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12 May 2026
Re: DISCLOSURE OF LANDOWNER NAMES IN PROPERTY IDENTIFICATION MAPS
Dear [Redacted],
Greetings from the National Privacy Commission.
This pertains to your request for an advisory opinion on whether vicinity maps, digital tax maps, or property identification maps that include the names of landowners may be disclosed by a municipal assessor or other government agency or instrumentality pursuant to an official request for project due diligence, consultation, discussion, and negotiation purposes. Further, you also inquire as to whether there exists a lawful basis or statutory exception justifying such disclosure under the Data Privacy Act of 2012.
In your letter-request, you stated that [Redacted] is a duly licensed renewable energy developer undertaking feasibility activities for two prospective projects in Quezon Province: the [Redacted] Solar Power Project (50 MWp) and the [Redacted] Onshore Wind Power Project (200 MW). [Redacted] further represents that its project activities are being undertaken pursuant to relevant Department of Energy approvals and commitments, including a Wind Energy Service Contract for the [Redacted] Onshore Wind Power Project. As part of its project development activities, [Redacted] requested from the Office of the Municipal Assessor of [Redacted], Quezon property identification maps bearing the names of landowners within the project areas. The first request, dated 19 January 2026, was granted. A subsequent request on 9 to 10 February 2026 resulted in the release of a map with the landowner names omitted. The Municipal Assessor’s Office cited the DPA and a purported local resolution as basis for the omission but provided no copy of either. [Redacted] emphasizes that landowner information is essential to identify proper parties for consultation, negotiation, land access, easement arrangements, and the conduct of social acceptability and stakeholder engagement processes required under applicable energy, environmental, and local government regulations.
Discussion
Landowner names in property identification maps; Personal information under the DPA
At the outset, the names of landowners appearing on property identification maps are generally personal information within the meaning of the DPA, which defines personal information as any information, whether recorded in material form or not, from which the identity of an individual is apparent or can reasonably and directly be ascertained.1 The DPA likewise defines processing broadly to include any operation performed upon personal data, including disclosure,2 such that the release of a property identification map bearing the name of a landowner by an assessor’s office would constitute processing subject to the DPA.
That said, the DPA does not operate as a blanket prohibition against the disclosure of all personal information held by government. Section 11 of the DPA expressly provides that the processing of personal information shall be allowed, subject to compliance with the requirements of the Act and other laws allowing disclosure of information to the public, and adherence to the principles of transparency, legitimate purpose, and proportionality.3 Thus, the mere fact that landowner names constitute personal information does not, by itself, end the inquiry. The proper question is whether the specific disclosure is supported by a lawful basis and carried out consistently with the DPA’s general principles.
Lawful basis for disclosure; Legal obligation
Under Section 12(c) of the DPA, the processing of personal information is permitted when it is necessary for compliance with a legal obligation to which the personal information controller is subject.4 This lawful basis is most relevant to the facts presented, considering that [Redacted] represents that the requested landowner names are necessary for the performance of project-related legal, regulatory, and governmental approval requirements.
Based on the facts presented, the relevant lawful-basis analysis may properly focus on legal obligation. [Redacted] represents that it is undertaking renewable energy project development activities pursuant to governmental approvals, project commitments, and regulatory requirements, including those arising from its Department of Energy-authorized project activities. These activities require the identification of affected or potentially affected landowners for project due diligence, consultation, negotiation, land access, easement arrangements, stakeholder engagement, and social acceptability processes.
Where [Redacted] sufficiently establishes that the requested landowner names are necessary for compliance with such legal, regulatory, or project-related obligations, the request may provide a lawful basis for disclosure under Section 12(c) of the DPA, subject to the releasing office’s assessment of necessity, proportionality, and any applicable restrictions under other laws.
From the standpoint of the Municipal Assessor or other government office having custody of the records, disclosure should not be refused merely because the records contain personal information. The office must determine whether the requested disclosure is authorized under the legal framework governing the record and whether the disclosure is necessary to enable compliance with a legal obligation established by the requesting party. Where the request is specific to identified parcels or a defined project area, and the information sought is limited to the names necessary to identify the proper landowners for lawful project-related dealings, disclosure may be consistent with Section 12(c) of the DPA, provided that the general data privacy principles are observed.
The Commission emphasizes that this analysis is fact-specific. A parcel-specific and project-specific request for landowner names required for consultation and negotiation is materially different from a broad, untargeted, or speculative request for personal data. The releasing office may require the requesting party to identify the legal or regulatory obligation involved, the project area covered, the specific information requested, and the purpose for which the information will be used.
Government records; Access questions under other laws and the DPA framework
The records described in your request appear to be official property-related records maintained by a government office in connection with local assessment and real property administration functions. This Advisory Opinion does not conclusively determine whether a particular property identification map, tax map, or related record is a public record that must be disclosed under the Constitution, the Local Government Code, taxation laws, freedom of information rules, or other sectoral issuances. That determination depends on the legal framework governing the specific record, the authority of the office having custody of the record, and any applicable limitations imposed by law.
For purposes of the DPA, the controlling point is narrower: the DPA does not, by itself, automatically prohibit the disclosure of a government-held record merely because the record contains personal information. Where another law, regulation, or lawful government process authorizes or requires the disclosure of property-related information, the DPA should be applied in a manner that allows the lawful disclosure to proceed while ensuring that the disclosure remains transparent, legitimate, and proportionate.5
Accordingly, the DPA should not be invoked as a general or categorical ground to omit landowner names from property identification maps without a proper assessment of the applicable lawful basis, the necessity of the disclosure, and the safeguards appropriate to the purpose.
Local resolutions; National law and privacy determinations
The Commission also notes your statement that the Municipal Assessor’s Office invoked a purported local resolution as basis for refusing to disclose the names of landowners, but that no copy of the resolution was furnished to [Redacted].
Local legislative or administrative issuances may regulate the handling of local government records, provided they are consistent with the Constitution and national law.6 However, a local resolution cannot, by itself, override or supplant the lawful-basis framework established by the DPA and its IRR. If a local government office restricts disclosure on privacy grounds, the restriction must be grounded in a proper application of the DPA and any other applicable law, not merely in a generalized or undisclosed local policy.
Thus, where disclosure is refused on the basis of data privacy, the releasing office should be able to identify the specific legal basis for the refusal and explain why disclosure would be unlawful or disproportionate under the circumstances. Conversely, where disclosure is permitted, the office should document the lawful basis, the purpose of disclosure, the scope of information released, and the safeguards applied.
Transparency, legitimate purpose, and proportionality in the requested disclosure
Even where a lawful basis exists, the disclosure must comply with the DPA principles of transparency, legitimate purpose, and proportionality.7
In this context, the releasing office should ensure that the request is tied to a defined project area or identified parcels; that only the information necessary to identify the proper landowners is disclosed; that the purpose of disclosure is clearly stated and documented; and that the requesting party is made aware that the information may be used only for the declared lawful purpose. The office may also consider reasonable safeguards, such as limiting the released information to landowner names and parcel references necessary for consultation or negotiation, keeping a record of the disclosure, and requiring the requesting party to observe appropriate confidentiality and data protection measures.
The same framework may apply, as appropriate, to other government agencies and instrumentalities mentioned in your request, such as the Department of Agrarian Reform, Department of Agriculture, or National Commission on Indigenous Peoples, subject to each agency’s mandate, the legal framework governing the records in its custody, and the requirements of necessity and proportionality.
Disclosure of landowner names not per se prohibited; Lawful basis and limitations
Accordingly, property identification maps, vicinity maps, or digital tax maps that include the names of landowners are generally covered by the DPA insofar as they contain personal information. However, their disclosure is not automatically prohibited by the DPA.
Where [Redacted] sufficiently establishes that the requested landowner names are necessary for compliance with its legal, regulatory, or project-related obligations in connection with the relevant renewable energy projects, disclosure may be supported by Section 12(c) of the DPA, subject to the legal framework governing the record and compliance with the principles of transparency, legitimate purpose, and proportionality.
The DPA does not support a categorical proposition that the names of landowners in official property identification maps may never be disclosed to a requesting party. What the DPA requires is a specific lawful-basis and proportionality assessment, not a blanket refusal. A local resolution of uncertain content cannot substitute for that assessment, nor can it override a lawful disclosure supported by national law.
Please be advised that this Advisory Opinion was rendered based solely on the information you have provided. Any extraneous fact that may be subsequently furnished us may affect our present position. Please note further that our Advisory Opinion is not intended to adjudicate the rights and obligations of the parties involved.
For your reference.
Very truly yours,
(Sgd.)
VIDA ZORA G. BOCAR
OIC-Director IV, Privacy Policy Office8
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, § 3(g) (2012). ↩
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The Local Government Code of 1991, Republic Act No. 7160, § 16 (1991). ↩
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National Privacy Commission Special Order No. 095, s. 2025. ↩