Official Announcement Matter in Personal Data Protection Law of Japan

Official Announcement Concerning the Personal Data Protection Law of Japan

Sanden Holdings Corporation and its Japanese subsidiaries and affiliates (hereinafter collectively referred to as the “Sanden Group”) hereby announce the following matters, based on the Personal Data Protection Law of Japan and other applicable laws and regulations concerning items that can be and are required to be easily accessible by the individuals concerned. Please click here to see the list of the companies comprising the Sanden Group that are covered by this policy.



I. Usage of Personal Data, etc.

(1)

The purposes of use of personal data and personal identification number (including specific personal data) (hereinafter collectively referred to as "Persona Data, etc.") of customers, suppliers, job applicants, employees, external organizations,subcontractors, shareholders and other parties (hereinafter collectively referred to as “Customers”) shall be as described below, provided that when purposes of use are described in a separate document, the purposes shall be as described in such document.


Personal Data


1. Business Activities: Business Partners Data:

・ Investigations concerning business partners;

・ Product shipments, communications and exchanges of data materials with business partners;

・ Charging for product sales; and

・ Other general business activities.


2. Business Activities: Customer Data:

・ Communications and exchanges of data materials with the Customers;

・ Requesting Customers to respond to a questionnaire survey;

・ Introduction of new products;

・ After-sale and other related services; and

・ Other general Customer management.


3. Management of Suppliers:

・ Selection and investigation of suppliers;

・ Orders, communications, and exchanges of data materials with suppliers;

・ Payments for purchased goods to suppliers; and

・ Other general supplier management.


4. Recruitment and Employee Data Management:

・ Contacts with job applicants;

・ Recruitment and transition support for new employees;

・ Processing and management of Personal Data of employees and retirees, and application processing for internal recreational benefits; and

・ Other general employment management.


5. Management of External Organizations:

・ Promotion of activities at external organizations, and communications and exchanges of data materials with them; and

・ Other external-organizations management.


6. Management of Subcontractors:

・ Outsourcing business to subcontractors, and communications and exchanges of data materials with them;

・ Payment of outsourcing fees and other costs; and

・ Other subcontractors management.


7. Management of Shareholders

・ Communications and exchanges of data materials with shareholders; and

・ Other shareholders management.


8. Other

・ The Sanden Group may receive Personal Data in the course of Corporate Social Responsibility (SCR) and other activities, and will inform those concerned whenever it does, including

- Responding to various inquiries, requests, consultations and complaints;

- Provision, development and improvement of products and services;

- Provision of information relating to products, services, campaigns and seminars;

- Compliance with the national and local laws and regulations; and

- CSR and other activities.


Personal Identification Number

1. Administrative works relating to employees (including dependents) of the Sanden Group

・ Administrative works relating to the withholding taxes;

・ Preparation of documents relating to withholding for dependents (change therein) and withholding of insurance premium and special withholding for spouse relating to salaried employees;

・ Preparation of documents relating to retirement income;

・ Preparation of documents, notification and application for employee savings;

・ Administrative works for health insurance, corporate pension insurance;

・ Administrative works for unemployment insurances and work accident insurances;

・ Preparation of payment working papers relating to the employees' shareholding association; and

・ Other administrative works relating to the above.


2. Individual other than employees (including dependents) of the Sanden Group

・ Preparation of payment working paper relating to the payment of remunerations and fees;

・ Preparation of payment working paper relating to shares;

・ Preparation of payment working paper relating to the rent of the real estates, etc.; and

・ Other administrative works relating to the above.


(2)

The Sanden Group may consign business to third parties, including its group companies, for the effective use of Customers' Personal Data to the extent necessary to achieve the purposes stipulated in the paragraph of I. (1) above. The Sanden Group will select such third parties after confirming that Personal Data will be kept fully confidential, and will supervise them in accordance with contracts and by other means. When the Sanden Group consigns the business to third parties which uses personal identification numbers, it will obtain consent from Customers in accordance with the laws and regulations.


(3)

The Sanden Group may share Customers’ Personal Data with its group companies and other organizations, to the extent necessary to achieve the purposes stipulated in the paragraph of I. (1) above for the integration of the Sanden Group’s businesses. The Sanden Group will be fully responsible for managing such Personal Data, based on agreements with its group companies and other organizations.



【Items of Personal Data, etc. to be shared】

In case of any individual other than the Directors and employees of the Sanden Group: Address, name, telephone number, e-mail address, birthday, age, occupation, office/school, various inquiries, requests, consultation and complaints and other related information.

In case of the Directors and employees of the Sanden Group: Address, name, telephone number, e-mail address, birthday, age and information relating thereto. In case of personnel move, secondment and assignment, if the special consideration is required relating to tasks at the new work place, information which requires special consideration may be also shared.


【Scope of third parties with whom Personal Data, etc. will be shared】

Sanden Holdings Corporation and its subsidiaries and affiliates in Japan. The name of those third parties can be reviewed at the below website.

http://www.sanden.co.jp/company/domestic.html


【Purposes of use by the third parties】

In case of any individual other than the Directors and employees of the Sanden Group:  Responding to various inquiries, requests, consultations and complaints.

In case of Directors and employees of the Sanden Group: The purposes set out in I. (1) 4. above.


【Responsible person for management of Personal Data, etc.】

Sanden Holdings Corporation and each respective shared party.


II. Providing Personal Data, etc. to Third Parties

The Sanden Group will strictly control Personal Data, etc. received from Customers, and will not disclose such information to any third parties without their consent, except for the case provided for in laws and regulations. In case of the disclosure of the Personal Data, etc. to third parties outside Japan the same rule will apply. Personal identification number shall not be disclosed to any third party regardless of whether consent from the individual concerned is obtained, except for the case provided for in laws and regulations.



III.Procedures for Disclosure and Other Requests

The Sanden Group will respond to any requests by the individuals concerned or their representatives regarding Personal Data, etc. held by the Sanden Group for notification of the purposes of use, disclosure, correction, addition, deletion, suspension of use, elimination, or suspension of provision to third parties (hereinafter referred to as “disclosure, etc.”) except for the case where disclosure, etc. is not required pursuant to the laws and regulations.


(1)

Addressee of the Request for Disclosure, etc.


Requests for disclosures, etc. are to be submitted via postal mail, and to include an application form and necessary documents. Indication (in red ink) on the front of envelope, “Disclosure, etc. Request Enclosed”, would be appreciated. Applications shall be sent to the following address:


Sanden Holdings Corporation
Administration Management Office, Administration & Human Resources Division

Akihabara Daibiru Building,

1-18-13 Soto Kanda, Chiyoda-ku, Tokyo, Japan

101-8583

(2)

Documents to be Submitted for Request for Disclosure, etc.:


Application Forms are to be downloaded, filled out completely, and mailed with copies of identifying documents to identify the individual concerned.

A. Application Forms:


B. Identifying Documents:

Driver’s license or passport copy. 1 copy


(3)

Disclosure Requests by a Representative:


If the party requesting a disclosure is a statutory agent for the individual concerned, a minor or an adult under guardianship, or a consigned agent of the individual concerned, enclosure of the either document (for Statutory Agent or Consigned Agent) below will be appreciated.


A.Statutory Agent:

・ A declaration form prescribed by the Sanden Group 1 copy

・ Confirmation of authority (copy of a family register or health insurance certificate describing the names of dependents are acceptable for agents with parental authority) 1 copy

・ Identification for the statutory agent of a minor or an adult under guardianship (copy of the agent's driver's license or passport) 1 copy


B. Consigned Agent:

・ Power-of-attorney form prescribed by the Sanden Group 1 copy

・ Certificate of the seal impression of the individual concerned 1 copy


(4)

Disclosure Request Fees:


300 yen per request (please enclose postage stamps equivalent to 300 yen.) Note: If fee payments are insufficient or not enclosed, the Sanden Group will notify the sender. If no fee payment is made within the deadline prescribed by the Sanden Group, disclosure requests will be deemed void.


(5)

Responses to Disclosure Requests:


The Sanden Group will respond in written form to the addresses indicated on application forms.


(6)

Usage of Personal Data, etc. Obtained from Disclosure Requests:


Personal Data, etc. obtained from the requests for disclosure, etc. will be treated to the extent necessary to respond to such requests. Submitted documents will be retained for three months after the completion of responses to such requests and they will be scrapped thereafter.


Note: Reasons not to Disclose Personal Data, etc.:

The Sanden Group will not disclose Personal Data, etc. subject the conditions below, and will send a notice and explanation to that effect to the applicant. Fees are to be paid even in the event of such non-disclosure.


・ The individual concerned cannot be identified (e.g., discrepancies between addresses on applications, on identifying documents, and registered with the Sanden Group).

・ Applying agent's authority cannot be confirmed.

・ Errors on application forms.

・ Subjects of disclosure requests are not included in the Personal Data, etc. held by the Sanden Group.

・ Disclosure may possibly threaten life, health, property, or other rights or interests of the individual concerned or third parties.

・ Disclosure may significantly interfere with the Sanden Group's business performance.

・ Disclosure is in violation of other laws.

 

IV. Complaints Desk

(1)

Complaints Concerning Treatment of Personal Data, etc.:


Complaints concerning the Sanden Group’s treatment of Personal Data, etc. are to be submitted as follows.


・ Via Telephone:

Sanden Holdings Corporation Administration Management Office, Administration & Human Resources Division
Phone: +81-(0)3-5209-3295

・ Via Email

EMAIL US

(2)

Certified Personal Data Protection Organization to which the Sanden Group Belongs:


The Sanden Group has no memberships in such organizations.


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