, and Google Drive for attendance photo files. Cloudflare Pages is planned to host the web interface. Google services are planned for sign-in and data storage. The final deployment configuration and any additional processors or integrations must be documented before production.

Access should be limited to personnel who need the information for an authorized task, based on assigned roles. Attendance records and photo folders must remain private. The system must use server-side authorization, restricted access to the underlying spreadsheet and Drive folder, secure configuration of credentials, and audit logging. No credentials, tokens, or service secrets should be exposed in the browser or committed to the source repository.

These are required safeguards, not a claim that every control is already implemented or independently verified. The system must not be used for official records until the responsible office has tested and accepted the controls.

6. Sharing and disclosures

Information should be made available only to authorized staff, supervisors, administrators, auditors, or other recipients who have a legitimate, approved need and a lawful basis to access it. Information may also be processed by the service providers necessary to operate the application, subject to appropriate safeguards and agreements. Any disclosure required by law or an authorized government process must be handled by the responsible office under applicable rules.

The system must not publish attendance records, selfies, or location information publicly. This notice does not authorize unrelated use, public disclosure, or sharing for advertising.

7. Retention and secure disposal

Attendance records, selfies, and related audit records must be retained and disposed of according to the applicable, approved DSWD records-retention and disposition policy and any relevant legal hold or government records requirements. No separate retention period is created by this notice, and no specific number of days or years is asserted here.

Before production, the responsible office must identify the applicable records schedule, assign responsibility for retention and secure disposal, and ensure that deletion from the application and storage systems is handled consistently with approved requirements.

8. Your rights under Philippine data privacy law

Subject to the conditions, exceptions, and procedures under Republic Act No. 10173 and other applicable law, a data subject may have rights including:

• to be informed about the processing of personal information;
• to access personal information held about them;
• to object to processing in circumstances provided by law;
• to request correction of inaccurate or incomplete information;
• to request blocking, removal, or destruction where legally available;
• to seek indemnification for damages as provided by law; and
• to lodge a complaint with the National Privacy Commission when they believe their rights have been violated.

These rights are subject to lawful exceptions and do not necessarily require deletion of official attendance or government records where retention or processing is required by law or an applicable approved records policy.

9. How to make a privacy request or raise a concern

1. Contact the designated DTR system administrator through the official channel provided by your office and state whether you are requesting access, correction, or help with a privacy concern.
2. Provide enough information for the responsible office to locate the relevant record. Do not send passwords, authentication codes, or unnecessary sensitive information.
3. The request should be referred to the responsible office and its designated privacy/Data Protection Officer for identity verification, assessment, and response under the applicable procedures and timelines.

The temporary administrator contact may assist with routing a request but does not make the final determination of data-subject rights. Before production, the responsible office must publish a verified privacy/DPO contact and formal request-handling procedure. If a request concerns an official government record, the applicable records-retention rules must also be considered.

10. Cookies, sign-in, and third-party services

Google sign-in and Google infrastructure are planned for account identity and storage; Cloudflare Pages is planned for web hosting. These providers may process technical information under their own terms and privacy documentation. The final implementation should disclose any additional cookies, analytics, logs, or integrations if introduced. The current design does not require advertising trackers.

11. Security incidents

Suspected unauthorized access, disclosure, loss, or misuse of DTR data should be reported promptly through the official channel provided by the relevant office. The responsible office and privacy personnel must assess and handle incidents according to applicable law and approved incident-response procedures.

12. Updates to this notice

This notice may be revised as the system is built. Material changes should be reviewed by the responsible office and communicated to affected users as appropriate. Publication of this page alone does not mean the system, its lawful basis, or its controls have been approved for production.