Safety management measures for personal information

In accordance with the Group Basic Policy for the Handling Personal Information, the Company shall take measures necessary and appropriate for safety management in accordance with each matter described below to prevent leakage, loss, or damage of personal information.

①　Establish privacy protection rules for the specific handling of personal information

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②　Establish an organizational structure for implementing safety management measures specified in privacy protection rules, a means for confirming the status of said structure in accordance with rules, a system for responding appropriately and promptly when a leak or other incident occurs or signs of a leak are detected, and the ongoing evaluation, review, and improvement of these measures

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③　Inform and educate employees consistently on the appropriate handling of personal information

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④   Manage areas where personal information is handled, engage in appropriate management to prevent theft, etc., of equipment and electronic media, prevent leaks, etc., when electronic media, etc., are physically relocated, provide appropriate deletion of personal information, and disposal of equipment and electronic media, etc.

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⑤  Institute access control when using information systems to handle personal information, identify and authenticate accessors, prevent unauthorized external access, and prevent of leaks, etc., associated with the use of information systems

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⑥　Take necessary and appropriate measures when handling personal information in a foreign country based on an understanding of the systems for personal information protection within said foreign country

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Provision of personal information to third parties

As a general rule, the Company shall not provide personal information to a third party without first providing the individual in question with the necessary information and obtaining said individual's consent. However, such shall not apply under any of the following circumstances.
 

①　When required by law

②　When necessary to protect the life, body, or property of an individual and obtaining consent of said individual is difficult

③　When particularly necessary to improve public health or promote the sound growth of children and obtaining consent of said individual is difficult

④　When providing personal information is necessary for cooperating with a national agency, a local government, or an individual or entity entrusted by either of the foregoing in executing affairs prescribed by laws and regulations, and obtaining the consent of said individual is likely to impede the execution of such affairs

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Provision of personal information to third parties in foreign countries

As a general rule, the Company shall not provide personal information to a third party in a foreign country without first providing the individual in question with the necessary information and obtaining said individual's consent. However, such shall not apply under any of the following circumstances.

①　When required by law

②　When necessary to protect the life, body, or property of an individual and obtaining consent of said individual is difficult

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③　When particularly necessary to improve public health or promote the sound growth of children and obtaining consent of said individual is difficult

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④　When providing personal information is necessary for cooperating with a national agency, a local government, or an individual or entity entrusted by either of the foregoing in executing affairs prescribed by laws and regulations, and obtaining the consent of said individual is likely to impede the execution of such affairs

 

Acquisition and provision of personal information

The Company shall, with the individual’s consent, link personal information used by the Company with personal information obtained from third parties (such as usage status of websites and web services collected through device identifiers such as advertising IDs and cookies), and use such information to the extent necessary to achieve the said purpose of use.

Further, in the event that personal information is expected to be acquired as personal data by the party to which it is provided, the Company shall not provide personal information to a third party without confirmation, etc., that the individual in question has provided consent.

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Creation of anonymously processed information and pseudonymized processed information

At the time of publication of this policy, the Company has not created anonymously processed information or pseudonymized processed information.

In the future, if the Company creates anonymously processed information, the Company shall disclose such, as well as what details of information about individuals are included in anonymously processed information. If the Company creates pseudonymized processed information, the Company shall disclose such and the purpose of use of the pseudonymized processed information in question.

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Contact for complaints, requests for disclosure, etc.
Complaints and requests for disclosure regarding the Company’s handling of personal information are accepted via the following contact methods.
 

〔Contact for complaints, requests for disclosure, etc.〕

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(Via physical mail)

Privacy Protection Desk, Legal and Compliance Division

Asahi Broadcasting Group Holdings Corporation

1-1-30 Fukushima, Fukushima-ku, Osaka 553-8503

 

(Online)

Contact for inquiries about personal information
(This page is available in Japanese only.)

https://cypher.asahi.co.jp/personal

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Procedures for disclosure of personal information

Follow the procedures below to request notifications of the purpose of use, disclosures, corrections, additions, deletions, suspension of use, or deletion of personal information. In principle, the Company shall respond to such requests in writing (by physical mail). Such is not the case when the request is made by the individual themselves.

①　Contact the desk for complaints and requests for disclosure in writing or via web form. Details regarding subsequent steps will be announced separately.

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②　To confirm the individual's identity, the Company may ask the individual to provide a copy of a driver's license, passport, or other official document with photo.

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③　In some cases, the Company may not be able to respond to requests for disclosure, etc., due to legal requirements. The Company will provide notification for the reason in this case.

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④　A handling fee of 300 yen (including consumption tax) and the actual cost of shipping will be charged for each request for disclosure and notification of the purpose of use.

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Changes to this policy

The Company may change the content of this policy to comply with laws and regulations or to meet business needs. In the event of any changes, the date of publication will be updated and the updated policy will be posted.

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Published by

Junji Murakoshi

Representative Director and President

Procenstudio Co., Ltd.
1-4-2 Moto-Akasaka, Minato-ku, Tokyo 107-0051, Japan

Last Updated: June 12, 2023