The rise of Online Lending Apps (OLAs) in the Philippines has brought convenient credit access, but it has also led to a surge in predatory practices. Many borrowers face "debt shaming," persistent spam, and unauthorized access to private data. Under Philippine law, these actions are not just unethical—they are illegal.

1. The Legal Framework

Several laws and regulations protect Filipinos from the abusive tactics of OLAs.

RA 10173: Data Privacy Act of 2012: This is the primary shield. OLAs often access your contact list, gallery, and social media without valid consent or for purposes beyond credit evaluation. Processing personal data to harass or shame a debtor is a direct violation.
SEC Memorandum Circular No. 18 (Series of 2019): The Securities and Exchange Commission (SEC) explicitly prohibits "Unfair Debt Collection Practices." This includes threats of violence, use of profane language, disclosure of debt information to third parties (debt shaming), and contacting people in a borrower’s contact list who are not co-makers or guarantors.
RA 10951 & The Revised Penal Code: Acts such as Grave Coercion, Unjust Vexation, and Cyber Libel may apply depending on the severity of the harassment.
RA 11765: Financial Products and Services Consumer Protection Act (FCPA): This law grants regulators more power to punish financial service providers for unfair, deceptive, or abusive practices.

2. Identifying Prohibited Acts

You are being harassed illegally if the OLA or its collection agency performs the following:

Contacting your references/contacts: Messaging people in your phone book who did not sign as guarantors.
Debt Shaming: Posting your photo or loan details on social media or creating group chats with your friends/family to shame you.
Threats of Imprisonment: Falsely claiming you will go to jail for non-payment of a civil debt (Note: Under the Constitution, no person shall be imprisoned for debt).
Misrepresentation: Claiming to be lawyers, court personnel, or police officers to intimidate you.
Excessive Contact: Calling at unreasonable hours (e.g., between 10:00 PM and 6:00 AM) or spamming your phone with hundreds of messages daily.

3. Step-by-Step Action Plan

Phase 1: Documentation (Crucial)

Before blocking the harassers, collect evidence. Without proof, regulatory bodies cannot take action.

Screenshots: Capture all threatening texts, emails, and social media posts.
Call Logs: Keep a record of the frequency and timing of calls.
Recordings: If possible, record phone conversations where threats are made (ensure you inform the other party if required by the Anti-Wiretapping Law, though harassment itself is a crime).

Phase 2: File Formal Complaints

Do not just ignore them; report them to the following agencies:

National Privacy Commission (NPC): File a "Statement of Complaint" if they used your data (contacts, photos) illegally. The NPC has the power to order the shutdown of apps found violating privacy laws.
Securities and Exchange Commission (SEC): Use the SEC OLA Complaint Form available on their website. The SEC handles violations of the "Unfair Debt Collection Practices" circular. They can revoke the OLA’s Certificate of Authority to operate.
PNP Anti-Cybercrime Group (PNP-ACG): If there are threats of violence, death, or cyber libel, visit the nearest PNP-ACG office to file a criminal complaint.

Phase 3: Technical Mitigation

Privacy Settings: Set your social media profiles to private and restrict who can tag you or comment on your posts.
NTC Reporting: Report the mobile numbers used for spam to the National Telecommunications Commission (NTC) via their email or website.
Blocking: Use built-in phone features or third-party apps to filter and block unknown callers and spam keywords.

4. Important Legal Realities

Debt is Civil, Harassment is Criminal: Defaulting on a loan is a civil matter. However, the methods used to collect that loan can be criminal. One does not cancel out the other. You still owe the principal debt, but the lender loses the right to harass you.
Cease and Desist: You have the right to demand that the OLA stop contacting third parties. Explicitly state in writing (email) that you are withdrawing any "consent" they claim to have regarding your contact list.
SEC Registration: Always check the SEC website to see if the OLA is a registered Lending or Financing Company. Many "shark" apps operate without a license, making their operations entirely illegal from the start.

Summary of Remedies Table

Agency	Issue Handled	Possible Outcome
NPC	Data privacy, contact list leakage	App shutdown, fines, imprisonment
SEC	Harassment, unfair collection, high interest	License revocation, administrative fines
PNP-ACG	Cyber libel, threats, coercion	Criminal prosecution of collectors
NTC	SMS spam and spoofing	Blocking of SIM cards/Series