What are the most significant cases or transactions that your legal team has recently been involved in?

The Philippine Data Privacy Awareness Program was launched in 3M Global Service Center-Philippines in 2017 following the issuance of the IRR for the Data Privacy Act of 2012. It involves comprehensive plans and activities focused on the development of employees’ knowledge, awareness and competency on data privacy compliance and best practices, which are locally and globally aligned with 3M policies and standards. Under my leadership, this program was expanded to cover all 3M entities in the Philippines. The objective of this program is to build upon 3M’s data privacy framework and strategic priorities by implementing country-specific activities that aim to instill a data privacy compliant mindset among employees and teach the general principles of data privacy, namely: Transparency, Proportionality and Legitimate Purpose.

To help drive this program, we formed a Data Privacy Team (DP Team) composed of volunteers from all of the company’s workstreams, who serve as Data Privacy Ambassadors. We also conducted key activities the past years like the Privacy Awareness Week Celebration pursuant to Presidential Proclamation No. 527. This is a yearly weeklong celebration, which is held every last week of May across all 3M entities in the Philippines. The aim of this event is to promote data privacy awareness, compliance and security. The event also consisted of privacy updates, brain teaser quizzes and refresher trainings.

Upon completion of the Data Privacy Maturity Assessment, it was observed that all 3M GSCs use a standard “new work request form” that is managed by each GSC’s Change Delivery Team. However, this form does include a question intended to capture any regulatory compliance issues/risks specifically, with regard to data privacy. Also, the GSCs do not conduct independent compliance assessments during the transition process. Hence, it was recommended to revise the global work request intake form to include additional questions intended to clarify data privacy/data security risks or issues. Acting on this recommendation, I together with my Data Privacy colleagues worked with the GSC Change Delivery Teams in revising the GSC “work request intake form” with additional questions related to privacy risk purposes. Under this new process, the Change Delivery Teams should route the responses to these questions to the dedicated GSC privacy compliance SME, which is me for 3M GSC-PH, for review and escalation, as needed. Following the Principle of Privacy-by-design, we want to take into account all data privacy considerations at the onset and throughout the entire transition process for all projects. By doing this, we aim to mitigate, if not eradicate, all privacy issues from the start of the transition until its full implementation.

How important is choosing to work with external lawyers who align with your company’s values? Are you likely to reconsider what firms you work with based on this? 

In 3M, we pride ourselves in doing business the right way with uncompromising honesty and integrity. In fact, for the 10th consecutive year, we’ve been again recognised by Ethisphere as one of the most ethical companies in the world. This is a reputation and legacy that we value as a company and as employees. Hence, it is very important for us that all of our external vendors/third parties, including external counsels, share the same values and principles. Hence, we only want to work with external counsels who extend excellent legal services and at the same time, know the importance of being ethical in the practice of law. In reality, this is easier said than done especially for a multinational company that has presence in multiple jurisdictions. But that it is a challenge that we accept with open arms and we’ve been successful so far.

What diversity, equity and inclusion initiatives have you and your legal department been championing within your company’s endeavours? 

3M is very big on Diversity, Equity and Inclusion (DEI). We believe that it is essential in making a working environment safe, productive, harmonious and enjoyable. I have been the 3M Pride Champion in the Philippines for about four years now. In this role, I work with our local Pride team in implementing 3M’s initiatives and conducting trainings designed to promote and protect the interests of our LGBTQ+ employees. One of the key initiatives that we have implemented is instilling the principles of SOGIE in the workplace via trainings and awareness campaigns. We believe that this is an integral part of educating our colleagues about the LGBTQ+ community. We were also actively involved in spreading awareness about the Safe Spaces Act (RA 11313) especially in relation to gender-based sexual harassment in the workplace. In relation to this law, we made substantive revisions to our Anti-Sexual Harassment Policy to make it conform to the new regulations especially in handling complaints dealing with gender-based sexual harassment, among others. As Pride Champion, I believe that the legal department has a crucial role in championing DEI. In the workplace, legal personnel are often seen as a beacon in championing the interests and welfare of the marginalised. Hence, the legal team’s participation in this movement is essential.

As we live in a fast-paced world today, what skills will a corporate legal team need to succeed in the modern in-house industry? 

Corporate legal teams nowadays need technological savvy. With remote work being the norm, it is important for these teams to be able to effectively cater to the needs of internal clients even without physical interaction. It is also essential to be agile in order to address constantly changing needs of the business. The more corporate legal teams are able to easily adapt to these changes, the more effective they will be.

It is likewise vital for corporate legal teams to have a proactive and preventive mindset. They must be able to anticipate risks and formulate action plans to mitigate or avoid these risks altogether ahead of time. Gone are the days of constantly “fire fighting” or being reactive in extending legal services. To be a value-add to the business, in-house teams must further be embedded in the business and see things from the perspective of their internal clients. Having this synergy will result to effective collaboration and thus, making the team being seen as an effective and integral part of the business.