YOUR PRIVACY IS IMPORTANT TO IRON MOUNTAIN
Iron Mountain Philippines (referred to as “Iron Mountain” or “We” or “Our” or “Us” in this Privacy Notice) have developed this Privacy Notice to inform you of how We process and protect the Personal Data that We Collect, Use, or Share with third parties. It also covers how Iron Mountain makes the Personal Data it holds available for access to and correction by you.
This Privacy Notice has been drafted having regard to Iron Mountain's obligations under the Data Privacy Act of 2012, its implementing rules and regulations, issuances of the National Privacy Commission, and other laws and regulations on the privacy and protection of personal data (the “DPA” or the “Act”).
Please read this Privacy Notice. By providing Us with your Personal Data, you are consenting to the Collection, Use and disclosure of your Personal Data as set forth in this Privacy Notice.
1.1 Iron Mountain Collects Personal Data about customers, prospective customers, vendors, prospective vendors, contractors, job candidates, the general public (via our CCTVs) and Website users which is reasonably necessary for, or directly related to the fulfillment of a contract with you, or the preparation to enter into a contract with you, the compliance with a legal obligation on the part of Iron Mountain, or other legitimate business purposes. The Personal Data may be Collected through our Website, over the phone, or otherwise.
1.2 Iron Mountain will not Collect Personal Data secretly or in an underhanded way and will not sell your Personal Data to any third party (except in the course of a sale of the business, etc.).
2.1 Iron Mountain holds Personal Data which it has Collected for its Primary Purposes, including but not limited to:
(a) providing you with the products and services ordered from Us or in relation to products or services We order from you;
(b) answering your inquiry or job application;
(c) sending you additional materials relating to Iron Mountain and services that may be of interest to you;
(d) providing you with effective customer service; and
(e) for security measures relating to our services.
2.2 Iron Mountain also holds Personal Data for purposes other than its Primary Purposes (Secondary Purposes). You provide your consent to Us using your Personal Data for the following Secondary Purposes:
(a) billing and account management;
(b) business planning and product development;
(c) providing you with relevant information, including promotions, about the products and services of Iron Mountain and its affiliates;
(d) enabling Us to better understand your needs and interests;
(e) improving the content, functionality and usability of our Website;
(f) improving our marketing and promotional efforts;
(g) displaying personalised advertising when you visit our Website;
(h) for any other purpose identified in any other agreement between you and Iron Mountain;
(i) issues, news or other information relevant to your dealings with Iron Mountain, or about Iron Mountain generally, or the industries in which you or Iron Mountain operates; and
(j) as otherwise described in this Privacy Notice.
2.3 Iron Mountain may Use and/or Share your Personal Data for any Secondary Purposes not included in this Privacy Notice if:
(a) the Secondary Purpose is related to a Primary Purpose; and
(b) you would have a Reasonable Expectation that We would Use the information for that Secondary Purpose.
2.4 From time to time We may Share your Personal Data to organisations outside of Iron Mountain in order to deliver the services you require or if required for other legal reasons. Your Personal Data is Shared with these organisations in relation to Us providing Our services to you or to meet such other legal requirements. These organisations carry out, amongst other services, Our:
(a) billing and debt- recovery functions;
(b) customer inquiries;
(c) information technology services;
(d) marketing and communication services (including market research);
(e) website usage analysis;
(f) to support or facilitate any of those activities described in paragraphs 2.1 and 2.2 herein; and
(g) advisers and insurers.
2.5 Iron Mountain adopts contractual or other means in compliance with the rules on outsourcing of the processing of Personal Data to prevent:
(a) your Personal Data transferred to above organisations from being kept longer than is necessary for the purpose or for other legal or business purposes;
(b) unauthorised access, Collection, Use, disclosure, copying, modification, disposal of or similar risks to your Personal Data transferred to organisation for the provision of the above services.
Furthermore We will take reasonable practicable steps to ensure that these organisations are bound by confidentiality obligations in relation to the protection of your Personal Data.
3.1 Iron Mountain only targets businesses with its services. Although Personal Data may be Collected from any individual through Our website or otherwise for various purposes (i.e., to download a document, respond to a query or a job application), with respect to direct marketing purposes, We intend to Use Personal Data that is Collected from individuals in their official capacities and Our promoted services are clearly meant for the Use of the targeted business. If these requirements are met, Iron Mountain does not need to obtain consent from this individual and the other provisions of the Act neither apply to Iron Mountain.
3.2 Should We have doubts that the Collected Personal Data relates to individuals in their official capacities, We ask for consent for Using and/or Sharing any Personal Data Collected from you for Direct Marketing purposes in accordance with the Act, whether Collected via telephone, the Website, or otherwise, but subject to the terms of this Privacy Notice.
3.3 In each Direct Marketing communication, We will include:
(a) a prominent statement appearing on the relevant piece of marketing material notifying you of your right to Opt Out from further Direct Marketing; and
(b) simple means for you to Opt Out of receiving further Direct Marketing communications of that kind.
3.4 Should you Opt Out, We will stop Using and/or disclosing your Personal Data for Direct Marketing purposes.
4.1 We take reasonable precautions to ensure that the Personal Data We Collect, Use and Share is complete, relevant and up-to-date.
4.2 However, the accuracy of that information depends to a large extent on the information you provide. That's why We recommend that you:
(a) let Us know if there are any errors in your Personal Data; and
(b) keep Us up-to-date with changes to your Personal Data. You may change your personal details by using the relevant facility on Our Website or by contacting Iron Mountain via contact details described in paragraph 12.
5.1 Iron Mountain will take reasonable steps to protect your Personal Data from misuse, interference, loss and unauthorised access or disclosure. This may include taking reasonable steps to destroy or permanently de-identify Personal Data once it is no longer needed for any purpose for which it may be Used or Shared.
5.2 Iron Mountain will not attempt to match de-identified or make anonymous data Collected through surveys or such online devices as "cookies", with information identifying an individual, without notifying the relevant individual.
5.3 Iron Mountain requires employees and contractors to perform their duties in a manner that is consistent with Iron Mountain's legal responsibilities in relation to privacy, including those in this Privacy Notice.
5.4 Iron Mountain will take reasonable steps to ensure that Personal Data is only accessible by people who have a genuine "need to know" as well as "right to know."
6.1 Upon request, you can access your Personal Data that We Store on Our systems.
6.2 If Iron Mountain is satisfied that:
(a) having regard to the purpose for which the information is held, the information is inaccurate, out of date, incomplete or irrelevant or misleading; or
(b) you (as the person to whom the Personal Data relates) request that We correct the information; We will take reasonable steps to correct Our records containing your Personal Data as soon as practically possible.
6.3 If you wish to lodge a request to access and/or correct your Personal Data, you may do so by contacting the Data Protection Officer as per the details in paragraph 12.
6.4 Iron Mountain will not charge a fee for processing an access request unless the request is complex or is resource intensive. Iron Mountain does, however, reserve the right to charge an administration fee if an individual requests access to their Personal Data more than once in a three month period.
6.5 Where Iron Mountain offers online account management facilities, customers can Use this capability to control aspects of their account, including amending or updating certain Personal Data.
7.1 Iron Mountain’s Data Protection Officer will be the first point of contact for inquiries about privacy issues. If you wish to make an inquiry or complaint regarding your privacy, you should contact this person as per the details in paragraph 12.
7.2 You will find that the Iron Mountain’s Website contains a copy of this Privacy Notice.
8.1 Iron Mountain will not make it mandatory for visitors to Our Website to provide Personal Data unless such Personal Data is required to answer an inquiry or provide a service. Iron Mountain may however request visitors to provide Personal Data voluntarily to Iron Mountain (for example, as part of a competition or questionnaire).
8.2 Iron Mountain will allow you to transact with Us anonymously or by using a pseudonym wherever that is reasonable and practicable.
9.1 If We send Personal Data out of the Philippines, in accordance with and to the extent covered by paragraph 2, Iron Mountain will take appropriate steps to ensure that the recipient is bound by legally enforceable obligations so at to provide to your transferred Personal Data a standard of protection that is comparable to that under the Act.
9.2 Iron Mountain may Share Personal Data to a recipient without complying with 9.1 if:
(a) you are Expressly Informed of the intended transfer of your Personal Data to the recipient, and you consent in writing; or
(b) the Sharing is for the purpose of outsourcing the processing of Personal Data and such processing is for the purpose of the fulfillment of Our legitimate interests, a mandate of a public authority; or an obligation under our Contract with you; taking steps at your request prior to Us entering into a contract with you; or compliance with a legal obligation to which We are subject; or protection of your vitally important interests, such as your life or health; or response to a national emergency or compliance with the requirements of public order and safety, as prescribed by law; and in both cases,
(c) We exercised due diligence to ensure that the Personal Data will not be treated in a manner which will contravene the Act.
Iron Mountain may, in its sole discretion, update this Privacy Notice at any time and from time to time. Any changes will be effective when posted on Our Website. Your continued Use of Our Website will indicate your acceptance of any changes to the Privacy Notice. All Personal Data, Collected both before and after any changes take effect, will be subject to the terms of the then current Notice, for which you will be taken to have provided consent, unless you indicate otherwise by contacting the Data Protection Officer as per the details in in paragraph 12. We encourage you to refer back to this page and especially prior to providing Us with any Personal Data.
Collect means gather, acquire or obtain by a lawful and fair means, information in circumstances where the individual is identifiable or identified.
Direct Marketing involves the Use and/ or Sharing of Personal Data to communicate directly with an individual to promote goods or services through written, verbal or electronic means of communication for the company that the individual is acting for and behalf of. The goods or services which are marketed may be those of Iron Mountain or those of an independent third party organisation on behalf of Iron Mountain.
Expressly Informed means the circumstance where We have provided you with a clear statement (either verbal or in writing) of the fact that that We will not be accountable under the Act and you will not be able to seek redress under the Act in the event that you provide consent to the Sharing of your Personal Data by Us to a recipient outside of Philippines and this recipient handles your Personal Data in breach of the Act.
Iron Mountain Philippines means Iron Mountain Philippines, Inc. including all subsidiaries, related and/or associated companies.
Opt Out means an individual's expressed request not to receive Direct Marketing communications.
Personal Data means any data (a) relating directly or indirectly to a living individual;(b) from which it is practicable for the identity of the individual to be directly or indirectly ascertained; and (c) in a form in which access to or processing of the data is practicable. This includes, but is not limited to, an individual’s name, address, telephone number and email address.
Primary Purpose is the main reason for the Collection of any Personal Data.
Reasonable Expectation means an individual's reasonable expectation that their Personal Data might be Used or Shared for the relevant purpose.
Secondary Purpose means a purpose of Use or Sharing other than a Primary Purpose.
Share or Sharing generally means the release of information outside Iron Mountain, including under a contract to carry out an "outsourced function."
Use means the handling of Personal Data within Iron Mountain.
Website means the website of Iron Mountain and related webpages.
If you have questions concerning this Privacy Notice, please contact the Data Protection Officer:
You can obtain further information about your privacy rights and the Act from the National Privacy Commission by visiting its web site at http://www.privacy.gov.ph/.
This Privacy Notice was last updated on 1 April 2019.