NPC Reminds Companies that Consent Must be Obtained for Vaccine Rewards

The National Privacy Commission (NPC) remind the personal information controllers (PICs) of companies to obtain the free and informed consent of vaccinated individuals before using any sensitive personal information in COVID-19 vaccination cards for promos, raffles, or discounts.


Privacy Commissioner Raymund Liboro reminded companies that vaccination cards possessed sensitive personal information such as age, date of birth, and health information. In obtaining consent, the Commissioner stated that “[T]he vaccinee should explicitly agree to the collection and processing of his or her vaccine card. Consent must also be evidenced by written, electronic, or recorded means.” Additionally, a privacy notice must be posted to sufficiently inform the individuals availing of these promos.


Furthermore, the Commissioner reminded the PICs that the use of the vaccine card must be limited to the intended purpose of giving promos, raffles, or discounts.


The full press release can be accessed here.

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