4 May 2022

MRS. VIRGINIA G. GUANLAO

51 A-Kanlaon Street,
Mandaluyong City

Dear Mrs. Guanlao,

This has reference to your letter addressed to the Hon. Andrea B. Ynares, City Mayor, requesting
for a reconsideration to redeem a parcel of land located in Barangay San Jose, Antipolo city
covered by Original Certificate of Title No. 0-1588 and Tax Declaration No. AP-002-06950/PIN
177-02-002-019-069 with a total area of Seven Thousand Four Hundred Ninety One (7,491) square
meters.

We regret to inform you that requested records contain information that is protected by the Data
Privacy Act of 2012 (“DPA”). Under the DPA, processing of personal data shall be allowed,
provided it complies with the law and adherence to the principles of transparency, legitimate
purpose, and proportionality.

In connection with the foregoing, Section 12 of the DPA provides for the parameters for lawful
processing of personal information of data subjects:

“SEC. 12. Criteria for Lawful Processing of Personal Information. – The

processing of personal information shall be permitted only if not otherwise
prohibited by law, and when at least one of the following conditions exists:

(a) The data subject has given his or her consent;

(b) The processing of personal information is necessary and is related to the
fulfilment of a contract with the data subject or in order to take steps at the
request of the data subject prior to entering into a contract;
(c) The processing is necessary for compliance with a legal obligation to which
the personal information controller is subject;
(d) The processing is necessary to protect vitally important interests of the data
subject, including life and health;
(e) The processing is necessary in order to respond to national emergency, to
comply with the requirements of public order and safety, or to fulfill functions of
public authority which necessarily includes the processing of personal data for
the fulfilment of its mandate; or
(f) The processing is necessary for the purposes of the legitimate interests
pursued by the personal information controller or by a third party or parties to
whom the data is disclosed, except where such interests are overridden by
fundamental rights and freedoms of the data subject which require protection
under the Philippine Constitution.”

Applying the aforequoted provision of the DPA, the data/information in the possession of the City
Government of Antipolo is protected from unlawful processing, i.e., processing that is not within
the parameters set forth in Section 12 thereof. Thus, in the absence of such, the City Government of
Antipolo is duty bound to protect the said information against any unlawful processing.

Very truly yours,

ATTY. CEDRICK JUSTICE U. CAPIRAL

City Legal Officer
Copy furnished:
Office of the City Mayor