PRIVACY NOTICE

          (In compliance with Republic Act 10173 otherwise known as the Data Privacy Act of 2012)

 

Purpose

 

We at Composite Wing Savings & Loan Association, Inc. (CWSLAI) value the personal data entrusted to us. We are committed to protect and respect your personal data privacy.  This Privacy Notice outlines the ways in which we collect, process, protect and share your personal data. We are at the forefront of not only implementing but also complying with the Data Privacy Act of 2012 (DPA).

 

Personal data

 

In this Privacy Notice, “Personal Data” refers to all types of information: (a) personal information; (b) sensitive personal information; and (c) privileged information as defined and classified in DPA.

 

Service description

 

CWSLAI is a Non-stock Savings and Loan Association authorized by the Bangko Sentral ng Pilipinas (BSP) and dedicated to provide quality, responsive and efficient financial services to our members. We collect personal data when you avail or utilize the following services:

  1. Membership. PAF military and civilian personnel, and pensioners of AFP and PVAO who are eligible to apply as members of our association.

  2. Loans. Members of CWSLAI may apply for PAF salary, AFP/PVAO pension and sufficient fund loans.

  3. Capital Contribution. Members are required to maintain at least P1,000.00 capital contribution to the association.

  4. Savings Deposits. Members may invest in Savings Deposit (SD) with competitive interest rate.

  5. PVAO Pension Account (PPA) – Members who are PVAO pensioners may opt to choose CWSLAI as its servicing financial institution where PVAO pension is directly transferred to their PPA in CWSLAI.

  6. Withdrawal. Any form of withdrawal: (a) capital contribution; (b) savings deposit; (c) PVAO pension; (d) insurance claims; and others.

 

Personal data that are collected

In order for our members to experience the best services we offer, we collect personal information. The types of personal information that we require may include personal data and sensitive personal data depending on the products, services or other transactions you avail or wish to avail from us which may include:

          Full name, gender, place and date of birth;

          Residential/permanent address;

          Contact details, including telephone number and email address;

          ID Picture;

          Specimen signatures and fingerprints/biometrics;

          Copy of Military/Civilian, AFP or PVAO ID;

          Copy of other valid identification cards;

          Salary or pension information;

          Employment or business information;

          Beneficiaries information (where applicable);

          Health information;

          Latest billing proof of address (where applicable);

          Images via CCTV and other similar recording devices and processes which may be observed                  when visiting our offices and/or using our other facilities; and

          Other information necessary to provide you with the product or service that you need.

Collection method

 

We have several ways and means to collect your Personal Data to include:

  1. When you fill-out and submit the initial membership or updating forms;

  2. When you enter into loan agreement or provide documentation or information in respect of your transactions with us, or when you avail of our services;

  3. When we conduct marketing activities and for documentation and reference purposes we ask for your personal information;

  4. When you interact with our personnel, example via letters and emails;

  5. When we seek information about you and receive your Personal Data from third parties in connection with your transactions with us, like your salary and pension details from finance centers when you avail loans;

  6. When we verify your information or seek additional information using the Armed Forces of the Philippines Pension & Gratuity Management Center website.

  7. When you enter in our offices that are equipped with CCTV cameras.

 

Timing of collection

 

When you transact to any CWSLAI office we require personal data before we process your transaction for verification and as supporting document on top of historical personal data under our custody.

 

Purposes of collected Personal Data

 

In adherence to the principles of transparency, proportionality and legitimate purpose, we collect your personal data for these reasons provided you give us your consent:

 

  •  To verifying your identity and customer due diligence;

  • To process your membership application or update your membership records;

  • To processing your loan application, bill and collect through finance centers and banks;

  • To process your deposits and placements of investment, withdrawals and claims;

  • To offer direct marketing;

  • To respond from your inquiries through phone;

  • To process and handle your complaints, queries, requests, feedback and suggestions;

  • To provide announcements, responses and security.

 

Storage and transmission of Personal Data

 

We will maintain records of your personal data stored in our database and copies of your documents both in hard and soft copies keep in our system and office and or records center.  We take necessary security measures to protect these data under our custody. We ensure that only authorized CWSLAI personnel operating in different locations nationwide are given access to your personal data for legitimate purposes and secure personal information through encryption when transmitting your data.  In the same manner, copies of your documents are restricted to authorized CWSLAI personnel only. By submitting your Personal Data, it is understood that you agree that we process, store and if necessary share or transfer your data to third parties.

 

Method of use

 

In addition to the purpose Personal information we collect that are laid down in Section 5, CWSLAI will use your personal data in the conduct of its operation including examinations by internal auditors, external auditors and government examiners. We may also use your personal information as historical data for our business studies.   

Location of Personal Data

Information we collect are entered in our CWSLAI Integrated Savings & Loan Information System (ISLIS). We store and maintain the copies of collected personal data in our records center and/or office/s nationwide.

 

Third party transfer

 

As part of the services we offered to you, the information you provide to us may be transferred to third parties if needed. We establish adequate safeguards for data privacy and security and uphold the rights of data subjects as stipulated in terms and condition of data sharing agreement when we share your personal data. We may share necessary data of our members with other entities including but not limited to:

 

  • Philippine Air Force / PVAO / Armed Forces of the Philippines Finance Centers. To verify or confirm members’ personal information including pension details to avail our loan products and likewise for collection purposes we may share your personal data to finance centers.

  • Insurance Providers. Part of our association’s policy is to insure all loans granted, which requires transfer of personal data and may sometimes require sensitive personal data pertaining to health conditions, for the benefit of our members and their dependents and to safeguard the association from sudden death of borrowers.

  • Collecting agencies. For delinquent borrowers, we take necessary actions to recover the amount due from our borrowers by hiring collecting agents whom we will provide necessary personal data.

  • Banks. When we issue checks or transfer funds directly to your accounts or deduct your monthly loan amortization from your servicing bank, we share necessary data to fulfill the transactions.

  • External Auditor. We engage the service of an external auditor, which may require examination through sampling of documents and files, to provide an independent opinion as to whether the financial statements present fairly, in all material respects, an entity's financial position, results of operations, and cash flows in conformity with generally accepted accounting principles.

  • Consultants. In some circumstances when necessary, we engage the services of consultants for their expertise in their fields, we may share your personal data solely for the purpose of the engagement.

  • Programmer. We outsource the services of a programmer who may have access to your personal data for the maintenance and upgrading of our system.

 

CWSLAI will disclose or share your personal information, without notice, only if required to do so by law or if such action is necessary to: (a) comply with any legal requirements; (b) protect and defend the rights or property of CWSLAI; and (c) act under exigent circumstances to protect the personal safety of the general public.

 

Retention period

 

CWSLAI will only retain your personal information for as long as it is necessary for the stated purpose, taking into account also our need to answer queries or resolve problems, provide improved and new services, and comply with legal requirements under applicable laws.

 

This means that we may retain your personal information for a period of 10 years after termination of your membership. When the personal information that we collect is no longer required, we destroy or delete it in a secure manner.

 

Participation of data subject

 

As a data subject you have the following rights relative to your personal data:

  1. Right to be informed of the processing of your personal information.

  2. Right to object to the processing of your personal information.

  3. Right to access the content, sources, names and addresses of recipients, and reason for disclosure to the recipients, and name, designation and address of the personal information controller.

  4. Right to correct any error in your personal information.

  5. Right to block/remove your personal information from CWSLAI's records.

  6. Right to data portability or to obtain a copy of the data being processed in an electronic or structured format.

  7. Right to be indemnified for damages sustained due to inaccurate, incomplete, outdated, false, unlawfully obtained, or unauthorized use of your personal information.

  8. Right to file complaints for violations of the Act, its implementing rules, and your rights as data subject.

 

We may charge a fee for processing your request/s for access and/or update. Such a fee depends on the nature and complexity of your request. Information on the processing fee will be made available to you prior to making the request.

 

Inquiry

 

You have the right to ask us not to process your Personal Data or modify your freely given consent. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by contacting us with this number 889-7830 local 310 through our Data Protection Officer.

 

For any queries, clarifications or requests on any aspect of this Notice, you may exercise your rights pertaining to your personal information or to provide any feedback about our processing of personal information, you may visit any of CWSLAI office or you may contact us with this number 889-7830 local 310. You may also email your concerns at felixpagaduan@cwslai.com.