Basic Policies on Information Security and Handling of Personal Information

Basic Policies on Information Security and Handling of Personal Information

Basic Policy on the Protection of Personal Information

We respect the privacy of every individual. In building and operating a system that includes personal information, we will construct a personal information protection management system that will provide a service that customers can trust, and will continuously make improvements on it.

  • In our process of designing, building, and operating IT infrastructures, in order to implement our personal information protection policy in accordance to the content and scope of the business, we will build a management system for protecting personal information that meet the required criteria, and will acquire, use, and provide personal information appropriately. Further, we will establish and take measures to adhere to a policy that, in the process and handling of personal information, we will not under any circumstances use personal information for purposes other than for those stipulated.
  • We will comply with the statutes related to the protection of personal information, guidelines stipulated by the government, and regulations such as the JIS Q 15001.
  • We will take preventative measures and corrective actions against any unauthorized access, loss, destruction, damage, falsification, or leak of personal information.
  • We will secure necessary resources to operate, maintain, and improve the personal information protection management system, allocate them appropriately, and create an environment in which all related employees can take part.
  • Each department will draw up a plan every year, implement measures for carrying out the plans, and follow up regularly.
  • The personal information protection management system conducts management reviews to reassess compatibility and effectiveness of the required items on an ongoing basis.
  • We have set up a complaint and inquiry hotline to respond to complaints and inquiries from both inside and outside of the company.

    General inquiries about personal information protection
    (Personal information protection administrator Director of Quality Assurance Dept)
    Phone: +81-3-5297-8011
    Email: privacy@ap-com.co.jp

Established: April 27, 2005
Final revision: October 1, 2015
AP Communications Co., Ltd.
Takeshi Uchida, CEO

Handling of Personal Information

We will handle personal information obtained through this site, recruiting activities, etc. as explained below.

Handling of Personal Information, by Category

  • Handling Personal Information Related to Our Customers

    【Purposes of using personal information】
    (1) Communication, negotiations, fulfillment of contracts, requesting fulfillment of tasks, etc. in our business transactions.
    (2) Providing support to our customers.
    (3) Sending out various documents, such as invoices.

    【Providing personal information to a third party】
    None of the acquired personal information will be provided or disclosed to a third party, unless doing so is agreed upon by the concerned party or is in accordance with the law. However, personal information of employees of partner companies may be provided to a third party for purposes prescribed below.

    (1) Purpose of providing the information: management of contracts, to permit entry into a customer’s building (to use when an admission card is needed), emergency work-related correspondence (contacting an individual in case of emergency during business hours, at times of emergencies, and while on vacation), educational activities (understanding skills, education planning, etc.), management of health conditions at work (health management, securing appropriate work environment, working hour management, etc.)
    (2) Personal information items to be provided: name, personal background, photo, contact information, date of birth, health status, etc.
    (3) Method for providing information: by sending email, phone call, etc.
    (4) Said information provided to: clients, customers, etc.
    (5) Use of contracts when handling personal information: contract will be exchanged with each entity to which information is to be provided.

    【Entrusting of personal information】
    None of the acquired personal information will be entrusted to any third party.

    【Discretion on providing personal information and the result faced in the event that the concerned party refuses to provide the relevant information】
    The persons concerned have the right to refuse to acquire (provide) personal information. However, this may impede the process of providing services appropriately and carrying out our business operations.

  • Handling Personal Information in Executing Commissioned Work

    【Objectives of using personal information related to execution of commissioned work】
    (1) To execute commissioned business (system development, design and construction, operation and maintenance, etc.)
    (2) To execute the work of depositing salaries commissioned by a group company.
    (3) To execute the work with the publication of the e-book.

    【Provision of personal information to third parties】
    None of the acquired personal information will be provided or disclosed to a third party, unless doing so is agreed upon by the concerned party or is in accordance with the law.

    【Entrusting of personal information】
    Within the scope of the purpose of use, the handling of all or part of the acquired personal information may be consigned.

  • Handling of Personal Information of Employees

    【Purpose of using personal information】
    (1) Employment management, educational activities, managing the entrance to the Kanda Headquarters and to customers’ offices, management of work-related health conditions, salary deposits.
    (2) Business activities related to customers.
    (3) Emergency contact.
    (4) PR activities, both in-house and outside the company.
    (5) Employee recruitment activities for our company.

    Providing personal information to third parties】
    Personal information may be provided to third parties for the purposes listed below.

    (1) Purpose of providing the information: educational activities (understanding skills, education planning, etc.), managing the entrance to the Kanda Headquarters and to customers’ offices (entrance using fingerprint authentication, creating passes for entering customer’s building), management of health conditions at work (health management, securing appropriate work environment, working hour management, etc.) salary deposits (transfers of funds).
    (2) Personal information items to be provided (differs depending on objective): name, personal background, photo, contact information, bank account number, salary amount, etc.
    (3) Method for providing information: by email, through the postal service, etc.
    (4) Said information provided to: customers, financial institutions.
    (5) Use of contracts when handling of personal information: a contract will be exchanged with each entity to which information is to be provided.

    Entrusting of Personal Information】
    Within the scope of the purpose of use, the handling of all or part of the acquired personal information may be consigned.

    【Discretion on providing personal information and the result faced in the event that the concerned party (provider of information) refuses to provide the relevant information】
    The persons concerned have the right to refuse to acquire (provide) personal information. However, this may impede the process of providing services appropriately and carrying out our business operations.

  • Handling Personal Information Related to Recruitment

    【Purpose of using personal information】
    (1) Adjusting schedules for seminars, information sessions, interviews, etc.; management of applicants.
    (2) Recruitment screening, analysis of application status in the recruitment activities, checking for duplicate applications.
    (3) Sending out various documents.

    【Providing personal information to third parties】
    None of the acquired personal information will be provided or disclosed to a third party, unless doing so is agreed upon by the concerned party or is in accordance with the law.

    【Entrusting of Personal Information】
    Within the scope of the purpose of use, the handling of all or part of the acquired personal information may be consigned.

    【Discretion on providing personal information and the result faced in the event that the concerned party (provider of information) refuses to provide the relevant information】
    The persons concerned have the right to refuse to acquire (provide) personal information. However, this may impede the process of providing services appropriately and carrying out our business operations.

  • Handling of Personal Information Related to Various Seminars

    【Purpose of using personal information】
    (1) Adjusting schedules of seminars, information sessions, etc.; management of applicants, etc.
    (2) Analysis of implementation results, checking for duplicate applications
    (3) Sending out various notices

    【Providing personal information to third parties】
    None of the acquired personal information will be provided or disclosed to a third party, unless doing so is agreed upon by the concerned party or is in accordance with the law.

    【Entrusting of Personal Information】
    Within the scope of the purpose of use, the handling of all or part of the acquired personal information may be consigned.

    【Discretion on providing personal information and the result faced in the event that the concerned party (provider of information) refuses to provide the relevant information】
    The persons concerned have the right to refuse to acquire (provide) personal information. However, this may impede the process of providing services appropriately and carrying out our business operations.

  • Regarding Handling of Personal Information

    [Purpose of Use]
    Personal information is handled by our company within the scope of the following purposes.
    The purpose of use is limited to matters related to the My Number defined in Article 9, Paragraph 3 of The Act on the Use of Numbers to Identify a Specific Individual in the Administrative Procedure (My Number Act).
    Based on the Act, the employee’s My Number shall be written on documents such as tax certificate slip, report of payment, health insurance / written notice of acquisition of the welfare pension insurance qualification, and shall only be used for operations and associated operations of submission to government agencies etc. or health insurance associations etc.
    “Employees (including executives, part-time workers and retirees), employee spouses and dependent relatives etc.”
    – Health insurance, welfare pension insurance related reporting
    – Employment insurance related reporting
    – Workers’ accident compensation insurance related reporting
    – Persons insured in the third grade of the national pension plan related reporting
    – Creation of tax certificate slip related to earned income and retirement income
    “Persons such as doctors, lawyers, certified public accountants, tax accountants”
    – Creation of report of payment related to compensation, fees, contract payments and bonuses and submission to the relevant tax office.
    “Subcontracting sole proprietors, consultants and other business partners”
    – Creation of report of payment related to compensation, fees, contract payments and bonuses and submission to the relevant tax office.

    [Submission to Third Parties]
    An individual’s My Number shall only be provided to parties defined under The My Number Act. Also, even if the individual in question consents, it shall not be provided to third parties other than those established by the Act.
    (Except for certain cases defined in The My Number Act, such as when necessary to protect a person’s life, body, or property.  
    (1) When the use of My Number is required by financial institutions for payment of money at times of disaster
    (2) When the use of My Number is required for protection of life, body or property)

    [Outsourcing]
    Some My Number related administration work, such as collecting certain personal information, tax related My Number clerical work, and social security related work, may be outsourced. Only outsourcing companies that have an adequate level for handling personal information based on the personal information guidelines shall be selected. A written agreement that complies with the personal information guidelines shall be signed, and necessary and appropriate monitoring shall be conducted to confirm that the subcontractor applies safety measures in accordance with those laid out in The My Number Act.

    [Shared Use]
    Personal information held shall not be shared with other corporations, organizations etc.

    [Contact for Complaints]
    The handling of personal information is explained in “About the handling of personal information related to inquiries” in paragraph (7) of this website.

  • Handling of Personal Information Related to Inquiries

    【Purpose of using personal information】
    The personal information that you provide in this form will be used for the purpose of responding to your below inquiry.
    (1) Response to inquiries related to APC products and services
    (2) Sending out of various documents related to the inquiry.
    (3) Various information to APC products and services

    【Providing personal information to third parties】
    None of the acquired personal information will be provided or disclosed to a third party, unless doing so is agreed upon by the concerned party or is in accordance with the law.

    【Entrusting of personal information】
    The acquired personal information will not be consigned to a third party.

    【Discretion on providing personal information and the result faced in the event that the concerned party (provider of information) refuses to provide the relevant information】
    The persons concerned have the right to refuse to acquire (provide) personal information. However, this may impede the process of providing services appropriately and carrying out our business operations.

Acquisition of Delicate Information

We may acquire such information only if it is in line with the law or applies to the following:
(1) Information related to the disabled person in the case of employing such an individual based on the Handicapped Persons’ Employment Promotion Law (information included in the physical disability certificate, rehabilitation certificate, health and welfare certificate of persons with mental disorders, etc.)

Security Control Measures Regarding Personal Information

In order to prevent any loss, falsification, or leaking of personal information that our company manages, we implement rigorous security measures which include the installing Firewall, encrypting data, and supervising authority to access in-house data.

Compliance with Laws and Standards

Regarding the acquisition and use of our customers’ personal information, we comply with related laws and regulations, and properly revise and improve our efforts listed above.

Use of IP Addresses and Cookies

We do not use our customers’ IP addresses and cookies recorded in the log for any purposes other than for managing our site.

Personal Information Disclosure

【Purpose of using personal information for disclosure, by category】

  • Purpose of using Personal Information for Disclosure Related to Our Customers
    (1) Communication, negotiations, fulfillment of contracts, requesting fulfillment of tasks, etc. in our business transactions.
    (2) Providing support to our customers.
    (3) Sending out various documents, such as invoices.

  • Purpose of using Personal Information for Disclosure Related to Our Employees
    (1) Employment management, educational activities, managing the entrance to the Kanda Headquarters and to customers’ offices, management of work-related health conditions, salary deposits.
    (2) Business activities related to customers.
    (3) Emergency contacts.
    (4) PR activities, both in-house and outside the company.
    (5) Employee recruitment activities for our company.

  • Purpose of using Personal Information for Disclosure Related to Recruitment
    (1) Adjusting schedules for seminars, information sessions, interviews, etc.; management of applicants
    (2) Recruitment screening, analysis of application status in the recruitment activities, checking for duplicate applications br>
    (3) Sending out various documents
  • Purpose of using Personal Information for Disclosure Related to Inquiries
    (1) To reply to inquiries
    (2) To send out various documents

【Disclosure, etc. of personal information (notification of purpose of use, disclosure, correction, deletion, usage, termination of provision, erasure, etc.)】

For request by the person in question (or his/her proxy) to disclose or change, correct, delete, etc. personal information, contact our company’s general inquiry desk. We will respond to your request appropriately and promptly. For information on how to request the disclosure, etc. of personal information held at our company please check our Disclosure, etc. Request Form.

To here for the Disclosure, etc. Request Form

【Our Company’s Personal Information Protection Management System Complaint and Inquiry Desk】
AP Communications Co., Ltd.
Kanda Tokuriki Bldg 3F. 2-9-12 Kajicho, Chiyoda-ku, Tokyo 101-0044 Japan

General inquiries about personal information protection
(Personal information protection administrator Director of Quality Assurance Dept)
Email: privacy@ap-com.co.jp
Phone: +81-3-5297-8011