Philippines: Closed consultation on NPC guidelines on legitimate interest

On 28 November, the Filipino National Privacy Commission (NPC) closed consultation on the guidelines on legitimate interest. The guideline applies to controllers and third parties that process or are involved in the processing of personal data on the lawful basis of the legitimate interest. The NPC proposes three tests when assessing a legitimate interest as the legal basis for data processing, namely a purpose test, a necessity test, and a balancing test, and defines the steps and criteria for each test. The NPC further establishes that the legitimate interest assessment must be documented and reevaluated regularly. The guideline will enter into force 15 days after its publication in the Official Gazette.