NYK-FIL Maritime e-Training, Inc. (NETI) respects your right to privacy and aims to comply with the requirements of all relevant privacy and data protection laws, particularly the Data Privacy Act of 2012 (“DPA”). The purpose of this policy is to explain what type of information we collect, how we obtain that information and the purpose of its collection. It also defines how we process your personal data in terms of how it is stored, who has access to your information, how it is archived, as well as disposal and possible sharing with third parties. In addition, this policy is meant to advise you of your rights under the DPA.
This policy applies to all information we collect from you or about you, and we only collect it after obtaining your explicit consent to do so. In this policy, the terms, “data” and “information” are used interchangeably.
What information we collect
We collect, acquire, or generate the personal data of our trainees in various forms. These may consist of written records, photographic and video images, digital material, and even biometric records, but generally they will fall under the following categories:
A. Information you provide us when you register/enroll for training.
When you register/enroll with us, we collect, among others:
- directory information, like your name, email address, telephone number, and other contact details;
- data you submit in registration forms, or other written materials;
- data about your personal circumstances, such as your employment record, and medical records.
B. Information we collect or generate during the course of your training.
We may also collect additional information about you during your training, including:
- details about your training, such as the courses you enrolled in, performance during training, attendance record, etc.;
- pictures or videos of your training, via official documentation of such activities, or through recordings from closed-circuit security television cameras installed within school premises.
- your health status such as your blood pressure reading, any illness you report to our company nurse including medication or treatment used; and
- any disciplinary incident that you may be involved in, including accompanying sanctions.
C. Unsolicited Information.
There may be instances when personal information is sent to or received by us even without our prior request. In such cases, we will determine if we can legitimately keep such information. If it is not related to any of our legitimate interests, we will immediately dispose of the information in a way that will safeguard your privacy. Otherwise, it will be treated in the same manner as information you provide us.
How We Collect and Use Your Information
NETI will process personal information from trainees to pursue our legitimate interests as a maritime training institution, including, but not limited to a variety of training, administrative, research, historical, and statistical purposes.
You are not required to submit any information to us but failing to do so may result in not being able to continue with your training. In addition, you also undertake that all data you have shared is true and correct to the best of your knowledge, and that you have not knowingly omitted any related information of an adverse nature.
For example, we may use the information we collect for purposes such as:
- evaluating enrollment in a particular training;
- recording, generating, and maintaining records, whether manually, electronically, or by other means, of grades, trainee’s evaluation, training history, training schedules, and attendance;
- establishing and maintaining trainee information systems;
- sharing of grades, assessment results and evaluation between and among faculty members, and others with legitimate official need;
- investigating incidents that relate to trainee behavior and implementing disciplinary measures;
- compiling and generating reports for statistical and research purposes;
- providing services such as health, insurance, library, transportation, parking, safety and security;
- managing and controlling access to training center facilities and equipment;
- communicating official announcements about your training;
- soliciting your participation in research and non-commercial surveys sanctioned by NETI; and
- other purposes required and/or allowed by law or regulation.
We consider the processing of your personal data for these purposes to be necessary for the performance of our contractual obligations to you, for our compliance with a legal obligation, to protect your vitally important interests, including your life and health, for the performance of tasks we carry out in the public interest (e.g., public order, public safety, etc.), or for the pursuit of the legitimate interests of NETI or a third party. We understand that the DPA imposes stricter rules for the processing of sensitive personal information and privileged information, and we are fully committed to abiding by those rules. If we require your consent for any specific use of your personal data, we will collect it at the appropriate time.
Please note further that we will not subject your personal data to any automated decision-making process without your prior consent.
How We Share, Disclose, or Transfer Your Information
To the extent permitted or required by law, we may also share, disclose, or transfer your personal data to other persons or organizations in order to uphold your interests and/or pursue our legitimate interests as a maritime training institution.
For example, we may share, disclose, or transfer your personal data for purposes such as:
- sharing information about your training with your Principal and/or sponsoring Manning Company upon their request;
- reporting and/or disclosure of information to the NPC and other government bodies or agencies such as MARINA, POEA, and OWWA when required or allowed by law;
- sharing of information with entities or organizations for accreditation;
- complying with court orders, subpoenas and/or other legal obligations;
- conducting internal research or surveys for purposes of institutional development;
- use of photos, videos, and other information in order to promote NETI, including its activities, through marketing or advertising materials, such as brochures, website posts, newspaper advertisements, physical and electronic bulletin boards, and other media; and
- publication of communications with journalistic content, such as news information publications, and social media sites.
How We Store, Retain and Dispose Your Information
NETI takes reasonable precautions to keep your stored data secure and employs organizational, managerial, electronic, technical, and physical security measures in order to protect your data from breaches that would result in loss or misuse.
Your personal data is stored and transmitted securely in a variety of paper and digital or electronic formats. Access to your personal data is limited to authorized personnel who have a legitimate interest in them for the purpose of carrying out their contractual duties.
Unless otherwise provided by law or by appropriate company policies, we will retain your relevant personal data indefinitely for historical and statistical purposes. NETI maintains archiving and deletion procedures so that personal data is deleted after a reasonable amount of time relative to the purpose for which your information was collected and held. Should certain laws or government institutions require that data be kept for a certain time, we will comply with all applicable rules and regulations.
The sections below are applicable to NETI’s website and Online Enrollment System. They describe how we collect, protect and manage the information we collect from or generate about you every time you access these sites.
What We Collect
Whenever you browse this site, we automatically record non-personal and technical information about your visit. They may include the following:
- browser type and version
- browser plug-in types and versions
- date and time of connection
- length of visits to certain pages
- IP address
- operating system
- pages viewed/searched for
- page interaction information (e.g., scrolling, clicks, and mouse-overs)
- page response time
- time zone setting
- download errors
- platforms and referrers
In most instances, the said technical information may not be readily used to determine your identity.
Why We Collect Them
The recorded information is used primarily to help keep our website safe and secure. In addition, it may also be used for bug tracking, investigations relating to a security or data breach and usage statistics. If we need to use any collected information that constitutes personal data for purposes not compatible with those listed here, we will inform you prior to such use and, where required by law, obtain your consent.
How We Use, Store, and Retain Them
All information collected by domains maintained by NETI are stored in its data center that is accessible only to authorized personnel and agents, such as, in some cases, third party service providers. The collected information is kept for as long as necessary to achieve the declared purpose for its collection. In no case is it shared with or transferred to other persons or organizations, unless required or permitted by law.
To serve you faster and with better quality, we use cookie technology on our website. Cookies are small bits of code, usually stored on a user's computer hard drive, which enable a website to personalize itself for each user by remembering information about the user's visit to the web site. The Help section of the toolbar on most Internet browsers will tell you how to prevent your browser from accepting new cookies or how to configure your browser to reject cookies altogether. If you disable cookies, you might not be able to access important functions or features of this website and your use of the website may be limited.
Your rights and how to exercise them
As a data subject, or a person from whom NETI collects, processes and stores data, you have certain rights as specified in the DPA. We feel it is important that you are aware of and understand these rights as they apply to you, so what follows is an excerpt from the National Privacy Commission website at https://privacy.gov.ph/know-your-rights/
- The right to be informed;
- The right to access;
- The right to object;
- The right to blocking or erasure;
- The right to damages;
- The right to file a complaint;
- The right to rectify; and
- The right to data portability
Should you wish to exercise these, or if you have some questions relating to the Academy’s data protection efforts, please contact our Data Protection Officer at firstname.lastname@example.org or you may write to:
NYK-FIL Maritime E-Training, Inc.
Attention: Data Protection Officer
Knowledge Avenue, Carmeltown
Canlubang, Calamba City
NETI reserves the right to update our policies in accordance with any changes in the law or in the way in which we pursue legitimate interests as an educational institution or process your personal data. When permissible, we will let you know through other means of communication. However, any modification is effective immediately upon posting on this website.