To LMM seafarers and applicants for onboard positions:
Lydia Mar Manila (LMM) recognizes your right to privacy. In compliance with the requirements of Data Privacy Laws, please read our privacy notice explaining how we collect and process your personal information, which we also refer to as your ‘data’ or ‘information’.
What We Collect
Your personal information is collected through written records, digital records, and photographs,
- Information you provided when you applied to LMM. When you apply for a position offered by one of LMM’s principals, our office, through our Crewing Officer, Crewing Assistant, or Recruitment Officer will ask you for your personal data through a physical application form. However, a form may also be transmitted to you digitally through e-mail. Alternatively, you may fill up an online job application form on the official LMM website, if available. We also collect your resume, employment history, and softcopies of your professional and/or training certificates—if it applies to you. Furthermore, our training officers may also view your data to assess your job skills and experience. In some cases, the company president and IT officer may also assist in collecting applicant data. Additional information related to your work experience is also collected through an applicant interview, or through the references you declared in your resume. If you’ve sailed with LMM before, we may use the information already in our possession, which you previously provided in an earlier application— in order to process your new intent to secure another position onboard.
- Information we collect upon initial employment via LMM. LMM Crewing Officers, Crewing Assistants, Recruitment Officer, and Processing Specialists, collect additional information from applicants who have been accepted for the job. The information we collect include, but are not limited, to the following: (1) Travel Documents; (2) Flag State Documents; (3) Training Certificates; (4) Certificates of Competency/Proficiency; (5) Philhealth Member Registration Form; (6) Philhealth MDR or ID; (7) Pag-IBIG Member’s Data Form and/or ID; (8) Pag-IBIG Member’s Change in Information Form (MCIF); (9) Birth Certificate (applicant/dependents); (10) Marriage Contract; (11) Bank account details necessary for allotment (12) Vaccine Card (13) PEME Result.
- Information we collect through the course of your ongoing employment with the principal. As an LMM seafarer, we may collect more information about you such as data to process benefits and loan applications, performance evaluations, updated licenses, and training certificates, and information on disciplinary cases. During cases when you cannot physically submit information at our office, we may also collect your data through e-mail; and if necessary, through mobile messaging services There will also be cases when we collect your data in the form of pictures and videos as part of documentation of office events or through closed-circuit television (CCTV) cameras located in the office.
- Other Information.
For unsolicited information sent or received by LMM without prior request. If this happens, we will determine if there is legitimate grounds for LMM to keep the data. If it has no relation to our legitimate interests, then the information will be disposed of in order to protect your privacy. Otherwise, it will be treated in the same way as information you provided us.
For personal and sensitive information of other people sent to or received by LMM for the purpose of providing your next of kin’s emergency contact, dependents’ details, or other similar cases, you have the responsibility to obtain the consent of these individuals before providing us with their personal data.
How We Use
We use your personal data to pursue our legitimate interests as an employer and crewing agency, to be able to comply with laws and regulations, as well as research, historical, and statistical purposes. For example, we may use the information for purposes such as:
- Identifying applicants and processing applications;
- Assessing candidates for a position;
- Verifying provided information;
- Establishing and maintaining an accurate crew information system on web, mobile, and, desktop platforms;
- Background checking;
- Processing compensation, benefits, and standard employment functions;
- Processing human resource functions such as performance management and disciplinary issues;
- Communication of relevant news and announcements;
- Personnel training;
- Communicating and sharing promotional materials such as events and workshops;
- Compiling statistics, surveys, and research for internal purposes;
- Communicating with your of next of kin, in case of an emergency;
- Sharing your information with persons or institutions mentioned below; and,
- Other related or similar tasks.
Processing your data for the purposes mentioned is necessary in order to fulfill our contractual obligation to you, to comply with legal obligations, and to protect your interests such as life and health or for the pursuit of the legitimate interests of LMM or a third party like our Principals.
Legal Compliance on Use, Sharing and Consent
LMM will always ask for your consent, for the specific use and sharing of sensitive personal data. This is part of our compliance to the Data Privacy Act with regards to the processing of sensitive personal information. If you did not receive any formal consent form before your data was processed, please contact LMM’s Data Protection Officer (email@example.com).
How We Share, Disclose or Transfer
We may also share, disclose, or transfer your personal data to other persons or organizations in order to pursue our legitimate interests as your crewing agent. For example, we may share, disclose, or transfer your personal data for the following purposes:
- Submission of information to government agencies (e.g. Philippine Overseas Employment Agency, Social Security System, Philippine Health Insurance Corporation, Pag-IBIG, Bureau of Internal Revenue, Maritime Industry Authority) for reporting requirements, accreditation, and the provision of employment benefits dictated by the law;
- Sharing of information with insurance companies, banks, seafarers’ union (e.g. AMOSUP), PEME Clinics, health service providers, and other similar organizations in relation to your loan applications, insurance claims, and benefits;
- Sharing of information with Flag State Offices, Embassies, Airlines, and shipping agents for the purpose of planning, embarkation, and disembarkation
- Sharing of information with LMM’s Principals outside the Philippines for the purpose of facilitating your employment on their vessels: Lydia Mar Shipping Co, S.A. (Greece); Mastermind Shipmanagement Ltd. (Cyprus); Aug. Bolten Wm. Miller’s Nachfolger (GmbH & Co.) KG (Germany); F.C.M. S.R.L. (Italy); Carisbrooke Shipping Limited (United Kingdom)
- To comply with court orders and other legal obligations;
- Use of photos and videos for promotional purposes and marketing materials such as social media posts, website articles, brochures, physical and electronic bulletins, and other media;
- Live-streaming of events; and,
- Any other purpose necessary as permitted or required by the law.
LMM will never share, disclose, or transfer your data for matters unrelated to your employment or our legitimate interests as your crewing agency—unless required by law.
How We Protect
LMM exercises due diligence in limiting the access to your personal information by authorized company personnel. Physical and digital methods of protection are also used to avoid security breaches. These include, security personnel, CCTV, locks, password protection, anti-virus, and firewalls. Organizational safety measures are also applied and our staff have been briefed on the importance and implementation of data privacy.
How We Store & Retain
Your personal data is stored in paper and electronic formats as well as databases shared between departments in the office and our Principals. Access to your personal data is limited to LMM personnel who have a legitimate interest in them for the purpose of fulfilling their duties. Our use of your personal data is limited to only what is needed, and to achieve the purpose of their collection and/or when permitted by law.
Your personal data is retained only up to the following time periods:
- For Job Applicants – LMM keeps your application data for up to one (1) yearfor pooling purposes. After that time has passed, it is securely disposed of and deleted from our records.
- For Seafarers no longer actively sailing with LMM- If you no longer intend to sail with the principals of LMM, your personal documents (i.e. travel documents, training documents, and contents of your document folder, etc.) shall be returned to you as soon as possible. Any details held about your allotment accounts are also securely deleted from our records once you leave LMM. After one (1) year, copies of your signed joining documents and travel documents are securely disposed and deleted from the LMM database. Meanwhile, copies of your training credentials and certificates are only retained for a maximum of three (3) years.
However, your crew service history remains securely archived, in case you need to access official sea service records with LMM. In addition, records of your social contributions are also archived in order for LMM to comply with its reportorial requirements to the government.
Know Your Rights as a Data Owner
As a Data Owner, you have the right to correct your information; a right to access your data; a right to object to the processing of your data, a right to be informed, a right for erasure or blocking, a right to damages, a right to be able to receive a copy of your data which LMM possesses, a right to damages, and a right to remedy issues on data privacy and security with the National Privacy Commission.
Visit https://www.privacy.gov.ph/know-your-rights/ for more information on you rights, and the Philippines’ Data Privacy Laws.