Is Data Privacy your weakest link?

Navigating the Philippine Data Privacy Act (RA 10173) is complex. We make it simple, operational, and future-proof.

Trust is your most valuable currency

In today's digital economy, protecting that trust is no longer optional: it's the law. Data mishandling is not a mere mistake, but a crime.

What happens if you look away?

Penalties for mishandling data range from ₱500k to ₱5M, plus up to 7 years of jail time for company officers. You also lose the customer loyalty you've built for years.

You need a DPO to keep you safe.

Data Privacy Officers don't just tick boxes. A good DPO finds leaks in your system before bad actors (and regulators do). We also train your staff accordingly, and act as your official liaison to the National Privacy Commission (NPC).

But compliance need not be expensive.

What's the use of avoiding penalties if a senior-level salary bleeds your business dry?

Cost-Efficient

Senior-level protection for a monthly retainer, not a full-time executive salary.

Objective

As an independent partner, we audit your processes without internal bias or office politics.

Flexible

We scale our involvement based on your audit cycles and immediate needs.

Future-Proof

We don't just work with your data. We make data work for you through cutting edge tech.

Operational Rigor Meets Holistic Expertise

Most DPOs are either lawyers who don't get the business, or officers who don't get the law. You need someone who understands the whole picture.

I am Charlemagne Dumaya, your fractional Data Protection Officer. My goal is to bring legal insight, operational grit, and future-ready defense to your company.My approach is built on a rare intersection of disciplines. With the academic foundation of a Juris Doctor from the top law college in the country, I interpret the nuances of the Data Privacy Act and NPC Circulars to ensure your contracts are legally sound. But while others merely quote the law, I set myself apart by creating workflows that help you apply it.Drawing on over a decade of operational experience in transnational businesses, I understand the rigor required to manage data at scales from local to global. I have audited workflows for highly regulated international accounts, ensuring efficiency never compromises security. I apply engineering-grade quality analysis to ensure that your privacy frameworks are efficient, scalable, and resilient.I also understand that compliance should never paralyze growth. My experience in the creative industry means I know how to navigate lead generation and consent without killing your marketing campaigns. As businesses rush toward the future, my background in AI data annotation allows me to audit your data pipelines for privacy leaks. I understand how datasets are built and labeled, enabling me to identify where sensitive information might be accidentally exposed to AI models, a risk traditional DPOs often overlook.I offer what most consultants cannot: the ability to speak the languages of your legal, operations, and IT teams fluently.

Primer: The Business Owner’s Guide to Data Privacy

Republic Act 10173 (Data Privacy Act of 2012) mandates that any business processing personal data, from employee files to customer contact lists, must secure that information. If you hold personal data, you are deemed a Personal Information Controller (PIC) and are accountable for its safety.

Why should YOU pay attention to this law?• Criminal Liability: Business owners can face up to 7 years in prison and ₱5M in fines for negligence or mishandling data.1
• Brand Reputation: A single leak can destroy years of customer trust. Customers always expect their data to be safe. If you can't prove it is, there will always be a competitor who can.
• Global Access: International partners often refuse to work with non-compliant companies. Compliance is your passport to global trade, and is especially visible with the Philippine Privacy Mark.

What does this mean for you?Compliance will bring about certain challenges, but they are manageable hurdles that strengthen your business.• Challenge: Operational Friction (e.g., adding data collection consent forms).
   🠮 Opportunity: This forces you to organize your data, often revealing inefficiencies you can fix to save money.
• Challenge: Cost of Security (e.g., software, training).
   🠮 Opportunity: Investing in security prevents losses from hacks or ransomware, which cost far more than prevention.
• Challenge: Complexity of Rules.
   🠮 Opportunity: Compliance acts as a seal of trust. You can market your compliance to attract high-value clients who prioritize privacy.

The Five Pillars of ComplianceThe National Privacy Commission (NPC) simplifies compliance into five actionable steps:21. Appoint a Data Protection Officer (DPO): (See below).
2. Conduct a Privacy Impact Assessment (PIA): This is a health check to find where your data is at risk.
3. Create a Privacy Management Program: Write your manuals and document your privacy policies.
4. Implement Security Measures: Lock physical files, encrypt digital ones, and train your staff.
5. Prepare for Breach Management: Have a plan. If a breach happens, you must report it within 72 hours.

Why you need a Data Protection Officer (DPO)The law requires you to appoint a DPO, but you shouldn't just do it for compliance. A capable DPO is the solution to the challenges listed above.The DPO is your shield. They:• Protect You from Liability: They ensure you don't accidentally break the law when launching a new product, tool, or marketing campaign. This is especially important when you use AI tools for your business.
• Handle the Headaches: They deal with the NPC and strategize customer communications so you can focus on running the business.3
• Manage Crises: In the event of a hack or leak, the DPO leads the response team, containing the damage and handling mandatory reporting to avoid heavy fines.
• Build Culture: They train your staff to stop human error: the #1 cause of data breaches.

Further Reading & ResourcesThe Law
• Republic Act No. 10173: The Data Privacy Act of 2012
• Implementing Rules and Regulations of RA 10173Key NPC Circulars (2024–2025)
• NPC Circular 2024-02: Guidelines on the Use of Closed-Circuit Television (CCTV) Systems
• NPC Advisory 2024-04: Guidelines on AI Systems Processing Personal DataEssential Compliance Issuances
• NPC Circular 2022-04: Registration of Personal Data Processing System
• NPC Circular 2023-04: Guidelines on Consent
• NPC Circular 2023-05: Prerequisites for the Philippine Privacy Mark Certification Program
• NPC Advisory 2017-01: Designation of Data Protection Officers
• NPC Circular 2016-03: Personal Data Breach Management.

Are you minimally compliant?

Being at least minimally compliant ensures you're not a standing target for privacy lawsuits.Take this 2-minute self-assessment to find out if you're vulnerable. If you answer NO or UNSURE to even one question, your business is legally vulnerable under RA 10173.

QuestionYESNOUNSURE
Registration: Do you have a valid NPC Seal of Registration Certificate displayed in your office? If you process data for 250+ people or handle sensitive info, this is mandatory. No certificate = Immediate red flag.▢▢▢
Front Door: Does your website and office have a visible, up-to-date Privacy Notice? You must tell people why you are collecting their data before they give it to you. "We just need it" is not a legal defense.▢▢▢
Vendor: Do you have signed Data Sharing Agreements (DSA) with your payroll provider, cloud storage, or marketing agency? If they leak your data, you go to jail—unless you have this contract in place.▢▢▢
Employees: If an employee lost their work device today, is there a written SOP for what to do in the first 2 hours? You have 72 hours to report a breach to the NPC. Without a practiced SOP, you will miss that deadline.▢▢▢
Consent: Can you prove exactly when and how your customers agreed to receive your marketing emails? If you can't produce the timestamped consent record, you are spamming illegally.▢▢▢

If you checked "YES" to everything: Great job! You have the basics of data hygiene down pat. You can also check out our 10-point Data Defense Protocols to see how far you are beyond the bare minimum.If you answered "NO" or "UNSURE" to anything: You are operating with a Single Point of Failure. A disgruntled employee or a simple hack could trigger fines ranging from ₱500,000 to ₱5,000,000.

But no need to panic; a Data Protection Officer protects you from all these, and more.

Compliance is the floor. The sky's the limit.

Most businesses view Data Protection Officers (DPOs) as a necessary evil. These are the people who stop operations just to tick compliance boxes. These are the people with the endless (mostly inexplicable) checklists.But you don't pay people for checklists. You deserve better.A truly effective DPO isn't just an admin assistant for the National Privacy Commission. They are a partner in your business growth. When interviewing a DPO, look for someone who plays two distinct roles:

ACTIVE DEFENSE
A bad DPO waits for a breach to happen. A good DPO engineers safety.• Look for Pragmatism, Not Panic: They shouldn't just tell you what you shouldn't do; they should translate legal issues into business risks you can understand.• Look for "Privacy by Design": They should be working with your IT and Ops teams before a project launches, building safety into the foundation so you don't have to patch leaks later.• Look for Culture Building: They don't police your staff; they train them. A good DPO turns every employee into a human firewall.

STRATEGIC OFFENSE
Compliance shouldn't slow you down. It should clean up your operations.• Look for Data Quality: A DPO leads your data organization efforts. This isn't just for the law: organized, clean data leads to better marketing insights and faster operations.• Look for the "Yes, If..." Mindset: A lazy DPO says "No, you can't do that, it's too risky." A strategic DPO says, "Yes, you can do that, if we follow careful procedures."• Look for Trust Signals: They use your privacy posture as a marketing asset. In a world of scams, proving you respect customer data makes people more likely to buy from you.

THE LITMUS TEST
Before you hire anyone (including us!), ask these three questions:1. "Do you understand how my business makes money?"
If they don't, they will create policies that kill your revenue.2. "Can you explain 'Data Privacy' without using legal jargon?"
If they can't, your staff won't understand the rules, and compliance will fail.3. "Do you view data as a liability or an asset?"
If they say liability, they are just a compliance officer. If they say asset, they are a DPO.

Most DPOs stop at compliance.Modern DPOs offer an advantage.At VitrifAI, we combine legal acumen and senior-level expertise with cutting edge tools at fair rates.

The VitrifAI Advantage

VitrifAI is not your traditional compliance officer. We're an expert unit built on legal knowledge, operational rigor, and technical principles.Our sole mission is to protect your business by protecting your customer's data.

1. FRACTIONAL EXPERTISE: "Renting" Executive Talent is smarter than "owning" a Junior Employee.Let's face it: a full-time, qualified DPO is scarce and expensive. Often, businesses settle for an overburdened HR manager or an under-qualified junior staffer.But with our Fractional Model, you get:       💎 Senior Expertise, Junior Cost: You get the output of a specialist with 13+ years of industry experience for a monthly retainer often lower than a fresh grad’s salary.       🤝 Zero "Office Politics": As an external partner, we audit your processes objectively. We don't fear internal hierarchies; our only loyalty is to your compliance and safety.       🏢 Cross-Industry Intelligence: An in-house DPO only knows your problems. We bring battle-tested solutions and best practices from across multiple industries and apply them to your business.

2. STRATEGIC SYNTHESIS: Real value isn't created in silos, but in the convergence of skills.DPOs are often lawyers who don't understand the tech, tech people who don't understand the law, or HR people who only excel at operations.VitrifAI stands at a rare intersection where policy transforms into practice, and where compliance becomes an advantage.       ⚖️ Juris Doctor Roots: We don't guess at the law. We interpret the Data Privacy Act (RA 10173) and NPC Circulars with academic precision, ensuring your policies stand up to scrutiny.       🌏 Global Ops Expertise: Theory is useless without execution. Drawing on over a decade of Transnational Enterprise Operations, we build workflows that are efficient, audit-proof, and designed to survive staff turnover.       🤖 Tech Native Approach: We speak the language of your engineers. We understand IT nuances and data structures, allowing us to implement "Privacy by Design" directly into your tech stack.

3. TRIZ INNOVATION ENGINE: With us, growth and safety go hand-in-hand.Compliance should never stifle innovation, and innovation should never endanger compliance. Whereas other DPOs would harp on the risks of new processes, we apply an engineering methodology called TRIZ to get you much more than a half-hearted compromise.

4. FUTURE-PROOF SYSTEMS: We champion Data Integrity in the AI revolution.The "AI" in VitrifAI is not just gimmick. We know how the future hinges on this tech, and we have firsthand experience working with the data of frontier models.And as you adopt these tools, your risk profile changes. We are uniquely positioned to understand how your AI usage and training data affects both your business and your compliance.       🖥️ Algorithmic Auditing: We assess your AI tools to ensure they aren't inadvertently learning from (and leaking) sensitive customer data.       📊 Clean Data Pipelines: We help you structure your data collection so that your automation runs on pre-vetted datasets, thus reducing the risk of liabilities

We're not your generic consultants. We're your partners. Let's protect your business together!

We Don't Just Find Vulnerabilities.
We Engineer Solutions.

Most audits stop at compliance. That's just our starting point.We treat Data Privacy failures the same way an engineer treats a mechanical failure. We don't just patch the leak; we find out why the pipe burst, and we redesign the flow.

Phase 1: The Diagnostic (Process Mapping)
We don't go by the book; we trace your operational reality. We map your data's journey from Input to Output to identify risks suchg as "Shadow IT" and hidden silos.

Phase 2: The Deep Dive (Root Cause Analysis)
We apply the "5 Whys" as we zoom in on compliance.When we find a vulnerability, we use Root Cause Analysis (RCA) to trace the systemic failure. We isolate errors in the process, and zero in on the causes. Was it a training gap? A software flaw? A process design error?

Phase 3: The Risk Grade (FMEA Methodology)
We understand that not all risks are created equal.We prioritize your vulnerabilities using Failure Mode and Effects Analysis (FMEA). We score risks based on Severity, Occurrence, and Detection, ensuring you prioritize the massive holes over the minor cracks.

Phase 4: The Innovation Fix (Powered by TRIZ)
Other DPOs will tell you to stop a risky business process. You trade off advantage for compliance.At VitrifAI, we refuse to accept trade-offs.Instead of blocking your business, we apply TRIZ (Theory of Inventive Problem Solving) to the root cause. We look for the technical contradiction, that point where your need for growth clashes with your need for safety, and we use engineering principles to resolve it.We don't just write a correction plan; we design a solution where you stay compliant without losing your competitive edge.

Phase 5: Validation (Stress Testing)
We'd ask you to trust us, but we'd rather you see it for yourself.Once the new solution is in place, we initiate a "red team" attempt. This is where we try to bypass the new controls to ensure they work in the real world, not just on paper.

The VitrifAI Protocol: TRIZ-Based Privacy Engineering.

The Problem: The Zero-Sum GameMost businesses believe they face a permanent trade-off:"To play it safe, we need to take it slow."On the other hand:"If we want to seize the advantage, we need to play loose with customer data."But this is just compromise. At VitrifAI, we use an engineering-grade protocol called TRIZ, the Soviet-era "Theory of Inventive Problem Solving" now used by NASA and Samsung, to isolate and resolve these compromises and contradictions.

HOW WE ELIMINATE CONTRADICTIONS

Technical Contradiction #1: MARKETING
The Conflict: You need deep customer analytics to grow (Goal: Information), but holding customer data creates massive liability (Goal: Safety)VitrifAI's TRIZ Fix:
We go beyond encryption, and extract the identity from the behavior (Principle of Extraction).• Old Way: A spreadsheet whose data says "Juan dela Cruz bought a TV".
• Our Way: A Tokenized Data Lake, where marketing only sees "User #4261 bought a TV". The name is stored in an air-gapped storage, giving marketing 100% utility with zero legal risk.

Technical Contradiction #2: SURVEILLANCE
The Conflict: You need to track company assets for efficiency (Goal: Management), but tracking employees 24/7 is a privacy violation (Goal: Rights).VitrifAI's TRIZ Fix:
We change where the privacy happens (Principle of Local Quality).• Old Way: Tracking the employee's personal phone via an app, which invades personal time.
• Our Way: Geofenced telemetry tracks the assets only when they enter or leave a preset location, or during specific hours of the day. This way, the system cannot spy on off-shift employees.

Technical Contradiction #3: SPEED
The Conflict: Your Dev Team needs to ship code regularly (Goal: Speed), but the Privacy Office needs extra time to review it.VitrifAI's TRIZ Fix:
We stop gatekeeping, and start frontloading (Principle of Prior Action).• Old Way: A DPO reviews projects from scratch, causing bottlenecks.
• Our Way: Developers get pre-approved code blocks for login, data storage, and consent. If they use the blocks, they get approval instantly. Compliance happens before the code is even written.

Stop mitigating risk. Eliminate it.

Services That Fit Your Risk Profile

Whether you need a regulatory shield or a privacy engineer, we have a protocol for you.
No hidden hourly fees.
No surprise charges.
Just results.

OPTION 1: COMPLIANCE SHIELD
Best for: SMEs, Logistics, Manufacturing, and Non-Tech Firms		OPTION 2: PRIVACY OPERATIONS
Best for: Tech Startups, High-Volume Retail, HR Firms, and BPOs
The Promise: Keep the Government Happy.
You need to comply with the Data Privacy Act (RA 10173) to avoid fines and renew your business permits. You don't need complex engineering; you just need to be compliant. We act as your official DPO to handle the bureaucracy so you can focus on operations.		The Promise: Engineer Your Growth.
You handle sensitive customer data daily. You aren't just worried about the NPC; you're worried about operational friction and client trust. We embed directly into your workflow to fix "dirty data," streamline consent, and speed up your development cycles using TRIZ methodologies.
WHAT'S INSIDE:
🛡️Official DPO Registration: We sign as your DPO with the NPC.
🛡️Annual Compliance Filings: We handle your yearly security incident reports.
🛡️Breach Triage: If you get hacked, we manage the mandatory reporting.
🛡️Regulatory Helpdesk: Email us your compliance questions, and we provide clear, actionable answers.		WHAT'S INSIDE:
🚀 Everything in Compliance Shield
🚀 Privacy Engineering: We audit and redesign your data workflows for efficiency.
🚀 Vendor Risk Management: We review the contracts of software you buy.
🚀 Priority Access: Faster response times and dedicated strategy sessions.
🚀 Active Defense: We sit with you during client or government inspections.
FeatureCompliance Shield (₱25k Monthly)Privacy Operations (₱40k Monthly)
RoleRegulatory GuardianStrategic Partner
NPC Registration✅ Included✅ Included
Privacy Manual✅ Standard Template⚡ Custom Engineered
Breach Management✅ Incident Reporting⚡ Coordinated Response
Support Channel✅ Email Only (Asynchronous)⚡ Email + Video Conference
Response SLA✅ 48 Business Hours⚡ 24 Business Hours
Team Sync AvailabilityNone (Available as Add-On)Up to 2x Monthly
Ideal For"I want to be safe.""I want to scale."

Which one do I need?

Choose Compliance Shield if:
• You collect minimal data (mostly employee records and simple customer lists).
• You rarely launch new software or digital products.
• You want a set-and-forget solution to satisfy the law.Choose Privacy Operations if:
• You are building an app, a website, or a loyalty program.
• You share data with third-party vendors or partners (including AI models) frequently.
• Your clients ask you for proof of compliance (e.g., you are a B2B vendor).
• You want a partner to explain how to fix a problem, not just what the law says.

Tactical Interventions

Focused, high-impact solutions for specific privacy challenges.
No long-term contracts.
No retainers.
Just execution.

Deep Scan (Gap Analysis Audit)
Best for: Companies preparing for an NPC visit or investor due diligence.You can't fix what you can't see. We conduct a forensic review of your data flows, IT systems, and physical premises to identify "Regulatory Debt" before it becomes a liability.Deliverables:• Red/Amber/Green Scorecard: A brutal, honest assessment of your compliance status. This covers all existing data streams, including AI tool usage.
• Remediation Roadmap: A prioritized list of fixes, based on TRIZ principles.
• Executive Briefing: A 1-hour presentation to your Board/Management.

Incident Command (Breach Response)
Best for: Companies currently experiencing a hack, leak, or ransomware attack.Panic is not a strategy. If you have suffered a data breach, you have 72 hours to report to the NPC. We step in as your interim Incident Commander to manage the fallout.Deliverables:• Containment Strategy: Immediate steps to stop the leak.
• Mandatory Reporting: Drafting and filing the NPC Breach Report within the deadline.
• Notification Management: Templates for informing affected customers without admitting unnecessary liability.

Privacy Engineering Workshop
Best for: Dev Teams, HR Departments, and Marketing Staff.Most privacy trainings are boring legal lectures. Ours is operational. We teach your teams how to build privacy into their daily workflows so compliance happens automatically.Deliverables:• 3-Hour Interactive Workshop: Customized for your industry.
• Data Hygiene Protocols: Practical checklists for password management and file sharing.
• Certificate of Completion: Proof of training for NPC compliance.Cost: ₱25,000 per session, up to 15 attendees. (Workshops included for free in our Privacy Operations retainer package.)

Third-Party Risk Assessment (Vendor Review)
Best for: Procurement teams buying new software or hiring BPOs.You are liable for your vendors' mistakes. Before you sign a contract with a new payroll provider or cloud storage service, we audit their security so you don't inherit their risks.Deliverables:• Contract Review: Redlining the Data Processing Agreement (DPA).
• Security Validation: Checking their certifications (ISO 27001, SOC2).
• Risk Memo: A "Go/No-Go" recommendation for your procurement team.Cost: ₱15,000 per contract (Assessments included for free in our Privacy Operations retainer package.)

What we offer for project-based engagements:• Speed: We deploy immediately. No long onboarding process.
• Clarity: Fixed-price quotes. You know exactly what you are paying for.
• Neutrality: As an external auditor, our findings are objective and credible to regulators and investors.

The Death of "Paper Compliance"

The rules have changed. Are you still in the game?

In August 2025, the National Privacy Commission stopped asking for privacy policies. Now, they're treating privacy as an engineering question.The New Standard:Under NPC Advisory 2025-02, if you launch an app or product without documenting the Privacy Engineering Life Cycle, you could get slapped with Gross Negligence charges. This is even worse than non-compliance.What Changed?• Old Way: Build the app 🠮 Hire a Lawyer 🠮 Write a Terms of Service.
• New Way: Run a Privacy Impact Assessment 🠮 Architect Privacy Controls 🠮 Build the App.The Risk:
A breach today isn't just a fine; it's evidence that you failed the engineering standard. And the risk grows further as AI tools become more increasingly available.The Solution:
You don't need more lawyers. You need a Privacy Engineer to retrofit your stack before the audit comes.

Is AI truly your superpower?

Or is it your single, most expensive mistake?

Most businesses are scared of falling behind on AI and its benefits. But it's even more terrifying to be the first entity fined ₱5M for an AI-related data breach under the Data Privacy Act.Here's the brutal truth: most companies are already non-compliant in terms of AI use. If your employees are prompting ChatGPT with live, unsanitized client data, you have a massive leak. If you are building custom models without a PIA, you are inviting a cease-and-desist from the NPC.But here at VitrifAI, our goal is to help you turn AI into the superpower it was meant to be, while shielding you from its legal side effects.

THE RISKShadow AI: Employees pasting trade secrets into public LLMs.Model Bias: Your automated systems perpetuating discriminatory stereotypes.Training Data Liability: Using scraped data that violates RA 10173.

THE FIXEnterprise Guardrails: Configuring secure, private API endpoints and "zero-retention" workflows.Algorithmic Auditing: Technical stress-testing of your training data for PII and bias.Synthetic Data Generation: Replacing real PII with statistically identical fake data for training.

THE SHIELDAI Acceptable Use Policy: Clear, enforceable contracts for your staff.ADMAS Compliance: Meeting NPC requirements for Automated Decision-Making.Data Provenance Logs: Audit-ready trails proving your data was ethically sourced.

VitrifAI specializes in the intersection of LLM deployment and RA 10173 compliance. We bridge the gap between technical AI development and the National Privacy Commission's guidelines on Privacy Engineering (Advisory 2025-02).