Employee laboratory results for LGU health permits

Overview

Addressing one part of an opinion that also covers cross-border certification, the NPC said employers should examine the actual LGU requirement before collecting employee health data. If proof of passing an examination suffices, a complete laboratory report may be excessive. The employer and LGU are separate controllers for information each handles.

Practice implications

Parao Law practice guidance

For physicians

When issuing a health certificate, distinguish the conclusion needed for the permit from underlying results. Confirm what the LGU actually requires and avoid routing extra clinical findings through HR. Use a secure channel for any necessary records and tell the employee what will be submitted.

For lawyers

Read the particular ordinance or permit rule and identify a lawful basis for sensitive data; the opinion did not decide whether the unspecified local requirement satisfied Section 13. Limit collection to required evidence, record who receives it, and allocate security and retention duties between employer and LGU.