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15 March 2021
Re: REQUEST FOR OFFICIAL LIST OF LEGITIMATE TAXI OPERATORS
Dear [Redacted],
We write in response to your letter forwarded by the Civil Service Commission - Cordillera Administrative Region on the request of the Association of Independent Taxi Operations and Drivers in the Cordillera (Association) for legal opinion on matters involving the Data Privacy Act of 20121 (DPA).
We understand that the Association requested from the Land Transportation Franchising and Regulatory Board – Cordillera Administrative Region (LTFRB-CAR) the list of legitimate taxi operators in the CAR in order for the Association to assist concerned government agencies in the anti-colorum drive and traffic decongestion efforts.
Specifically, the request pertains to the list of the legitimate taxi operators together with the Certificate of Public Convenience (CPC) number, number of taxi units, type of taxi units, and their corresponding plate numbers. We understand that such request was denied by LTFRB-CAR citing the provisions of the DPA.
Discussion
The request of the Association for the list of legitimate taxi operators, which includes their CPC numbers, number of taxi units, type of taxi units, and their corresponding plate numbers, implicates questions relating to freedom of information and the scope of the DPA.
We note that while there may be information that is of public interest and subject to disclosure, the disclosure thereof must still be consistent with the principles of the DPA, specifically considering the purpose of the disclosure, the necessity thereof, and whether the information sought is proportional to the purposes.
In view of the foregoing, we opine that information concerning legitimate taxi operators, including their license and equipment specifications, may be disclosed to the Association. Such disclosure serves a legitimate government interest in addressing the anti-colorum drive and traffic decongestion. The information requested is not excessive in relation to the stated purpose, and the Association has a legitimate interest in assisting government agencies in these endeavors.
However, we recommend that the LTFRB-CAR disclose only information that is material and necessary for the stated purpose and refrain from unnecessary disclosure of other personal information of the taxi operators not essential to the anti-colorum drive and traffic decongestion efforts.
This opinion is based solely on the limited information you have provided. Additional information may change the context of the inquiry and the appreciation of facts. This opinion does not adjudicate issues between parties nor impose any sanctions or award damages.
For your reference.
Very truly yours,
(Sgd.) IVY GRACE T. VILLASOTO OIC-Director IV, Privacy Policy Office
Footnotes
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An Act Protecting Individual Personal Information in Information and Communications Systems in the Government and the Private Sector, Creating for this Purpose a National Privacy Commission, and for Other Purposes [Data Privacy Act of 2012], Republic Act No. 10173 (2012). ↩