Memorandum of Cooperation for Personal Information Protection between The Personal Information Protection Commission of Japan and The National Privacy Commission of the Republic of the Philippines ‐個人情報保護委員会‐
The MOC establishes a bilateral cooperation framework for cross-border data protection enforcement and information exchange between two national data protection authorities.
The agreement involves international coordination and supervisory cooperation mechanisms between regulatory authorities, though the primary focus is data protection rather than general supervision.
Product
This update concerns cross-border data protection authority cooperation and has no connection to any financial services product, service, instrument or proposition in the taxonomy.
No secondary financial product tag is applicable; this is a data protection regulatory cooperation agreement between government authorities with no financial services product dimension.
Obligation
The MOC establishes a framework for bilateral information exchange and mutual assistance between two data protection authorities, which most closely aligns with Governance and Oversight as it creates accountability structures and coordination mechanisms between regulatory bodies.
The agreement's provisions on information exchange, confidentiality protections, and restrictions on use of shared data could secondarily relate to Recordkeeping, though the MOC is primarily an inter-authority cooperation framework rather than a firm-level obligation.
Activity
This update concerns a bilateral data protection cooperation agreement between Japanese and Philippine privacy authorities and does not describe any retail financial services business activity within the FS taxonomy scope.
While data protection and privacy are foundational to financial services compliance, this update is purely administrative and institutional in nature with no connection to any specific FS business activity such as customer onboarding, account servicing, or transaction monitoring.
Themes
The MOC establishes cross-border cooperation mechanisms for data protection enforcement between two national authorities, which relates to how personal data is governed internationally, though the update is primarily an inter-agency administrative agreement rather than a direct retail customer data-handling obligation.
The framework's emphasis on information exchange, confidentiality protections and enforcement coordination has tangential relevance to operational governance and third-party risk management, though neither theme is central to this inter-agency cooperation agreement.
Functions
Data and Privacy functions may need to monitor this international cooperation framework for potential impacts on cross-border data-handling policies, though the update is primarily an inter-regulatory agreement with limited direct operational impact on a single firm.
Compliance functions may need to horizon-scan this framework for implications to their regulatory engagement strategy, though the MOC is non-binding and does not impose direct compliance obligations on individual firms.
2026-07-21 14:43:49·kgurnani@vixio.com
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TITLE: Japan's Personal Information Protection Commission Establishes Cooperation Framework with Philippine Privacy Authority
BODY:
On June 1, 2026, the Personal Information Protection Commission of Japan (PPC) and the National Privacy Commission of the Republic of the Philippines (NPC) signed a Memorandum of Cooperation (MOC) to strengthen cross-border data protection enforcement.
The MOC establishes a non-binding framework for bilateral cooperation between the two data protection authorities, recognising the need for enhanced coordination in an increasingly interconnected global economy. The agreement enables the PPC and NPC to exchange information and provide mutual assistance in enforcing their respective national personal information protection laws. Key provisions include: information exchange on contact points, enforcement records, and investigative details relevant to specific cases; restrictions on the use of shared information, which may only be used for stated purposes without prior written consent from the providing authority; confidentiality protections requiring security measures appropriate to information sensitivity; and prohibitions on using shared information in criminal investigations without explicit written approval. The MOC permits both authorities to jointly identify cooperation areas, including sharing best practices on data protection policies, privacy-enhancing technologies, joint research projects, and training initiatives. The authorities may convene bilateral meetings annually or as mutually agreed. Costs incurred by the requested authority in executing requests will generally be borne by that authority, though extraordinary expenses require consultation to determine cost allocation. The MOC commenced upon signature and continues indefinitely unless either authority provides three months' written notice of discontinuation. Both authorities may publish the MOC on their websites and coordinate public statements regarding the agreement.
The framework reflects growing international recognition of the need for coordinated data protection enforcement across jurisdictions and establishes mechanisms for the PPC and NPC to support each other's regulatory functions while maintaining their independence as distinct entities.
Memorandum of Cooperation for Personal Information Protection between The Personal Information Protection Commission of Japan and The National Privacy Commission of the Republic of the Philippines This Memorandum of Cooperation (“MOC”) establishes a framework for cooperation between the Data Protection and Privacy Authorities: (I) The Personal Information Protection Commission of Japan (the “PPC”), and (II) The National Privacy Commission of the Republic of the Philippines (the “NPC”), hereinafter referred to individually as a “DPA” and collectively as the “DPAs”. The DPAs; Recognising the nature of the modern global economy, the increase in circulation and exchange of personal information across borders, the increasing complexity of information technologies, and the resulting need for increased cross-border enforcement cooperation; Acknowledging that the DPAs have similar functions and duties for the protection of personal information in their respective countries; Reaffirming the intent of the DPAs to deepen their existing relations and to promote exchanges to assist each other in the enforcement of laws protecting personal information; Emphasizing that one of the most important and fundamental functions of the DPAs is to exercise their authorities, conferred by legislation, against violations of individual privacy and to prevent further possible breaches. This function is essential to protect the rights and interests of individuals and should not be limited unnecessarily by prioritizing the economic benefits of business operators; and Convinced that the bilateral cooperation between the DPAs may support them to exercise their authorities against violations of their national legislations on the protection of personal information, Have reached the following recognition: Paragraph 1 - General Matters (a) The Japanese Data Protection and Privacy Authority is represented by the PPC, and the Philippine Data Protection and Privacy Authority is represented by the NPC. (b) Requesting DPA means the DPA that requests information or assistance. (c) Requested DPA means the DPA to which information or assistance is requested. Paragraph 2 - Non-Binding Effect of this MOC This MOC is a statement of intent that does not give rise to legally binding obligations on the part of each DPA. Paragraph 3 - Scope of Cooperation (a) All measures mentioned in this MOC will be provided and implemented in accordance with the applicable laws and regulations of the DPA's respective jurisdictions and within the limits of its competence and available resources. (b) The DPAs will provide each other, either on their own initiative or on request, with information necessary to ensure proper application of national legislations on personal information protection by exchanging relevant information and providing necessary assistance in line with this MOC. (c) The DPAs acknowledge and concur that the PPC and the NPC are independent and distinct entities. As such, nothing in this MOC should be construed as establishing or implying a partnership, joint venture, agency, or other legal relationship between the DPAs. Paragraph 4 - Information Exchange (a) In order to facilitate information exchange, each DPA will ensure that the information on contact points is kept up to date. The DPAs will mutually exchange information on their own initiatives or on request and to the extent it is available, through the contact points. (b) On request, the requested DPA will, within the limits of the laws, regulations and available resources, provide the following information: (i) contact information of entities that the requesting DPA needs to communicate for its own investigation on a specific case, (ii) past enforcement record which deems relevant to and helpful for the requesting DPA to conduct an investigation on a specific case, provided that such enforcement records will not contain any personally identifiable data, and (iii) any other relevant information which deems relevant to and helpful for the requesting DPA to conduct an investigation on a specific case. (c) Requests in line with this MOC will be made in writing in English. Information deemed useful for the execution of such requests will accompany the requests. When the urgency of the situation so requires, oral requests may also be made and accepted but will be promptly confirmed in writing. (d) Requests in line with this MOC will include the following information: (i) the nature of the proceedings in respect of which the request is made; (ii) the purpose and the reason for the request; (iii) contact information of the persons to whom the request relates, if known; and (iv) a brief description of the matter under consideration and the legal elements involved. (e) The Requested DPA may impose restrictions and details on its use when sharing information with the Requesting DPA. (f) Personal information will not be shared, except for cases where contact information including personal information will be shared according to subparagraphs (b)(i) and (d)(iii) of this paragraph. (g) If the Requested DPA is unable to provide information, or declines or postpones doing so, it will explain the reasons why. (h) The DPAs may provide non-confidential information on their own initiative. The non- confidential information includes but not limited to methods, practices, and guidance documents that may be useful for the other DPA to exercise their legal authorities. Paragraph 5 - Use of Information (a) When the Requesting DPA receives information from the Requested DPA in line with this MOC, the information will be used solely for the purpose defined in line with paragraph 4 (d) of this MOC. Where the Requesting DPA wishes to use such information for other purposes, it will obtain a prior written consent of the Requested DPA which provided the information. Such use will then be subject to any restrictions laid down by the Requested DPA. (b) When the Requesting DPA receives information from the Requested DPA in line with this MOC, the use of information will comply with restrictions and details laid down by the Requested DPA in line with paragraph 4(e) of this MOC. (c) Information provided in line with this MOC will not be used in criminal case investigation and adjudication, without prior written consent. (d) Information shared in line with this MOC will be marked with the appropriate confidentiality classification. Security measures will be decided to be taken by the Requesting DPA for storage, use, disclosure to a third party or any other processing of the information in line with the sensitivity of the information and any classification that is applied by the Requested DPA. Where confidential information is wrongfully disclosed, the Requesting DPA who has wrongfully disclosed the information will bring this to the attention of the Requested DPA. (e) Where one DPA has received information from the other DPA in line with this MOC, it will consult with the other DPA before disclosing the information to a third party such as other relevant competent authorities or using the information in an enforcement proceeding or court case. Paragraph 6 - Further Cooperation (a) The DPAs may jointly identify one or more areas or initiatives for cooperation. Such cooperation may include: (i) sharing of experiences and exchange of best practices on data protection policies and relevant technologies including privacy enhancing technologies (PETs); (ii) implementation of joint research projects; (iii) cooperation in specific projects of interest; (iv) training and education in the field of Data Protection and Privacy; and (v) any other areas of cooperation as mutually decided by the DPAs. (b) The DPAs may convene bilateral meetings annually or as mutually decided between the DPAs. Paragraph 7 - Cost Expenses incurred by the Requested DPA in carrying out a request from the Requesting DPA under this MOC will be borne by the Requested DPA. If the execution of a request requires expenses of a substantial or extraordinary nature, the Requested DPA will consult to determine the details under which the request will be executed as well as the manner in which the costs will be borne. Paragraph 8 - Review and Modification (a) Both of the DPAs will monitor the operation of this MOC and review it biennially, or sooner if either DPA so requests. (b) Each DPA will have a point of contact, and any issues arising in relation to this MOC will be notified to the designated point of contact for each DPA through diplomatic channels. (c) Should any problem arise as to the implementation of this MOC, it will be settled amicably between the DPAs through diplomatic channels. (d) This MOC may only be modified by the DPAs in writing and signed by each DPA through diplomatic channels. Paragraph 9 - Commencement, Publication and Discontinuation (a) This MOC will commence upon signature by the DPAs and will continue indefinitely unless either DPA notifies, in written form, the other DPA of its intention to cease this MOC at least three (3) months in advance of the discontinuation date. (b) The DPAs may publish a copy of this MOC on their respective websites and social media platforms, and should coordinate with each other for any press release and statements. (c) The discontinuation of this MOC will not affect the duration of any ongoing programs or activities made under this MOC. For the Personal Information For the National Privacy Commission Protection Commission of Japan of the Republic of the Philippines Name: Dr. Satoru Tezuka Name: Johann Carlos S. Barcena Title: Chairperson, Personal Title: Privacy Commissioner of the Information Protection Commission National Privacy Commission of the of Japan Republic of the Philippines Date: 1 June 2026 Date: 1 June 2026