CCTV Privacy Policy

1. Introduction

ASEC Development and Construction Corporation (“ASEC” or “the Company”) recognizes that CCTV plays a legitimate role in maintaining a secure and safe environment for all its employees, workers and visitors. ASEC acknowledges, however, that the use of this technology may raise valid concerns about its effect on individuals’ privacy rights.

This policy serves to directly address those concerns. Because the images recorded by CCTV Systems may contain personal data, they must be processed strictly in accordance with the Guidelines on the Circular on CCTV systems issued by the National Privacy Commission (NPC Circular No. 2024 – 02) and all other related data protection laws of the Philippines. ASEC is fully committed to complying with its legal obligations and ensuring that the legal rights of all data subjects concerning their personal data are acknowledged and respected.

2. Purpose

We utilize Closed Circuit Television (CCTV) Systems to record images, enabling us to provide a safe and secure environment for everyone who works at and visits ASEC’s premises, and to protect our property.

Monitoring our CCTV Systems helps us to achieve the following specific objectives:

• • Maintain public safety for all individuals on our premises.
  • Maintain the security and integrity of our company’s property.
  • Assist in the prevention of crime and unauthorized activity.
  • Reduce the fear of crime and offer safety assurance to all employees and workers.
  • Facilitate the apprehension and prosecution of offenders involved in criminal activities.

We consider the processing of personal data captured by these cameras to be within our legitimate interests, as it is essential for us to maintain a secure and safe workplace for our personnel and visitors.

3. Operational Details

• • The storage capacity is 10TB at Head Office and 8TB at the jobsite;
  • The CCTV camera will only record image and will not record the sound;
  • 16 CCTV cameras are in operation 24 hours a day in Head Office and minimum of 6 cameras in jobsites.
  • CCTV cameras are located at the Reception, Meeting area and workplace area.
  • CCTV cameras are located at Gate, Operations’ office, Support office, Warehouse storage area, outside the warehouse storage area across the jobsite

4. Access and Disclosure

4.1 Control of Access

Access to our CCTV Systems and any associated recorded images that contain personal information (“Recorded Materials”) is strictly controlled. Access is limited only to personnel who require it for the purposes of this policy and existing company policies and must be approved by IT Manager.

Disclosure of Recorded Materials to external third parties will only occur to fulfill the purposes stated above and must always comply with applicable data privacy laws.

4.2 Access purpose

Recorded Materials may only be viewed for strictly defined purposes. These authorized purposes are:

1. 1. 1. The investigation of an alleged crime.
      2. The investigation of a security incident.
      3. The investigation related to employee discipline outlined on company code of conduct.

Any viewings that are authorized must be meticulously registered in a dedicated log. After an incident occurs, we retain the right to use the Recorded Materials to assist in the identification and detection of offenders or in the thorough investigation of a security incident and/or employee discipline.

4.3 Disclosure to Third-parties

CCTV footage should not be required by or provided to third parties, except in the specific circumstances listed below:

• • • Footage may be released to support official law enforcement activities and criminal investigations.
    • Disclosure is authorized when explicitly mandated by a valid court order.
    • Footage will be provided to facilitate formal administrative investigations.
    • Disclosure to the media is subject to strict conditions. The release must always adhere to general principles of privacy, the rights of data subjects, and the codes of conduct and ethical standards of journalism. ASEC will not disclose CCTV footage of identifiable individuals to the media for mere amusement or entertainment purposes, unless the release is done with the consent of the data subjects or is otherwise permitted under applicable laws.
    • Any request for CCTV footage or images from other third parties will be evaluated with greater scrutiny to prevent any violation of the privacy rights of the data subjects concerned. ASEC will determine these requests on a case-by-case basis. Footage will only be released when our determination shows that the requesting third party’s needs outweigh the privacy rights of the data subjects to whom the CCTV footage and images pertain.

4.4 Access by You

The privacy laws grant individuals specific data privacy rights, including the ability to access, modify, or delete their personal information. Furthermore, individuals may have the right, under specific circumstances, to restrict how we process their data.

• • • Right to Access. You have the right to access or request a copy of the CCTV footage or any other data we hold about you. Please use the contact information provided below to submit your request. Reviewing only (viewing the footage) – Within 5 working days from receipt of request ; Obtaining a Copy – Within 15 working days from receipt of request.

Important Note: We may refuse your request for access or a copy if it conflicts with our legal rights, a court order, or the privacy rights of other individuals. If your request is rejected, we will inform you of the reasons.

• • • Right to Object. You have the right to object to the collection, use, or disclosure of your CCTV Data if the processing is based on legitimate interest and/or the legitimate interest of other persons.
    • Your objection request will be processed within 7 working days of our receiving it.
    • We may refuse your request if we can demonstrate a more important legal interest in collecting, using, or disclosing your CCTV Data, or if the processing is necessary for establishing, performing, defending, or exercising legal claims, or for complying with applicable laws.
    • Right to Withdraw Consent. For any specific purposes where you have previously granted us consent to process your Personal Data, you retain the right to withdraw that consent at any time.
    • Right to Erasure. You have the right to request that we delete your CCTV Data or render it unidentifiable (anonymize it) to the extent permissible under law. This right does not apply in cases where we are legally required to retain your CCTV Data, such as when necessary for establishing, performing, defending, or exercising legal claims, or for complying with the law.

Should you wish to exercise these rights by requesting a copy of the data we hold, or if you need to change or completely erase any portion of your information, please use the contact details provided below to reach us.

Address :      3rd Floor Tower A, The Regalia Corporate Center, 150 P. Tuazon Blvd., Cubao, Quezon City

Phone No.:     (02) 3-473-4751 / (02) 8-709-3640 loc. 135

Email Address: dpo@asecconstruction.com

5. Retention Policy

Recordings captured by our CCTV cameras are stored within Hard Disk Drives (HDDs) located at the ASEC Head Office and at the EHS Office for each jobsite. These HDDs are used to retain recordings for a maximum period of 30 days, after which all footage is permanently deleted.

Recordings may be kept beyond the standard 30-day limit only if officially requested by relevant authorities as evidence for a criminal investigation, or if needed for internal staff improvement or disciplinary investigations.

We commit to ceasing retention and permanently deleting or anonymizing personal information once the original collection purpose has been fulfilled, or immediately upon confirmation of your valid erasure request.

1. 6. Security Measures

Recorded Materials must be stored securely and strictly prohibited from placement in locations accessible to the employees (with the sole exception of those granted explicit access rights), the public, or from being distributed in any manner.

We are obligated to implement all reasonable precautions necessary to ensure the protection of the Recorded Materials from:

1. 1. Loss, interference, and inappropriate use; and
   2. Disclosure without authorization, unapproved modification, or illegitimate access.
   3. Contact and further Information

If you have questions or concerns regarding our data processing methods detailed in this Privacy Policy, or if you intend to exercise any of your data subject rights, or if you want to submit a detailed written complaint concerning our handling of your personal information, please contact us via email at dpo@asecconstruction.com. We welcome the opportunity to address and resolve your concerns without delay.

Date: 6 November 2025