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NPC Advisory No. 2024-04: Guidelines on the Application of Republic Act No. 10173 or the Data Privacy Act of 2012 (DPA), its Implementing Rules and Regulations, and the Issuances of the Commission to Artificial Intelligence Systems Processing Personal Data

Record PH-01 · NPC Advisory No. 2024-04 (Ref. No. DPCD-24-00678)

Issued by
National Privacy Commission (NPC) of the Philippines
Jurisdiction
Philippines
Level · region
National · South & Southeast Asia
Published / adopted
2024-12-19
Language
English
Official identifier
NPC Advisory No. 2024-04 (Ref. No. DPCD-24-00678)

Summary

Advisory of the Philippine National Privacy Commission on how the Data Privacy Act of 2012, its implementing rules and Commission issuances apply when personal data are processed to develop or deploy AI systems, including training and testing. Controllers must explain the purpose, inputs, risks, expected output and impact of the processing; remain accountable, including for processors; set up governance such as privacy impact assessments, continuous monitoring and an AI ethics board; provide meaningful human intervention and a way to contest automated decisions that pose a significant risk; identify and limit bias; avoid 'AI washing'; and keep data-subject rights exercisable throughout.

Safety topics

accountability & liabilitytransparency & labellinghuman oversight

Status notes

Signed by Privacy Commissioner John Henry D. Naga and Deputy Privacy Commissioners Leandro Angelo Y. Aguirre and Nerissa N. de Jesus. Issued under Section 7(g) of the Data Privacy Act, which empowers the Commission to publish a guide to all laws relating to data protection, and Section 9 of the Act's implementing rules. Its description of AI systems cites the EU High-Level Expert Group's Ethics Guidelines for Trustworthy AI, the OECD Recommendation on Artificial Intelligence, ISO/IEC 22989:2022 and NIST AI 600-1. The advisory states that publicly available personal data keep the Act's protection, and that incorporating personal data into data sets does not by itself make data-subject requests unreasonable.

Sources

Open the official source https://privacy.gov.ph/wp-content/uploads/2025/02/Advisory-2024.12.19-Guidelines-on-Artificial-Intelligence-w-SGD.pdf

Local copy

Archived. The browser retry also failed (Browser could not load the page: Page.goto: Timeout 45000ms exceeded.). The official site does not allow automated downloads; the stored copy was provided by Michael Riegler and confirmed by Michael Riegler (issue #155). Last attempt 2026-10-18 08:34:01 UTC

Official source, a copy provided by a person because the site does not allow automated downloads (third-party copy, not published) archive/PH-01/2026-10-18/provided.pdf
Retrieved 2026-10-18 08:09:07 UTC
SHA-256 93a9c89b33f2182ba5be1bb9886401a30bad08d3838b52c39f15ff8c2c8b7e2e

Verification

A
The instrument's own official text, or an official register, was stored and confirms the title, date and status. checked 2026-10-18 · official-url-fetched
Refresh of 18 Oct 2026. privacy.gov.ph refuses the archiver (HTTP 403, and the browser retries time out), so a maintainer downloaded the signed advisory in a browser from the official URL and stored it with archive.py --provide (issue #155); it is the record's official source. The stored PDF (5 pages, text layer read with pypdf) confirms the advisory number, the reference number DPCD-24-00678, the date of 19 December 2024, the subject (the full official title), the legal basis (Section 7(g) of the Data Privacy Act and Section 9 of its implementing rules), the scope (development or deployment of AI systems, including training and testing), the substantive sections and the three signatories. Nothing stored shows a later amendment or replacement. Earlier statements in the notes that the advisory was issued alongside NPC Advisory No. 2024-03 and about pending AI bills rest on no stored source and were dropped.
Second check: Independent check by Claude Code (claude-sonnet-5-5), 2026-10-18: 7 field(s) supported.

History

  1. 2026-10-18notes: Signed by Privacy Commissioner John Henry D. Naga and Deputy Commissioners Leand → Signed by Privacy Commissioner John Henry D. Naga and Deputy Privacy Commissione — kept the signatories; added the legal basis and the sources of the AI definition from the advisory; dropped the claims that NPC advisories are not regulations, that it was issued alongside Advisory 2024-03 and that AI bills are pending, which no stored source supports2026-10-18-refresh-recheck-rest · Claude Code (claude-opus-5-5)
  2. 2026-10-18summary: Guidance from the Philippine data protection regulator on how the Data Privacy A → Advisory of the Philippine National Privacy Commission on how the Data Privacy A — rewritten from the stored text: drops 'profiling' and 'security measures proportionate to AI risks', which the advisory does not say, and adds its accountability, governance (PIA, monitoring, AI ethics board), human intervention and contestation of automated decisions, bias and AI-washing provisions2026-10-18-refresh-recheck-rest · Claude Code (claude-opus-5-5)
  3. 2026-10-18title: NPC Advisory No. 2024-04: Guidelines on the Application of the Data Privacy Act → NPC Advisory No. 2024-04: Guidelines on the Application of Republic Act No. 1017 — the shortened title -> the full official subject of the advisory, as the WHEREFORE clause and the heading give it (adds 'Republic Act No. 10173 or the' and '(DPA)')2026-10-18-refresh-recheck-rest · Claude Code (claude-opus-5-5)

Related records

Philippines National AI Code bill (HB 7627) Philippines · Draft / proposed

Citation

National Privacy Commission (NPC) of the Philippines. NPC Advisory No. 2024-04: Guidelines on the Application of Republic Act No. 10173 or the Data Privacy Act of 2012 (DPA), its Implementing Rules and Regulations, and the Issuances of the Commission to Artificial Intelligence Systems Processing Personal Data [NPC Advisory No. 2024-04 (Ref. No. DPCD-24-00678)]. 2024-12-19. https://privacy.gov.ph/wp-content/uploads/2025/02/Advisory-2024.12.19-Guidelines-on-Artificial-Intelligence-w-SGD.pdf. Status: Published (non-binding, current); verified 2026-10-18 (level A). Local copy archive/PH-01/2026-10-18/provided.pdf retrieved 2026-10-18 08:09:07 UTC, SHA-256 93a9c89b33f2182ba5be1bb9886401a30bad08d3838b52c39f15ff8c2c8b7e2e. Every AI Policy Ever, version 1.18 (snapshot 2026-10-18), record PH-01.

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