Metro Pacific Tollways Corporation and its subsidiaries1 (the “Group”) respect your right to privacy and are committed to complying with the Data Privacy Act of 2012, its Implementing Rules and Regulations (IRR), and the issuances of the National Privacy Commission (NPC).

This Privacy Notice (the “Notice”) explains how we collect, use, retain, disclose and dispose of personal data of applicants, employees, and all individuals working for or on behalf of the Group, as well as former employees including retirees and separated personnel).

1. SCOPE
   This Notice applies to all personal data collected, used, stored, and shared by the Group in relation to job applicants during the recruitment process. Our Human Resources (HR) function operates as part of a shared services model under NLEX Corporation, managing recruitment processes on behalf of various business units within the Group.
   
   
2. TYPES OF PERSONAL DATA WE COLLECT
   We collect the following categories of personal data during the application and recruitment process through online or physical submissions by applicants, or through employee referrals, including resumes, curriculum vitae, and other necessary documents in compliance with the Group’s hiring procedures:
   
   
   • Personal Information: such as, but not limited to, your full name, date of birth, nationality, gender, LinkedIn Profile and other biographical details.
   • Contact Information: Personal email address, mobile number, and residential address.
   • Resume and Employment Data: Resume/CV, employment history, job titles, job summaries, and references.
   • Education Details: Educational background, degrees, fields of specialization, and certifications.
   • Emergency Contacts: Names, relationships, and contact details.
   • Salary Information: Current and expected salary.
   • Background Verification Records: Relevant background verification details such as previous employers, character references, educational details and criminal history, if any.
   • Medical Records: such as pre-employment medical exams and related health information.
   • Miscellaneous Information: Additional information such as how the applicant learned about the position, and employment connection.
     
     Applicants are responsible for obtaining the consent of their emergency contacts, character references, and employment connections before providing their personal data in the application form.
   
   
3. PURPOSE OF PROCESSING PERSONAL DATA
   Your personal data is processed for the following purposes:
   
   
   • Recruitment and hiring – Evaluating job applications and conducting background checks.
   • Pre-employment assessments – facilitating tests, interviews, and skill evaluations.
   • Regulatory Compliance – Ensuring compliance with labor laws and other applicable regulations.
   
   
4. LEGAL BASIS FOR PROCESSING PERSONAL DATA
   We process personal data based on the following legal bases under the Data Privacy Act of 2012:
   
   
   • Consent – For background verification records that require consent such as, but not limited to, educational details and criminal history.
   • Legitimate Interests – For evaluating qualifications and determining suitability for the role, ensuring workplace security, and verifying provided information.
   • Fulfillment of Pre-Contractual Obligations – For data necessary to proceed with an employment offer.
   • Legal Obligation – For mandatory government employment requirements, including pre-employment medical exams.
   
   
5. RETENTION AND DISPOSAL OF PERSONAL DATA
   
   
   • Applicants – Unsuccessful applications will be retained for 2 years for future opportunities, unless the applicant requests immediate deletion.
   • Hired Candidates – if hired, your application data will be transferred to your employee records.
   
   
6. SECURITY MEASURES, STORAGE, AND TRANSMISSION OF PERSONAL DATA
   

   We take reasonable and appropriate measures to protect personal data in accordance with applicable laws, industry standards, and company policies. This includes managing access controls, securing corporate-issued devices, investing in the latest Information Security Capabilities, and implementing security solutions to prevent unauthorized access, such as, without limitation to, password protection, multi-factor authentication, and encryption. Personal data is pseudonymized and anonymized, stored securely, and access is restricted to authorized personnel based on their job roles and responsibilities and subject to contractual obligations when processed by third parties. Data transmission and handling practices comply with industry standards to ensure confidentiality and integrity.

   The Group utilizes a Human Capital Management System (HCMS) for storing, processing, and managing its applicants’, employees’, and separated employees’ personal data.

   If you believe that your privacy has been compromised, please contact us immediately.

   You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be absolutely guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.

   Your password is the key to your account. Please update it regularly and use unique numbers, letters, and special characters, and do not share your password to anyone.

   
   
7. SHARING AND DISCLOSURE OF PERSONAL DATA
   

   We may share your personal data with:

   • Third-party service providers (e.g., background check providers and HCMS providers) for employment verification and application processing.
   • Business units within the group – Your data may be shared internally if you apply for positions across different units of the Group.
   
   
8. DATA SUBJECT RIGHTS
   

   Under the Data Privacy Act of 2012, you have the following rights:

   • Right to be informed – Know how your data is collected and processed.
   • Right to reasonable access – object to the processing of your personal data if processing is based on consent or legitimate interest.
   • Right to correct – dispute the inaccuracy or error in your personal data and have it corrected.
   • Right to erasure – Request deletion of unnecessary data.
   • Right to data portability – Obtain a copy of your data in a portable format.
   • Right to file a complaint – Report violations to the NPC.
   • Right to Damages – seek compensation if your personal data is misused, incorrect, outdated, or obtained unlawfully, especially if it violates your rights.
   
   
9. Updates or Changes to the Privacy Notice
   

   The Group reserves the right to update or revise this Notice at any time and as required by latest amendments to the Data Privacy Act of 2012, its Implementing Rules and Regulations, issuances of the NPC, or when there are improvements and changes to the collection, processing, sharing or disclosure, retention, and disposal of your personal data. Previous versions of the Notice will be retained and provided to data subjects upon request.

   Last updated: 12 March 2025

   
   
10. CONTACT INFORMATION
    

    For HR-related privacy concerns, you may contact:

    Data Protection Officer – NLEX
    NLEX Corporation
    NLEX Compound, Km.12, Balintawak,
    Caloocan City
    Data Protection Officer – NLEX
    dataprivacyoffice@nlex.com.ph
    
    For group-wide privacy related concerns, you may also contact:
    
    Group Data Protection Officer
    Metro Pacific Tollways Corporation
    5th Floor, Tower 1, Rockwell Business Center,
    Ortigas Avenue, Barangay Ugong,
    Pasig City
    data privacyoffice@mptc.com.ph