Privacy Notice

PRIVACY NOTICE

HCP Seafarers and Sea-Based Applicants

 

To HCP seafarers and applicants - 

In recognition of your right to privacy and in compliance with the requirements under the Data Privacy Act, its IRR and advisories, please read the following privacy policy explaining how we collect and process your personal information:

 

What We Collect

Your personal data is collected in the form of written records, photographs, video images, digital material, and biometrics:

• Information you provided upon application to HCP. When you seek a job with HCP’s Principals through our office, we ask for personal data through the online Sea-Based Application forms and AF CRS 005 Application Form. We also collect information sent by job applicants to our Human Resource Department (Sea-Based) official e-mail. We also request for your resume, Transcript of Records, and professional license if it applies to you. Throughout the pre-employment process we may also collect additional data from your interview and declared references. If you’ve previously worked with HCP before, we may use that information that is already in our possession in order to process your application for a position. 

 

• Information we collect upon initial employment via HCP.  Once your job offer has been accepted and finalized, additional information is collect but is not limited to the following: (1) Travel Documents; (2) Flag State Documents; (3) Training Certificates; (4) Certificates of Competency/Proficiency; (5) Philhealth Member Registration Form; (6) Philhealth MDR or ID; (7) Pag-IBIG Member’s Data Form and/or ID; (8) Pag-IBIG Member’s Change in Information Form (MCIF);  (9) Birth Certificate (applicant/dependents); (10) Marriage Contract; (11) Bank account details necessary for allotment.

 

• Information we collect through the course of your ongoing employment with the principal. After securing employment through HCP, we may collect more information about you such as annual pre-employment medical examination results, data to process benefits and loan applications, performance evaluation, updated licenses and training certificates, and information on disciplinary cases. We may also collect your data through our official communication channels such as e-mails, mobile, and Facebook Messenger during cases when you cannot physically submit the information at our office. There will also be cases when we collect your data in the form of pictures and videos as part of documentation of office events or through closed-circuit television cameras located in the office.

 

• Other Information.

For unsolicited information sent or received by HCP without prior request. If this happens, we will determine if there is legitimate grounds for HCP to keep the data. If it has no relation our legitimate interests, then the information will be disposed of in order to protect your privacy. Otherwise, it will be treated in the same way as information you provided us.

For personal and sensitive information of other people sent or received by HCP for purposes such as supplying who to contact in case of emergencies, supplying dependents for claiming of benefits, and other such similar cases, you have the responsibility to obtain the consent of such individuals before providing us with their personal data.

 

How We Use

We use your personal data to pursue our legitimate interests as an employer and crewing agency, to be able to comply with laws and regulations, as well as research, historical, and statistical purposes. For example, we may use the information for purposes such as:

1. Identifying applicants and processing applications;
2. Assessing candidates for a position;
3. Verifying provided information;
4. Background checking;
5. Processing compensation, benefits, and standard employment functions;
6. Processing human resource functions such as performance management and disciplinary issues;
7. Establishing and maintaining an accurate crew information system on web, mobile, and, desktop platforms;
8. Identification purposes for the activation of your mobile application
9. Establish and maintain accurate crew information on the mobile application
10. Communication of relevant news and announcements; 
11. Personnel training;
12. Communicating and sharing promotional materials such as events and workshops;
13. Compiling statistics, surveys, and research for internal purposes;
14. Contacting others in case of an emergency;
15. Sharing your information with persons or institutions mentioned below; and,
16. Other related or similar tasks.

 

Processing your data for these purposes is necessary in order to fulfill our contractual obligation to you, to comply with legal obligations, and to protect your interests such as life and health or for the pursuit of the legitimate interests of HCP or a third party such as our Principals in the Hartmann Group.

Legal Compliance on Use, Sharing and Consent

In compliance with the Data Privacy Act which imposes stricter rules on processing of personal and sensitive information, rest assured that we shall independently ask for consent for the specific use and sharing of your personal data.  If you do not receive any formal written consent form before your information was processed, kindly contact the HCP Data Privacy Officer through the contact information listed above.

 

How We Share, Disclose or Transfer

We may also share, disclose, or transfer your personal data to other persons or organization in order to pursue our legitimate interests as crewing agency. For example, we may share, disclose, or transfer your personal data for the following purposes:

1. Submission of information to government agencies (e.g. Philippine Overseas Employment Agency, Social Security System, Philippine Health Insurance Corporation, Pag-IBIG, Bureau of Internal Revenue, Maritime Industry Authority) for reporting requirements, accreditation, and the provision of employment benefits dictated by the law;
2. Sharing of information with insurance companies, banks, seafarers' union (e.g. AMOSUP), health service providers, counseling services and other similar organization in relation to your loan applications, insurance claims, and benefits ;
3. Sharing of information with Flag State Offices, Embassies, Airlines, and shipping agents for the purpose of planning, embarkation, and disembarkation
4. Sharing of information with members of the Hartmann Group (e.g. (1) Germany- Hartmann AG, Hartmann Dry Cargo, Hartman Gas Carriers, Gaschem Services, Hartmann Crew Germany (2) Cyprus- Intership Navigation, Donnelly Tanker Management, United Bulk Carriers, Seagiant (3) Poland- Hartmann Crew Consultants (4) Singapore – Hartmann Shipping Asia.) for the purpose of facilitating your employment on their vessels;
5. Sharing information with industry entities or organizations (e.g. Philippine Association of Manning Agencies and Ship Managers);
6. To comply with court orders and other legal obligations;
7. Use of photos and videos for promotional purposes and marketing materials such as social media posts, website articles, brochures, physical and electronic bulletins, and other media;
8. Live-streaming of HCP events; and,
9. Any other purpose necessary as permitted or required by the law.

 

Rest assured that HCP will never share your personal data for matters unrelated to your employment or our legitimate interests as your crewing agency unless required by law.

How We Protect

HCP exercises due diligence in limiting access to your personal information to its authorized agents, personnel tasked to process your information and Principals from the Hartmann Group. HCP maintains physical and digital methods of protection to avoid security breaches through the deployment of security personnel, use of CCTVs, locks and password protection.

 

How We Store & Retain

Your personal data is stored in paper and electronic formats as well as databases shared between departments in the office and our Principals from the Hartmann Group. Access to your personal data is limited to HCP personnel who have a legitimate interest in them for the purpose of doing their duties. Rest assured that our use of your personal data will is limited to only what is needed to achieve the purpose of their collection and/or when permitted by law.

Your personal data is retained only up to the following time periods: 

1. Seafarers who have been employed on Hartmann Group Vessels – Up to ten (10) years from the day you stopped working with HCP and have removed your physical documents from our offices. After which, your employment records (e.g. Crew Management System Data) shall be securely archived. We indefinitely retain relevant personal data for historical and statistical purposes as well as required reporting to government agencies.

2. Job Applicants - Up to two (2) years for pooling purposes, after which it is disposed of securely unless used within the two-year period.

 

Know Your Rights

Pursuant to the Data Privacy Act, its IRRs and advisories, you have the right to — information, access, objection, erasure or blocking, damages, complaint, rectification; and data portability. For more information on the following, visit:  https://www.privacy.gov.ph/know-your-rights/.

 

Amendments to this Privacy Policy We reserve the right to revise our policy from time to time. Any changes made are effective upon publication in our website and other similar forms of communication.