The National Privacy Commission (NPC) has reminded all personal information controllers (PICs) to get vaccinees’ free and informed consent before using any personal information in their COVID-19 vaccination cards for promos, raffles, or discounts.
The agency recently issued NPC Public Health Emergency (PHE) Bulletin No. 20 in light of reports of collection of copies of COVID-19 vaccination cards by certain companies as a form of reward to vaccinated individuals.
Privacy Commissioner Raymund Liboro noted that vaccination cards contained sensitive personal information such as the vaccinee’s age, date of birth, and health information.
“While we laud these gestures as part of the ongoing initiative to encourage all eligible individuals to be vaccinated against COVID-19, we must also remind all PICs of the need to establish a lawful basis in the conduct of their respective personal data processing activities. Securing the free and informed consent of the individuals may be a lawful basis,” Liboro said.
For consent to be valid, Liboro said it must be freely given, specific, informed, and an indication of will.
