There are only a few months left before the government’s deadline for SIM (subscriber identity module) registration.

All SIM card owners must register their SIM cards under Republic Act No. 11934 or what is now commonly known as the SIM Registration Act (SRA) before using them for mobile internet, calls, and texts.

All SIMs, including those used for mobile phones, prepaid Wi-Fi kits, and other devices, whether they are in card or electronic form, must be registered. A SIM won’t be activated and users won’t be able to use it if they are not registered by April 26.

According to the government, the law exists to safeguard consumers against nefarious practices that have been prevalent with unregistered SIM cards, including scams, smishing, and other forms of online and mobile fraud.

Because criminals can use prepaid SIMs without registering any of their personal information, it makes them more elusive to law enforcement and they are enabled to continue their illegal activities anonymously and avoid detection.

As such, all SIM users, both current and new, are required to register their SIMs with their current carriers.

Any SIM cards that have just been purchased after Dec. 27, 2022 are automatically deactivated and need to be registered before a telco company may activate them.

All SIMs supplied by telcos, authorized distributors, or resellers are required by law to be in a deactivated condition and only become active if the SIM buyer registers the SIM on one of the recognized registration platforms. Existing subscribers must register their SIM cards on these platforms based on the Law’s permitted registration period.

In the case of minors, SIMs must be registered in their parent or legal guardian’s name.

The SIM will be permanently canceled if existing users are unable to register it before the deadline. This means that they will not be able to use text, call, data, or other mobile services on that SIM, with all load and active promotion registrations becoming void.

For the registration process, new and existing SIM users are required by the Law to provide Philippine telco providers their personal information, such as name, date of birth, sex, present or official address, as well as supporting documentation such government-issued IDs like passports, driver’s licenses, or the Philippine Identification Card.

The telcos then must verify the submitted information, maintain a database with these information, and process the information only for the purposes of SIM activation or deactivation.

For foreigners, they may only use their registered SIMs for 30 days, but may avail of longer period by submitting an approved extended visa to their respective Public Telecommunications Entity (PTE). Foreign SIM end-users may register their SIMs using their passport and/or visa.

Concerns

Given that the SIM Registration Act will mean a massive data collection effort, there are many who voiced their concerns about what the government and telcos will do with the information.

Privacy Commissioner John Henry Naga raised concerns that might imply misuse of data such as notices and tick boxes on telcos’ websites asking for users’ consent to use their personal data for marketing, profiling, or sharing with third-party partners.

“Telcos must ensure the secure, ethical, and responsible handling of data, especially in all data processing being conducted in compliance with the SIM Registration Act,” Mr. Naga told reporters.

“Their obligation to comply with the SIM Registration Act comes hand in hand with ensuring that data privacy and protection is upheld. Such includes the implementation of mechanisms that would allow the assurance to its data subjects that the data being collected are for the purposes of the SIM Card Registration,” he added.

The National Privacy Commission (NPC), in general however, supports the purpose of intention of the law, citing that it can help “prevent the proliferation of various and evolving electronic communication-aided criminal activities.”

“The NPC is fully aware that implementing a SIM card registration system will entail a massive collection of personal data. Hence, there is a strong need to develop a technology-neutral approach and to future-proof the proposed legislation to achieve its intended purpose, in a manner that respects the rights and freedoms of the data subjects,” the commission said in a statement.

The commission added that it has urged the Philippine Senate and House of Representatives to take the proportionality principle and data minimization procedures into consideration when drafting the rules governing social media providers and authorized resellers.

Essentially, in order to mitigate security threats and data breaches that could result from excessive collecting and faulty or inappropriate data monitoring techniques, the NPC suggested mechanisms must be put into place.

“The NPC recommended that the burden to determine the SIM card buyer’s identity should not fall on retailers who may not have the necessary know-how or resources to properly verify the identity of data subjects and the authenticity of the identification cards that will be presented,” the commission said.

“Delegating it to these retailers may result in overcollection and improper or inadequate monitoring and security practices.”

The NPC also advised against using a central server or database due to the higher risk of a security compromise. This suggestion was since accepted in the legislation, which mandates that the PTEs or designated government organizations maintain their own databases. Telcos are only permitted to process, activate, or cancel a SIM or subscription using the database.

On the registration front, Infrawatch PH, a public policy think tank, recently expressed worry over the slow registration of SIM cards, stating that at the current rate, just 69.52% of all customers may be registered by the deadline.

“In other words, this means the removal of at least 51.5 million subscribers by the April [26,] 2023 deadline,” Infrawatch PH Convenor Terry L. Ridon said in a letter sent to the NTC dated Feb. 7.

Mr. Ridon stated that given the “deeply concerning” pace, telecommunications businesses may advocate for modifications to the implementing rules and regulations to speed up registration. According to him, the government shouldn’t permit registration shortcuts since they are stipulated by Republic Act. No. 11934.

“Allowing changes in registration procedure and requirements will defeat the purpose of the SIM Card Registration Act, particularly the wisdom of Congress to fight online scams and spams, and other malevolent activities undertaken through digital means,” said Mr. Ridon.

Progress

As of Feb. 8, the Department of Information and Communications Technology (DICT) has recorded 30.01 million SIM registrations since the process began on Dec. 27, only 17.76% of the 168.98 million subscribers nationwide.

“We are seeing good progress in terms of the registered subscribers, and we look forward to how this will translate to a safer and more secure digital communications in the coming days,” DICT Secretary Ivan John E. Uy said in a press release.

“The SIM registration in remote areas is intended to ensure that we are reaching out in areas with limited telecommunication or internet access to assist them in registering their SIMs. The DICT’s Free Wi-Fi sites will serve as the hubs for SIM registration in geographically isolated and disadvantaged areas,” DICT Spokesperson and Undersecretary Anna Mae Yu Lamentillo said. — Bjorn Biel M. Beltran

RELATED ARTICLESMORE FROM AUTHOR