Data Privacy Declaration


This Data Privacy Declaration outlines how the Great Seas Mariners Training Center (GSMTC)collects, uses, stores, and protects your personal information in compliance with the Data Privacy Act of 2012 (RA 10173), its Implementing Rules and Regulations, and MARINA Circular SC-2021-12 including requirements under AD-59 and AD-60. By proceeding to log in to the Learning Management System (LMS), you acknowledge and agree to the terms stated below.


1. Purpose of Data Collection

The GSMTC collects, processes, and stores your personal data strictly for the following lawful purposes:

  1. To verify your identity and eligibility for enrolment in STCW-approved distance-learning and e-learning courses.
  2. To manage your LMS account, including registration, authentication, password management, session access, and course participation.
  3. To support the delivery of asynchronous and synchronous learning, assessments, assignments, digital records, and training completion requirements as required under MARINA AD-59/AD-60.
  4. To generate and issue training records, progress reports, certification, and MARINA-required documentation.
  5. To maintain security, integrity, and traceability in accordance with LMS security and registration procedures.
  6. To comply with institutional, regulatory, accreditation, and audit requirements.

2. Personal Data to be Collected

Depending on your course and system usage, the GSMTC may collect the following:

  • Full name, date of birth, nationality, and personal identifiers
  • Contact information (email, phone number)
  • PRC/SID/SRB or government-issued ID numbers (when applicable)
  • LMS login credentials (username and encrypted password)
  • Course enrolment records, attendance logs, submissions, assessment results, and feedback forms
  • IP address, device information, and session activity logs (for authentication and security)
  • Audio/video recordings of synchronous sessions (when required for monitoring and compliance)
  • System logs required by MARINA for audit and surveillance

3. Legal Basis for Processing

Your data is processed under the following lawful bases:

  • Contractual necessity – to provide training, assessment, and certification services.
  • Compliance with legal obligation – to follow MARINA standards and retention requirements.
  • Legitimate interests – ensuring platform security, preventing cheating, and maintaining academic integrity.
  • Consent – for voluntary or optional processing such as surveys or feedback.

4. Data Storage and Retention

  • Your data will be stored in secured LMS servers protected by access controls, authentication systems, and firewall configurations compliant with AD-60 requirements.
  • Personal data, course records, assessment logs, and system-generated files shall be retained for at least one (1) year or longer when required by MARINA, QMS policies, or legal obligations.
  • Backups, archives, and digital records follow secure retention and disposal procedures.

5. Data Sharing and Disclosure

Your data may be shared only with:

  • MARINA STCW Office for accreditation, monitoring, inspection, and surveillance
  • Accredited instructors, assessors, and administrative personnel involved in course delivery
  • LMS developers or authorized IT personnel for technical support and system maintenance
  • Regulatory bodies when required by law

Your data will never be sold, distributed, or disclosed to unauthorized third parties.


6. Security Measures

The GSMTC implements technical, organizational, and physical security controls to protect all student data including:

  • User registration and de-registration protocols
  • Password management and confidentiality statements
  • Privilege and access management
  • Session time-out, authentication logs, and geo-fencing/geo-mapping for assessments
  • Anti-tampering, anti-hacking, and intrusion-prevention mechanisms
  • Routine updates, maintenance, and server hardening
  • Encryption of sensitive information
  • Secure backup and disaster-recovery procedures

These measures satisfy the LMS security and intellectual property requirements outlined under AD-60.


7. Your Rights as a Data Subject

You have the following rights under RA 10173:

  • Right to be informed – to understand how your data is processed
  • Right to access – to request a copy of your personal data
  • Right to rectification – to correct inaccurate or outdated information
  • Right to erasure/blocking – subject to regulatory retention obligations
  • Right to object – when processing is based on consent
  • Right to file a complaint with the National Privacy Commission

Requests must be submitted to the GSMTC Data Protection Officer (DPO).


8. Consent and Acknowledgment

By clicking “I Agree” and proceeding to log in, you acknowledge that:

  • You have read and understood this Data Privacy Declaration.
  • You voluntarily give consent to the GSMTC to collect and process your personal data for legitimate academic, administrative, security, and regulatory purposes.
  • You understand that refusal to provide required data will prevent access to the LMS and its services.
  • You agree to follow the Digital Learning Code of Conduct and uphold academic integrity.

If you do not agree, please click “I Do Not Agree” and contact the GSMTC for assistance.


9. Contact Information

For questions, concerns, or data-related requests, you may contact:

Data Protection Officer (DPO)
Great Seas Mariners Training Center