COURTESY CONSULTING, Labor and Social Security Attorney of Japan recognizes that the protection of personal information of our clients, whose business we have been entrusted with, is one of our most important responsibilities. We are fully committed to safeguarding personal information and will handle it as follows.

1.  Respect for Compliance

We strictly manages and protects personal information at all times, in accordance with the Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures, the Act on the Protection of Personal Information, the Labor and Social Insurance Attorney's Act, and confidentiality standards.

2. Purposes for the Acquisition and Use

The purposes for the acquisition and use of customer information are clearly stated in the contract, and such information is acquired and used only to the minimum extent necessary for the execution of firm operations based on labor and social insurance laws.  Except when necessary, information is not taken out of the office nor disclosed.”

3. Staff Training and Supervision 

We conduct training on the proper handling of customer information, and only staff authorized by our firm can access this information.  Any staff member who violates our commitment to the protection of personal information will be subject to the prescribed disciplinary actions.”

4. Non-Disclosure Policy 

We will not disclose customer information to any other organizations or entities, except when instructed by the customer or as required by law under labor and social insurance regulations. Additionally, any requests for disclosure directly from employees will always be made through their employer.

5.  Policy on External Outsourcing

Our firm does not outsource work to external parties. Should the need arise to outsource any part of our work in the future, we will always obtain the client’s consent first. Furthermore, any subcontracting will be required to comply with our confidentiality standards, and we will conduct regular audits to ensure that the subcontractor adheres to these confidentiality standards.

6. Policy on Sharing Information with Third Parties 

Our firm will not share any personal information about our clients with external organizations or groups, nor provide it to third parties, regardless of the purpose, without the client’s consent.

7. Prohibition on Alteration of Personal Information 

Our firm will not alter any personal information we have received without the consent of the client.

8. Procedure for Disposing of Personal Information 

When disposing of personal information after the legally mandated retention period has expired, we will use a cross-cut shredder for paper records and completely erase electronic data.

9. Computers Handing Personal Information 

Computers handling personal information are equipped with sufficient firewalls and virus scanning capabilities. Computers that are taken outside are configured with authentication functions upon startup. 

10. Communication Through Designated Contacts

Communications with our clients will be conducted through the designated contact person specified by the client.

11. Inquiry Desk

Chizuru Yoshinaka, representative of COURTESY CONSULTING, Labor and Social Security Attorney of Japan

E-mail address:  consultation@courtesyconsulting.com

Our firm will use personal information only within the scope of the following purposes. Furthermore, when the purposes for using personal information are specifically limited by law or other regulations, we will not use the information for any other purposes.

1. Personal Information of Clients Who Have Contracts with Us

1-1  For the fulfillment and management of contracts.

1-2  For providing information and communication regarding our services.

1-3  For delivering information from us to clients.

2. Personal Information of Individuals Who Contact Us

2-1  For receiving and responding to opinions, requests, and inquiries from clients and others.

3. Personal Information of Individuals Applying for Employment at Our Firm

3-1  For communication, selection, and hiring procedures related to recruitment.

4. Personal Information of Our Employees (Including Former Employees)

4-1  For personnel, labor management, and attendance management.

4-2  For payroll management, administration of social insurance, labor safety, welfare benefits, and business execution.

5. Personal Information Handling in Our Operations

5-1  For administrative procedures (applications and notifications) based on labor and social insurance laws.

5-2  For the preparation of work rules, employment records, and documents based on labor and social insurance laws.

5-3  For consulting and advising on labor management, human resource systems, and other matters based on labor and social insurance laws.

5-4 For payroll calculations and related operations.

COURTESY CONSULTING, Labor and Social Insurance Attorney of Japan recognizes the strict protection of specific personal information, including the Individual Numbers ("My Number") of our clients and our employees, as a significant social responsibility in the course of our duties as certified labor and social insurance attorney. To ensure the proper handling of specific personal information, we have established this basic policy

1.  Scope and Structure of Handling Specific Personal Information

Our firm specifies the scope of duties that involve handling Individual Numbers and the specific personal information associated with these duties (such as Individual Numbers, personal information linked to Individual Numbers, names, birthdates, etc.). We clearly define the personnel responsible for handling these tasks. Additionally, we have established regulations for the handling of specific personal information and have organized a system to manage this information.

2.  Safety Control Measures

　　Our firm has established separate regulations for the handling of specific personal information, which outline measures to prevent the leakage, loss, or damage of such information and ensure proper management. We strictly adhere to these regulations. When outsourcing tasks that involve handling specific personal information to third parties, we will obtain prior consent from our clients, select contractors with sufficient management systems, and provide necessary and appropriate guidance and supervision.

3.  Compliance with Relevant Laws and Guidelines

Our firm complies with laws and regulations related to personal information and specific personal information, national guidelines, and the “Guidelines for Proper Handling of Specific Personal Information (for Businesses).” We ensure the proper handling of specific personal information in accordance with these regulations.

4.  Inquiry Desk for Specific Personal Information

We have established a system to respond promptly and appropriately to complaints and inquiries from individuals regarding the handling of specific personal information. For any questions or complaints about the handling of specific personal information at our firm, please contact the following inquiry desk.

• Chief Manager of Specific Personal Information: Chizuru Yoshinaka, the representative of COURTESY CONSULTING and a certified Labor and Social Security Attorney in Japan.

• E-mail address: consultation@courtesyconsulting.com

• Date of Establishment: January 1st, 2023

• Date of Revision: January 1st, 2024

This policy will be communicated and enforced among all employees and made publicly available outside the office. We will also strive to educate and raise awareness among employees to maintain and improve the protection of specific personal information.

　Publicly Available Information Based on the Act on the Protection of Personal Information and Related Laws

In accordance with the Act on the Protection of Personal Information and related laws, we hereby disclose the following matters that are required to be made public or otherwise easily accessible to the individual.

1. Purposes of Use of Personal Information When Acquired

Our office uses personal information within the scope of the following purposes. In cases where the purposes of use of personal information are limited by laws or regulations, the information will not be used for any purposes other than those specified.

A. Personal Information of Clients Who Have Contracts with Our Firm

A-1.  For the fulfillment and management of contracts.

A-2.  For providing information and communication regarding our services.

A-3.  For distributing information, such as newsletters, via email.

B. Personal Information of Individuals Who Inquire with Our Firm

B-1.  For receiving and responding to opinions, requests, and inquiries from clients and others.

C. Personal Information of Individuals Applying for Employment at Our Firm

C-1.  For communication, selection, and employment procedures related to recruitment.

D. Personal Information of Our Employees and Staff (Including Former Employees)

D-1.   For personnel and labor management, and attendance management.

D-2.   For payroll management, administration of social insurance, labor safety, welfare benefits, and business execution.

E. Personal Information Handled in Our Service

E-1.   For administrative procedures (applications and notifications) based on labor and social insurance laws.

E-2.  For the preparation of work rules, employment records, and documents based on labor and social insurance laws.

E-3.  For consulting and advising on labor management, human resource systems, and other matters based on labor and social insurance laws.

E-4.  For payroll calculations and related operations.

2. Purposes of Use for Acquired Specific Personal Information

The purposes of use for specific personal information obtained from employees or third parties, and specific personal information obtained under our consultancy agreement, are limited to the handling of Individual Numbers within the following scope:

F. Individual Number-Related Tasks for Employees of Our Firm

F-1. Employment insurance notification tasks.

F-2. Health insurance and pension insurance notification tasks.

F-3. Tasks related to claims under the Workers’ Accident Compensation Insurance Act.

F-4. Payroll calculation tasks and preparation of withholding tax slips for salary and retirement income.

G. Individual Number-Related Tasks for Non-Employees (Including Independent Contractors)

G-1. Preparation of payment records for remuneration, fees, etc.

G-2. Preparation of payment records for dividends, surplus distribution, and fund interest.

G-3. Notification tasks for No.3 insured persons of the National Pension.

G-4. Preparation of payment records for real estate rental fees, etc.

G-5. Preparation of payment records for consideration for the acquisition of real estate, etc.

H. Individual Number-Related Tasks Under our Consultancy Agreement with Clients

H-1. Employment insurance notification tasks.

H-2. Health insurance and pension insurance notification tasks.

H-3. Tasks related to claims under the Workers’ Accident Compensation Insurance Act.

H-4. Payroll calculation tasks and preparation of withholding tax slips for salary and retirement income.

Tasks accompanying the above F to H (including tasks related to handling specific personal information).

※The tasks listed under F-1, F-2 and H-1, H-2 include procedures for filing applications, applying for compensation benefits, and subsidies.

Details Regarding the Handling of Retained Personal Data by Our Firm

1. 1.  Name of Business and Representative of the Business Operator

• Name of Business/Service: COURTESY CONSULTING, Labor and Social Security Attorney of Japan

• Representative of the Business Operator: Chizuru Yoshinaka

2.  Purpose of Use of All Retained Personal Data

 (1) Personal Data of Clients with Whom Our Firm Has Contracts:

①  For the performance and management of contracts.

②  For providing information and communication regarding our services.

③  For distributing information such as newsletters.

(2) Personal Data of Individuals Who Have Inquired Our Firm:

①  For receiving and responding to opinions, requests, and inquiries from customers.

(3) Personal Data of Individuals Seeking Employment at Our Firm:

①  For communication, selection, and employment procedures related to recruitment.

(4) Personal Data of Our Firm’s Employees and Staff (including former employees):

①  For personnel and labor management, attendance management, etc.

②  For payroll management, social insurance, labor safety, welfare benefits operation and management, and business performance management.

3.  Requests for Disclosure, etc., of Retained Personal Data

(1)  Disclosure Requests:

Upon receiving a request from the individual or their representative for the disclosure of retained personal data or records of third-party provision, our firm will promptly respond in accordance with the Personal Information Protection Law, after confirming the identity of the requester, except in the following cases. The items subject to disclosure requests, etc., are listed in sections A to D above. If disclosure is not possible or if the retained personal data does not exist, we will inform the requester of that fact.

①  When there is a risk of harm to the life, body, property, or other rights and interests of the individual or a third party.

②  When there is a significant risk of interference with the proper conduct of our firm’s business.

③  When it would result in a violation of laws and regulations.

Additionally, if a request is made by the individual or their representative to correct, add, or delete information that is inaccurate, or to suspend use or erase or stop the provision to third parties of the retained personal data, our firm will conduct an investigation and appropriately respond in accordance with the Personal Information Protection Law.

(2)  How to Request Disclosure, etc., of Retained Personal Data:

Please contact us by mail, phone, email, or through the “Contact” section on our website. After confirming the content of your request, we will send you the prescribed request form, which you should fill out and return to us. At that time, we will verify the identity of the requester and, if applicable, confirm the authority of the representative.

(3) Fees:

For requests regarding the notification of the purpose of use of retained personal data and disclosure, or the disclosure of third-party provision records, a fee of 5,000 JPY will be charged, so please be aware of this in advance.

(4) Request Destination:

Please direct your requests to the contact listed in section 5 “Personal Information Inquiry Desk.”

4. Measures for the Security Management of Retained Personal Data

Our firm takes appropriate measures to manage the personal information we handle and implements necessary security management measures to prevent leakage, loss, or damage. The main security management measures we implement are as follows:

(1) Establishment of Basic Policies:

We have established basic policies to ensure the proper handling of personal information and to provide information on the inquiry and complaint processing desk.

(2) Development of Rules for the Handling of Personal Data, etc.:

We establish rules concerning the handling methods of personal data, the responsibilities of managers and staff, and their duties.

(3) Organizational Security Management Measures:

We appoint a person responsible for the handling of personal data, and establish a reporting and communication system for reporting to the responsible person in cases of violations or signs of violations of the Personal Information Protection Law or internal regulations.

We conduct regular self-inspections regarding the handling of personal data.

We regularly conduct internal audits by our internal audit department. (Applicable only to firms that conduct internal audits.)

(4) Personnel Security Management Measures:

We ensure that all staff members are informed about the proper handling of personal data and conduct regular training sessions.

We obtain confidentiality agreements concerning the handling of personal data from all staff members.

(5) Physical Security Management Measures:

We manage the entry and exit of staff members in areas where personal data is handled, restrict the devices brought into such areas, and take measures to prevent unauthorized access to personal data by unauthorized persons.

We take measures to prevent the theft or loss of devices, electronic media, and documents that handle personal data.

When transporting devices, electronic media, etc., that handle personal data, including within our firm, we take measures to prevent easy identification of personal data.

(6) Technical Security Management Measures:

We implement access control measures for personal data, including limiting, verifying, and storing access records.

We introduce systems to prevent unauthorized access to the information systems that handle personal data from external sources.

(7) Outsourcing:

When outsourcing the handling of personal data, we only provide the necessary personal data within the scope of the outsourcing, and select contractors who can implement security management measures equivalent to our firm’s standards.

We conduct necessary and appropriate supervision regularly.

(8) Understanding External Environments:

We implement security management measures based on our understanding of personal information protection systems. For an overview of these systems, including those in the United States, please refer to the following website of the Personal Information Protection Commission in Japan:

① General Information:

https://www.ppc.go.jp/personalinfo/legal/kaiseihogohou/#gaikoku

② US Federal Government:

https://www.ppc.go.jp/files/pdf/USA_report.pdf

③ New York State:

https://www.ppc.go.jp/files/pdf/newyork_report.pdf

5. Complaints, Inquiries Regarding the Handling of Retained Personal Data, and General Inquiries About the Handling of Personal Information

【Inquiry Desk】

Chizuru Yoshinaka, representative of COURTESY CONSULTING, Labor and Social Security Attorney of Japan   E-mail address:  consultation@courtesyconsulting.com