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Philippines: NPC releases Complaint-Affidavit template for data privacy violations

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The Philippine National Privacy Commission (NPC) has rolled out a new Complaint-Affidavit template, effective 1 July 2025. This updated template standardizes the format and structure of complaints filed with the NPC, specifically those relating to alleged violations of the Philippine Data Privacy Act (DPA).

The NPC also announced that it will no longer accept the previous version of the Complaint-Affidavit as 31 July 2025 or 30 days from the date of public notice.

Failure to comply with the proper form and content of the new Complaint-Affidavit may result in the outright dismissal of the complaint, pursuant to the current NPC rules of procedure.

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Clients that intend to file a complaint with the NPC, such as those filing on behalf of data subjects, must ensure that any Complaint-Affidavit uses or follows the newly prescribed format. Failure to comply may be raised as an affirmative defense by the respondent, or serve as a basis for the NPC to dismiss the complaint outright for insufficiency in form and/or substance.

Quisumbing Torres is available to assist clients in navigating the NPC complaints process, including preparing or responding to complaints filed with the NPC.

For assistance or further inquiries on matters related to the DPA, please feel free to reach out to Quisumbing Torres’ Intellectual Property, Data and Technology Practice Group.

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Please contact QTInfoDesk@quisumbingtorres.com for inquiries.

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Bienvenido Marquez III is a partner and head of Quisumbing Torres' Intellectual Property, Data and Technology Practice Group. He also co-heads the Consumer Goods & Retail Industry Group and is a member of the Technology, Media & Telecommunications Group. He participates in initiatives of Baker & McKenzie International of which Quisumbing Torres is a member firm. Bien has vast experience in handling IP enforcement litigation, trademark and patent prosecution and maintenance, copyright, data privacy, information security, IT, telecommunications, e-commerce, electronic transactions, cyber security and cybercrime.

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Divina Ilas-Panganiban is a partner in Quisumbing Torres’ Intellectual Property, Data and Technology Practice Group and co-heads the Technology, Media & Telecommunications (TMT) Industry Group. Divina's practice focuses on the protection of trademarks, copyright, patents and other intellectual property rights. She also assists clients in licensing and IP commercialization transactions, including franchising arrangements. She has advised various clients on regulatory and compliance matters, and has extensive experience in IP litigation cases, domain name disputes, data privacy, data breach and cyber security matters. She is an accredited arbitrator of the Philippine Intellectual Property Office and often serves as resource speaker in local and international seminars on IP and IT laws.

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Pepe is the National Managing Partner in Mexico. He is recognized as a leading practitioner in real estate law by Chambers Latin America.

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Micah Mirra Borja is a junior associate in Baker McKenzie's Manila office.

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