DATA PRIVACY NOTICE

I. INTRODUCTION

Multinational Foundation, Inc. ("MFI", the "Foundation", "we", "us", or "our") is a non-stock, non-profit organization committed to advancing education and community development through scholarships and capacity-building programs. As part of its mission, MFI works closely with program partners to support access to education and promote positive social impact.

In carrying out its programs and activities, MFI collects and processes personal data in a responsible and transparent manner. This Data Privacy Notice explains how we collect, use, store, share, retain, and protect personal data in connection with our scholarship programs.

All personal data is processed in accordance with the Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and applicable issuances of the National Privacy Commission (NPC). MFI acts as the Personal Information Controller (PIC) for personal data covered by this Notice.

II. SCOPE

This Notice applies to personal data provided by program partners who interact with MFI through its educational programs, events, communications, website, and by individuals under MFI’s directly managed program, covering:

  • Scholarship applicants, scholars, and alumni;

  • Parents or guardians of minor scholars;

  • Benefactor and program partners;

  • Employees, officers, consultants, and volunteers; and

  • Individuals who submit inquiries or participate in Foundation activities online or offline.

III. PERSONAL DATA COLLECTED

Depending on the purpose and relationship, MFI may collect personal data voluntarily provided by its program partners and individuals participating in its directly managed program, such as:

  • Identifying information (e.g., name, date of birth, gender, photographs);

  • Contact details (e.g., address, email address, mobile number);

  • Academic and educational records;

  • Scholarship application, assessment, and monitoring information;

  • Financial or socioeconomic information relevant to scholarship evaluation;

  • Photos, audio, or video recordings for documentation and advocacy purposes (subject to separate consent);

  • Employment or volunteer-related records, where applicable; and

  • Other information voluntarily provided or lawfully obtained for legitimate purposes.

MFI collects only data that is relevant, necessary, and proportionate to its lawful purposes.

IV. MANNER OF COLLECTION

Personal data may be collected through program partners or from individuals under MFI’s directly managed program, using the following means:

  • Scholarship application forms and supporting documents;

  • Interviews, assessments, and program-related communications;

  • Emails, phone calls, written correspondence, and website inquiry forms;

  • Foundation events, activities, and program monitoring;

  • Consent forms for photos, videos, and publications; and

  • Lawful public sources or disclosures, where applicable.

V. PURPOSE OF PROCESSING

Personal data is processed for the following purposes:

  • Evaluation, selection, implementation, and monitoring of scholarship and assistance programs;

  • Administration of grants, stipends, and program benefits;

  • Program documentation, reporting, storytelling, and impact assessment;

  • Communication with benefactor and program partners;

  • Compliance with legal, regulatory, audit, and reporting requirements;

  • Security, governance, and risk management; and

  • Other similar purposes directly related to the administration, monitoring, evaluation, and reporting of the Foundation’s programs.

VI. LEGAL BASIS FOR PROCESSING

Processing is based on one or more of the following lawful grounds:

  • Consent of the data subjects, where required;

  • Performance of contracts or program obligations;

  • Compliance with legal or regulatory obligations; and

  • Protection of legitimate interests of MFI or third parties, provided these do not override data subject rights.

Where consent is the basis of processing, consent may be withdrawn at any time, subject to applicable legal and operational limitations. The withdrawal of consent may not affect the data subject’s participation in the Foundation’s programs where processing is optional, but withdrawal of consent may affect the data subject’s continued participation in the Foundation’s programs or limit access to certain services or activities where the processing of personal data is necessary.

VII. DATA SHARING AND DISCLOSURE

Personal data may be shared only when necessary and subject to appropriate safeguards, with:

  • Partner educational institutions and program partners;

  • Benefactor where reporting is required and permitted;

  • Service providers acting as Personal Information Processors (PIPs) under written agreements, where applicable;

  • Regulators or government agencies, where required by law; and

  • Other parties with lawful authority or valid consent.

MFI does not sell personal data.

VIII. DATA STORAGE AND SECURITY

Personal data may be stored in secure environments, including:

  • Official email systems and electronic repositories;

  • Shared drives, OneDrive, SharePoint, or records‑managed systems;

  • Secure devices and authorized business applications;

  • Physical files stored in locked cabinets or controlled storage areas; and

  • Off site archival storage managed by accredited service providers, where applicable.

Access is restricted to authorized personnel on a need to know basis.

IX. DATA RETENTION

Personal data is retained only for as long as necessary to fulfill the stated purposes or comply with legal requirements. In accordance with the Foundation’s records governance practices, the following retention periods apply:

  • Scholarship records are retained for the duration of the scholar’s participation in the program and up to five (5) years thereafter;

  • Alumni and program monitoring records are retained for up to five (5) years following program completion;

  • Photo and video materials are retained for the duration of the scholar’s participation and thereafter for as long as the Foundation deems the materials relevant to its legitimate purposes, in accordance with the applicable consent, unless consent is earlier withdrawn;

  • Other records are retained in accordance with the Foundation’s approved records retention schedule, which defines specific retention periods based on record type, lawful business need, and applicable legal or regulatory requirements.

X. SECURE DISPOSAL

Upon expiration of the applicable retention period or withdrawal of consent, personal data shall be securely disposed of, deleted, anonymized, or otherwise rendered inaccessible in accordance with the Foundation’s retention and secure disposal policies.

XI. SECURITY MEASURES

MFI implements reasonable organizational, physical, and technical safeguards, which may include access controls, authentication measures, confidentiality obligations, secure storage, and periodic policy reviews, to protect personal data against unauthorized access, loss, misuse, or disclosure.

XII. RIGHTS OF DATA SUBJECTS

Under the Data Privacy Act, data subjects have the right to be informed, access, correct, object to processing, withdraw consent (where applicable), request erasure or blocking, data portability (where applicable), and lodge a complaint with the NPC.

XIII. CONTACT INFORMATION / DATA PROTECTION OFFICER

To exercise his rights or withdraw his consent, the data subject may submit a request through the contact details provided below. The data subject should indicate the nature of his request (e.g., access, correction, or withdrawal of consent) and include his full name and relevant details for verification.

Requests shall be acknowledged, evaluated, and acted upon within seven (7) business days from receipt, where reasonably practicable, subject to verification, complexity of the request, and applicable law.

Data Protection Officer

Multinational Foundation, Inc.

Email: mfi@multinationalfoundation.org.ph

Phone: +63 (2) 8817‑1511

Address: 22/F Multinational Bancorporation Centre, 6805 Ayala Avenue, Makati City 1226, Philippines

XIV. POLICY UPDATES

This Notice may be updated to reflect changes in law, regulation, technology, or Foundation operations. The latest version will be made available through the Foundation’s website and appropriate channels.

XV. COMMITMENT

Multinational Foundation, Inc. remains committed to responsible, transparent, and lawful processing of personal data in support of its mission and programs.

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