Privacy Policy
This policy explains what personal information SMARTCLOCK, the attendance system, holds about you, why, where it is kept, who can see it, how long it is kept, and what you can do about it. It describes what the system actually does, in line with the Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations.
1. Who is responsible
Pangasinan State University - Asingan Campus is the personal information controller for this system: it decides what is collected and why, and it is answerable for it.
A Data Protection Officer has not been named for this system yet. Until one is, raise anything about your personal information with the HR office.
2. What the system collects
| Information | What it includes |
|---|---|
| Account and employment details | Your name, email address, employee or faculty ID, position, employee type, department and role. Your password is stored only as a one-way hash, which nobody can read. |
| Face data | Only if you agree to enrol: several readings of your face, each a list of 128 numbers. No photograph of you is kept. See section 4. |
| Attendance | The time of each scan at the terminal, whether it counted as an arrival or a departure, how closely the face matched, and whether it passed the liveness check. From these the system produces your daily time record (Civil Service Form 48). |
| Leave requests and supporting documents | The requests you file and the files you attach (images or PDF). A document may contain health information, such as a medical certificate, if you choose to include it. |
| Profile photo (optional) | A picture you choose to show beside your name. Only if you upload one. It is cropped and saved again from its pixels, so location, camera and date details stored inside the picture are not kept. It is not used for face recognition, which works only from your enrolled face readings. |
| Your agreement to face enrolment | When you agreed, and to which version of the notice. |
| Notifications | Messages the system sends you, such as a recorded scan or a decision on a request. |
| Security records | An audit trail of actions taken in the system - who did what, and when - together with the network (IP) address and browser details of the device used. |
The system does not collect your location. The camera is used only when you enrol your face and when you scan at the attendance terminal.
3. Why it is used
- To record attendance and produce your daily time record, which the university keeps as a government employer under Civil Service rules. This is necessary for your employment and for the university to meet its legal obligations (RA 10173, Section 12).
- To recognise you at the terminal using your face data - only with your agreement (RA 10173, Section 13).
- To handle your leave requests and supporting documents. Health information in a document you submit is used only to evaluate the request it came with.
- To keep the system secure and accountable, through the audit trail and the protections on signing in.
- To keep you informed, through notifications, and to send password reset links to your email address.
Your information is not sold, not used for advertising, and not used for any purpose not listed here. The terminal decides automatically whether a face matches an enrolled employee; the system makes no other automated decision about you.
4. Your face data
Your face is sensitive personal information, so it is recorded only after you agree on the enrolment notice.
- Each reading is a list of 128 numbers describing the measurements of your face. The numbers cannot be turned back into a picture of you.
- The images your camera captures - when you enrol and each time you scan - are used to produce those numbers and to check that a real person is in front of the camera, and are then discarded. No photograph is stored.
- The readings are encrypted before they are stored, with a key held only on the campus server. No screen anywhere shows them; administrators can see that you are enrolled and how many readings you gave, not the readings.
- They are used for one purpose only: recognising you at the attendance terminal.
- You can decline. The system records attendance only through the face terminal, so if you decline, your daily time record is kept on paper through the HR office instead. Declining does not affect your pay and is not held against you.
- You can withdraw your agreement at any time from your profile, and your readings are deleted when you do.
5. Where it is kept, and who receives it
Where
- The system's database is Supabase, a cloud database service, on Amazon Web Services servers in Seoul, South Korea. Your account details, attendance, requests, notifications and the audit trail are stored there, and your face readings are stored there in encrypted form. The connection to it is encrypted. Because these servers are outside the Philippines, keeping information there is a transfer of personal information abroad; the university remains responsible for it wherever it is kept.
- The campus server that runs the system and the attendance terminal holds the files you attach as supporting documents, and an encrypted copy of enrolled employees' face readings, with their names and employee IDs, so the terminal keeps working when the internet connection drops. Scans taken while the connection is down are kept there until they can be sent to the database.
Supporting documents can be opened only after signing in, and only by you and by HR and administrators. Each time somebody other than you opens one, the system records who and when.
Who receives it
- HR and administrators of the campus see attendance records, requests, supporting documents and profile photos, as their work requires. Other employees do not see your photo.
- Supabase, which hosts the database for the system. Your face readings are encrypted before they reach it, and it does not have the key.
- Google (Gmail), which carries the emails the system sends, such as password reset links, to your email address.
- Government authorities, only where the law requires it.
Nothing else is shared. The system's pages load nothing from other companies - no fonts, scripts or trackers - so using it does not send your address to anybody else.
6. How long it is kept
| Information | How long |
|---|---|
| Face readings | While you are enrolled. Clear your enrolment or withdraw your agreement and they are deleted from the database immediately, and from the terminal's copy at its next refresh, within 15 minutes. If you leave and an administrator removes your account, the terminal stops recognising you within 15 minutes, and your face readings are deleted from the database automatically 30 days after the removal. Until then an account removed by mistake can be restored as it was. |
| Attendance and daily time records | For as long as the university is required to keep daily time records under Civil Service and government records rules. Withdrawing your agreement does not delete them: they hold dates and times, not your face. |
| Supporting documents | Until the document is removed from the system. |
| Profile photo | Until you remove or replace it - the old one is deleted when you do. If your account is removed, it is deleted with your face readings 30 days after the removal. |
| Account details | While you have an account. Accounts are removed by an administrator; when one is, your name and employee details stay with your attendance records, which have to be kept. Your face readings do not - see above. |
| Audit trail | Kept for accountability. No automatic deletion is set up yet; the period is for the university to set. |
| Scans taken offline | On the campus server only until they have been sent to the database. |
7. How it is protected
- Face readings are encrypted by the system with AES-256 before they are stored, so they cannot be read even by the database host.
- Attendance records are kept in a database that its host encrypts at rest with AES-256, and the system only connects to it over an encrypted (TLS) connection.
- Scans taken while the connection is down are encrypted with AES-256 on the terminal until they are sent, so they cannot be read from the terminal's disk.
- Passwords are stored as one-way hashes, and changing one requires the current password.
- Each role reaches only the parts of the system it needs, and employees see only their own records.
- Administrative actions and decisions about face enrolment are recorded in the audit trail.
- Sign-in sessions are encrypted where they are stored.
- Within the campus, the system is reached over the local network. The university is responsible for securing that connection.
- The terminal is put into service with a PIN and can be restricted to the campus network.
- Repeated failed sign-in attempts are limited.
No system is perfectly secure. If a breach affects your personal information, the university will act on it as the Data Privacy Act requires, including notifying the National Privacy Commission and the people affected where the law calls for it.
8. Your rights
Under the Data Privacy Act you have the right to:
- be informed about how your personal information is processed - which is what this policy is for;
- access the personal information held about you;
- object to processing, including by declining or withdrawing your agreement to face enrolment;
- correct information that is wrong;
- have information removed or blocked where the law allows;
- data portability - to obtain your information in an electronic format you can use;
- be compensated for damage caused by inaccurate, incomplete, outdated, false, unlawfully obtained or unauthorised use of your personal information; and
- complain to the National Privacy Commission (privacy.gov.ph).
How to use them
- From your profile you can update your name and email address, see whether you are enrolled and which notice you agreed to, and withdraw your agreement - which deletes your face readings.
- You can view and print your attendance history and daily time record from your account.
- For anything else - a copy of your information, a correction to a record, or a question about this policy - contact the HR office (see section 11).
9. Cookies and your browser
The system uses only what it needs to work:
- a session cookie, which keeps you signed in and is encrypted;
- a security token that stops other websites submitting forms as you;
- a "remember me" cookie, only if you tick that box when signing in; and
- on the attendance terminal, a cookie recording that it was put into service with the PIN, which lasts until midnight, and a stored copy of one static "reconnecting" page, shown if the terminal is opened before the system has started. Neither holds personal information.
There are no advertising or analytics cookies, and nothing tracks you across other websites.
10. Changes to this policy
When this policy changes, the date at the top changes with it. When the part about face data changes, the enrolment notice gets a new version, and you are asked to read it and agree again the next time you open face enrolment.
11. Contact
Pangasinan State University - Asingan Campus. A Data Protection Officer has not been named for this system yet; raise questions with the HR office.
See also the Terms of Use.