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NPC: Stockholder Inspection Rights and Data Privacy in Compensation and Retirement Benefit Records

The National Privacy Commission (NPC), through its Privacy Policy Office, has issued two advisory opinions dated 25 August 2026 on how corporations may respond to stockholder requests to inspect records that contain personal data. Advisory Opinion No. 2026-005, requested on behalf of a corporation, addresses compensation records of directors and officers; Advisory Opinion No. 2026-007, requested on behalf of another corporation, addresses records on retirement and other employee benefits, related tax records, and the compensation of its top seven most highly compensated directors or officers. Both advisory opinions confirm that the Data Privacy Act (DPA) does not bar a stockholder's inspection rights under Section 73 of the Revised Corporation Code (RCC), but that disclosure must be proportionate.