Personal Data Breach Response Procedure
Last updated: February 18, 2026
This procedure defines how PlayKorte handles potential or confirmed personal data breaches under Republic Act No. 10173 (Data Privacy Act of 2012) and NPC Circular 16-03.
1. Scope and Objective
- Apply this procedure to all PlayKorte systems that process personal data (web app, dashboard, API, database, storage, and integrations).
- Contain and remediate incidents quickly.
- Meet legal notification deadlines for notifiable personal data breaches.
- Preserve incident evidence for legal, technical, and regulatory review.
2. Breach Intake and Classification
Trigger this runbook immediately when any of the following occurs:
- Unauthorized access to personal data.
- Accidental disclosure, deletion, or corruption of personal data.
- Loss or compromise of credentials, tokens, backups, or storage objects containing personal data.
- Third-party processor notice that PlayKorte data may have been exposed.
Initial severity:
- Critical: Active exposure of sensitive personal data, broad account compromise, or ongoing unauthorized access.
- High: Confirmed exposure with contained access.
- Medium: Limited exposure risk with no current evidence of misuse.
- Low: Security event with no confirmed personal data impact.
3. Roles and Ownership
- Incident Commander: Engineering lead on call. Owns technical triage, containment, and timeline tracking.
- Data Protection Contact: support@playkorte.com (until a dedicated DPO is appointed). Owns regulatory assessment and notification approvals.
- Communications Owner: Support lead. Owns affected-user notices and support scripts.
- Recorder: Assigned engineer. Maintains an incident log with timestamps, decisions, and evidence links.
No step in this procedure should wait for perfect certainty if delay risks missing the seventy-two (72) hour deadline.
4. Timeline Requirements
Treat T0 as the time PlayKorte becomes aware of facts indicating a possible personal data breach.
- T0 to T+4 hours
- Open incident channel and assign roles.
- Start incident log with UTC and PHT timestamps.
- Contain active access (credential rotation, key revocation, session invalidation, access blocks).
- T+4 to T+24 hours
- Confirm data categories and estimated number of affected records.
- Assess likely risk of harm to data subjects.
- Decide if breach is notifiable under RA 10173 and NPC guidance.
- T+24 to T+48 hours
- Draft NPC notification and affected-user notice.
- Prepare remediation plan and support FAQs.
- T+48 to T+72 hours
- Submit notification to NPC if the breach is notifiable.
- Send affected-user notices for notifiable breaches.
- Record proof of submission and message delivery.
If complete details are not yet available by T+72, file the initial notice with known facts, then submit follow-up updates as new facts are confirmed.
5. Required Notification Content
For notifiable breaches, include at least:
- Description of incident nature and date/time discovered.
- Categories of personal data involved.
- Estimated number of affected data subjects and records.
- Likely consequences and risk level.
- Containment and mitigation actions already taken.
- Recommended protective steps for affected data subjects.
- Contact channel for support and questions.
Primary contacts:
- NPC: info@privacy.gov.ph and official NPC breach notification channels.
- Affected users: Email to the address on file, plus in-platform notice when available.
6. Technical Response Checklist
- Disable compromised credentials, rotate keys, and revoke active sessions.
- Isolate affected services, endpoints, or storage paths.
- Preserve logs and evidence snapshots before destructive cleanup.
- Verify integrity of booking and payment records after containment.
- Patch root cause and deploy fix with change record.
- Increase monitoring and alert sensitivity for related indicators.
7. Post-Incident Activities
Within 5 business days after containment:
- Complete root cause analysis and corrective actions.
- Document lessons learned and control improvements.
- Update this procedure if timeline gaps or ownership gaps were discovered.
- Confirm closure with engineering and support leads.
Retain incident records, notification artifacts, and evidence inventory according to applicable legal retention requirements.