Privacy Policy

Last updated: 11 August 2018

Punongbayan & Araullo (or “P&A Grant Thornton”) is the Philippine member firm of Grant Thornton International Ltd (GTIL). ‘Grant Thornton’ refers to the brand under which the Grant Thornton member firms provide assurance, tax, and advisory services to clients and/or refers to one or more member firms, as the context requires. GTIL and each member firm of GTIL are separate legal entities. P&A Grant Thornton complies with the Philippine Data Privacy Act of 2012 and is committed to protect the privacy of the subscribing company (or “Subscriber’) and reporters/whistleblowers of the ProActive Hotline Anonymous Reporting System (or “ProActive Hotline”). This Privacy Statement explains how we secure and maintain the Subscribers’ and reporters’/whistleblowers’ information, including any personal information, when collected in the ProActive Hotline. Any information provided to the ProActive Hotline will not be disclosed other than as outlined in this Policy.

P&A Grant Thornton is not responsible for the content of any Subscribers’ and reporters’/whistleblowers’ personal information saved to this ProActive Hotline. Our responsibility is limited to collecting and securing that information in accordance with the terms of this Privacy Statement, our contracts with the Subscribers and applicable law. Subscribers must ensure that their privacy policies are updated to reflect the use of the whistleblowing channel. Moreover, it is also the responsibility of the Subscriber to ensure that consent of the data subject is obtained prior to the use of this service.

Please read the following policy; it will help you to understand how we use your personal data. We may change our privacy policy at any time without giving you notice, so please check it each time you visit our website.

Whenever you give us personal data, you are consenting to its collection and use in accordance with this privacy policy.

About ProActive Hotline

ProActive Hotline is an anonymous reporting tool developed by the P&A Grant Thornton which aims to inform Subscribers about abuse, misconduct, fraud and other issues within their organisation. It is a facility that enables someone to freely report fraud, violations of laws, rules and regulations or misconduct to people of authority.

ProActive Hotline allows Subscribers to define and classify the categories of reports, assign responsible officers for each type of report and generate management reports. Upon submission of a report to the ProActive Hotline, an auto-generated e-mail notification will be sent to the selected Subscriber for its assessment. P&A Grant Thornton will never be notified nor will be able to access any submitted reports to the ProActive Hotline.

Why we collect personal data

P&A Grant Thornton does not directly collect the data but rather stores it in a secured cloud-based server and acts as an administrator of the ProActive Hotline system. ProActive Hotline maintains the company information submitted upon signing up to this service. Information submitted by the reporters/whistleblowers using the ‘Submit Report’ button in the ProActive Hotline will go directly to the selected Subscriber.

What types of personal data do we collect

We may log your Internet Protocol (IP) address in order to receive and send information from and to you over the internet. If you are submitting a report to a Subscriber of this service, this information will be communicated directly to the Subscriber. When you visit the ProActive Hotline website to make a report, you may be asked to provide some personal data such as your name, address, telephone number and e-mail address. You will not be obligated to provide such information, even if it will facilitate the resolution of the issue you are reporting. In the event you decide to provide personal data, this policy will apply.

Registration: When an organization decides to sign up for the service of the ProActive Hotline, a subscription form is required to be accomplished. This form includes the necessary information required to proceed with our service.

Assigning Category Handler/s: The Subscriber can assign responsible person/officer for each type of report. Upon subscription, Subscribers may identify two or more authorized persons who will be the recipients of the reports. In doing so, the Subscribers must enroll the names and e-mail addresses of the chosen Category Handler/s.

Reporters/whistleblowers: When a reporter/whistleblower accesses the ProActive Hotline website to submit a report, a questionnaire form is required to be accomplished. This questionnaire only includes questions pertaining to the nature and important details of the incident to be reported. The questionnaire does not require the reporters/whistleblowers to identify themselves but provides them with an option to do so. Upon submission of the report, an auto-generated tracking number is provided to the reporters/whistleblower that can be used for monitoring the status of the report made.

Where we get these personal data

The personal data we gather are those that you have given us yourself. You provide personal information when:

  • You sign up for a subscription;
  • Subscriber assigns a Category Handler; and
  • Reporters/whistleblowers fill out the questionnaire form upon submitting a report.

How we store and transmit your personal data

Your personal data will be sent and stored electronically to our primary cloud-based server in Singapore and secondary cloud-based server in Hong Kong for back-up purposes.

How long we keep your personal data

We will store and retain personal data for such period as may be required by applicable law, or as may be needed to enable us to fully and efficiently provide services to you.

We will retain your personal information for as long as the information is reasonably required to fulfill the collection of the information or until you request that we delete the information.

How we use your personal data

We use your personal data to provide information to you or your organization. When you give us personal data, those data may be sent electronically to our cloud-servers. Whenever and wherever we collect, process, or use personal data, we take steps to ensure that these are treated securely and in accordance with the Philippine Data Privacy Act of 2012 and Grant Thornton International privacy policy.

Any questions and concerns related to how the Subscriber may process, use or share your information should be coursed directly to that Subscriber by contacting it directly.

To whom might we disclose or transfer your personal data

By default, your personal data we collected are not forwarded to anyone outside P&A Grant Thornton. For those who opt to reveal their identity, the personal data you provided may be included in the report/s you file in the ProActive Hotline website that is forwarded to the Subscriber. The destination of this information may be located anywhere in the world, as defined by the Subscriber.

Except as set out above, we will not disclose your personal information unless we are obliged to do so or allowed to do so, by law, or where we need to do so in order to run our business.

By providing personal information on our website, you consent to this transfer and/or storage of personal information across borders. We ensure that a standard of protection is accorded to your personal information transferred in accordance with applicable laws.

How we protect your personal data

The integrity, confidentiality, and security of your information are important to us. We strictly enforce our privacy policy within the Firm and we have implemented technological, organizational, and physical security measures designed to protect your personal data from unauthorized access, use, alteration, and disclosure. We put in safeguards such as:

  • Keeping and protecting your information using a secure server behind a firewall, encryption, and security controls;
  • Restricting access to your information only to qualified and authorized personnel who hold your information with strict confidentiality.

We will retain your personal information for as long as the information is reasonably required to fulfill the collection of the information or until you request that we delete that information.


P&A Grant Thornton recognizes the importance of protecting children's privacy, especially in an online environment. ProActive Hotline is not intentionally designed for or directed at children under the age of 16. We never knowingly collect or maintain personal information about anyone under the age of 16.

How you can access your personal data

Subscribers who would like to request access to their information, to update their details, or unsubscribe from our service should contact P&A ProActive Hotline Administrator using the Contact page. In all cases, we will treat requests to access information or change information in accordance with applicable legal requirements.

Your rights as a data subject

You have rights in relation to your personal data under The Data Privacy Act of 2012, which includes, among others, the right to object to the processing of your data, the right to access your data, the right to modify inaccurate data, and the right to the erasure or blocking of data.

How you can contact us if you have data privacy concerns

This is the website of the ProActive Hotline which is managed and operated by P&A Grant Thornton, a member of Grant Thornton International located in the Philippines.

If you wish to access your personal information in our records, or you think that such personal information we have of you is incomplete, not updated, or inaccurate, you may get in touch with our Data Privacy Officer through the contact details provided below:

Data Protection Officer

T +63 2 988 2288 ext.360
E [email protected]
19th Floor Tower 1, The Enterprise Center
6766 Ayala Avenue, Makati City 1200