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 domestic subsidiaries and affiliates (hereinafter collectively referred to as “Sanden Group”) hereby announce the following matters, based on the Personal Data Protection Law of Japan, 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 Sanden Group that are covered by this policy.



I. Usage of Personal Data

(1)

Except when personal data is obtained from customers, suppliers, job applicants, employees (regardless of the types of their contracts), external organizations, subcontractors, shareholders, and other parties (Herein after collectively reterred to as “customers, etc.”), via written documentation stating the purposes for which they will be used, Sanden Group will use personal data as follows.


1. Business Activities: Client Data

・ Investigations concerning clients

・ Product shipments, communications, and exchanges of data materials with clients

・ Charging the proceeds from product sales, and other general business activities


2. Business Activities: Customer Data

・ Communications and exchanges of data materials with customers

・ Requesting customers to respond to a questionnaire survey

・ Introduction of new products

・ After-sale and other related services

・ Other general customer management


3. Management of Suppliers

・ Selection and investigation of suppliers

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

・ Payments of purchases goods to suppliers

・ Other general supplier management


4. Recruitment and Employee Data Management

・ Contacts with job applicants

・ Recruitment and transition support for new recruits

・ Processing and management of personal data of employees and retirees, and application processing for internal recreational benefits


5. Management of External Organizations

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

・ 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

・ Other subcontractors management


7. Management of Shareholders

・ Communications and exchanges of data materials with shareholders


8. Other

・ Sanden Group may receive personal data in the course of Corporate Social Responsibility and other activities, and will inform those concerned whenever it does



(2)

Sanden Group may consign business to third parties, including its group companies, for the effective use of customers' personal data and to the extent necessary to achieve the purposes stipulated in the paragraph of I. "Business activities: client data". 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.


(3)

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. “Business activities: client data”, and for the integration of the Sanden Group’s businesses.
Sanden Group will be fully responsible for managing such personal data, based on agreements with its group companies and other organizations.



II. Providing Personal Data to Third Parties(Article 23, Sections 2 and 3 of the Personal Data Protection Law)

Sanden Group will strictly control personal data received from customers, and will not disclose such information to any third parties without their consent, except in the following cases:


・ When required by law

・ When necessary to protect life, health, or property, if it is difficult to obtain consent from the individual concerned

・ When necessary to protect public health or child raising, if it is difficult to obtain consent from the individual concerned

・ When it is necessary to cooperate with national or local authorities, or anyone who is commissioned thereby in their performance of operational
    works provided by law, and if acquiring consent from the individual concerned may disrupt such work.



III.Procedures for Disclosure and Other Requests(Article 29 of the Personal Data Protection Law)

Sanden Group will respond to any requests regarding personal data retained by Sanden Group (hereinafter referred to as "retained personal data") by the individuals concerned or their representatives, for disclosure, modification, suspension of retained personal data, and other revisions of the usage of retained personal data held (hereinafter referred to as “disclosure, etc.”).


(1)

Items to be indicated in disclosure requests (information contributing to identify retained personal data held):


Items of retained personal data held to be disclosed are as follows: Name, address, telephone number, email address.

Name address telephone number email address

(2)

Disclosure Request Method and Addressee:


Disclosure requests 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 Request Enclosed”, would be appreciated. Applications are to be sent to the following address:


Sanden Holdings Corporation
Legal & Compliance Dept., Administration Division

Akihabara Daibiru Building,

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

101-8583

(3)

Disclosure Request Documents to Be Submitted:


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


(4)

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 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 Sanden Group 1 copy

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


(5)

Disclosure Request Fees:


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


(6)

Responses to Disclosure Requests:


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


(7)

Usage of Personal Data Obtained from Disclosure Requests:


Personal data obtained from requests for disclosure 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:

Sanden Group will not disclose personal data 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 Sanden Group.

・ Applying agent’s authority cannot be confirmed.

・ Errors on application forms.

・ Subjects of disclosure requests are not included in personal data held.

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

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

・ Disclosure is in violation of other laws.

 

IV. Complaints Desk(Article 24, Section 1, Subsection 4, and Article 31, of the Personal Data Protection Law, Article 5 of the Personal Data Protection Enforcement Regulations)

(1)

Complaints Concerning Treatment of Personal Data:


Complaints concerning Sanden Group’s treatment of personal data are to be submitted as follows.


・ Via Telephone:

Sanden Holdings Corporation Legal & Compliance Dept., Administration Division
Phone: +81-(0)3-5209-3297

・ Via Postal Letter

Sanden Holdings Corporation Legal & Compliance Dept., Administration Division
Akihabara Daibiru Building, 1-18-13 Soto Kanda, Chiyoda-ku, Tokyo, Japan 101-8583

・ Via In-person Visit:

Complaints made by visiting Sanden Group in person cannot be accepted.

(2)

Certified Personal Data Protection Organization to which Sanden Group Belongs:


Sanden Group has no memberships in such organizations.


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