TSUNEISHI ENGINEERING Co., Ltd.
Policy on Protection of Personal Information (Privacy Policy)
TSUNEISHI ENGINEERING Co., Ltd. (hereinafter the “Company”) recognizes that the right to protect personal information is essential among the many rights held by the individual. We believe that protecting personal information is the basis of our Group’s business and our social responsibility. The “Company” has established the personal information protection policy (hereinafter referred to as the” Protection Policy”). It shall be made known and shall be observed by the officers, employees and team members.
1. Observance of relevant laws and guidelines, etc
The Company will comply with the Act on the Protection of Personal Information and other applicable laws, regulations, guidelines, etc. regarding the handling of personal information.
2. Proper Collection of Personal Information
When collecting personal information, the Company will clarify the purpose of collection and use within the scope of the Company. The personal information will be obtained in a fair and lawful manner.
3. Purposes of Use of Personal Information
The Company will use the collected personal information only for the purposes stated and never use it for any other purposes. When the personal information will be used beyond the scope of the stated purposes, prior consent will be obtained in the appropriate manner from the individual concerned.
- (i) To provide information on products, services and related information of the Company and the Group companies
- (ii) To develop and improve products and services of the Company and the Group companies
- (iii) To execute rights or obligations based on laws and ordinances
- (iv) To respond to inquiries and requests from individuals about their personal information
- (v) To perform personnel management and welfare of the Company’s employees
- (vi) To engage in activities concerning the Company’s CSR (Corporate Social Responsibility)
- (vii) To provide information on services, products, events, and campaigns, and to conduct questionnaire surveys of the Company and the Group companies
- (viii) To perform other businesses incidental to the items mentioned above
- (ix) For the purposes described above as well as those described in “6. Shared Use of Personal Information.”
4. Proper Handling of Personal Information
The Company will strictly handle personal information, implement preventive measures against all risks such as loss, destruction, falsification, leakage and unauthorized access, and take necessary and appropriate measures for the safe management of personal information. Furthermore, the Company will establish concrete rules for the proper handling and use of personal information and will appoint personnel responsible.
5. Providing Personal Information to Third Parties
5.1 The Company will not provide personal information to third parties except in the following cases:
- (i) When prior consent of the individual concerned is obtained.
- (ii) When it is required by law or ordinance.
- (iii) When it is necessary to protect lives, physical bodies, and properties and when it is difficult to obtain consent of the concerned individual.
- (iv) When it is particularly required for the improvement of public health or to promote sound development of children, and when it is difficult to obtain consent of the individual concerned.
- (v) When it is necessary to cooperate with a national or local government entity or its personnel entrusted with the execution of the matter prescribed by laws and regulations, and when obtaining the consent of the concerned individual is likely to become a hindrance to the execution of the matter.
- (vi) When the provision is permitted by the Act on the Protection of Personal Information.
5.2 The Company will not provide specified personal information to third parties unless required by the law.
6. Joint Use of Personal Information
The Company may share the use of personal information with the Group companies on the following conditions:
- The Company may share the use of personal information with the Group companies on the following conditions:
・Name, address, phone number, e-mail address, date of birth, workplace, gender, type of transaction, etc.
- (ii) Scope of persons jointly using
・Our Group companies
- (iii) Purposes of use
・To execute contracts with the individual concerned;
・To sell products and provide services handles by the Company and Group companies;
・To provide information and conduct surveys etc. about the products and services handled by the Company and Group companies.
・To notify the relevant company when the concerned individual has an inquiry or applies to use the products and services handled by the Company and Group companies;
・To manage customer information of the Company and Group companies;
・To perform other tasks that are incidental to or related to the preceding items;
- (iv) Person responsible for the management of the Company’s personal information.
TSUNEISHI HOLDINGS CORPORATION
7. Supervision of Subcontractor Handling Personal Information
The Company may transfer collected personal information to a third-party subcontractor in order for example, to perform smooth operation of services. In such case, the Company will treat personal information properly by selecting a subcontractor that meets the sufficient standards for protecting personal information and including appropriate measures in the relevant contracts, etc.
8. Matters Related to Safety Control Measures
For the personal data held, the Company has taken the following safety measures:
- (i) Establishment of basic policies
・In order to ensure proper handling of personal data, we have formulated basic policies such as 『Compliance with relevant laws and guidelines』and 『Contact point for handling questions and complaints』.
- (ii) Establishment of rules for handling of the personal data
・Rules are formulated for handling of personal data for each stage such is acquisition, use, storage, provision, deletion/disposal, and related matters as well as the duties of the person responsible for the handling.
- (iii) Organizational Safety Management Measures
・The status of handling of the personal date is regularly conducted by self-inspection and audited by other department.
- (iv) Human Safety Control Measures
・Regular training is conducted for employees on matters to be noted regarding the handling of personal data.
- (v) Physical Safety control measures
・Measures are taken to prevent the theft and loss of equipment, electronic media, and documents with personal data. Measures are also taken to ensure that personal data is not easily identified when such equipment, electronic media, and other are transported, including within the office.
- (vi) Technical Safety Control Measures
・Access control is implemented to limit the scope of the persons in charge and the range of the handled personal information database are limited.
9. Procedures for Responding to Application for Disclosure, etc.
9.1 When an individual wishes to inquire about the purpose of use of his/her personal data retained by the Company OR to make corrections, additions, or deletions to the personal data, and/or suspend its use or erase it, the individual can request by making an application for disclosure, (hereinafter the “Application for Disclosure, etc.”). The individual shall mail the following documents or the like to the Person in Charge of Handling Personal Information in Section 10.
- (i) Document that includes the address, name, profession, telephone number, e-mail address of the applicant, and the purpose of the application.
- (ii) Document that identifies the applicant (a photocopy of their driver’s license or passport or national health insurance card or the like).
- (iii) Postage stamps for the mailing charge (please consult with the Person in Charge of Handling Personal Information for the postage amount.)
9.2 After the applicant is verified and confirmed as the relevant individual, the Company checks the retained personal data, takes the necessary steps, and mail to the applicant a written answer of the request.
9.3 Personal information collected through the Application for Disclosure, etc. will be used only to the extent that is necessary for the Application for Disclosure, etc. The documents mailed by the applicant will be retained for an appropriate period of time and thereafter, discarded.
9.4 If an applicant falls under any of the cases stated below, the personal information will not be disclosed. When a non-disclosure decision is made, written notice of the reason will be given to the applicant.
- (i) When the applicant cannot be verified.
- (ii) When the applicant has not paid the charge.
- (iii) When the application does not fall under an Application for Disclosure, etc.
- (iv) Cases in which disclosure might harm the life, body, property, or other rights or interests of the person or a third party
- (v) When the application is likely to cause significant hindrance to proper execution of the Company’s business.
10. Request for Disclosure of Purpose of Use and Personal Information
An individual should send an Application for Disclosure to the following Person in Charge of Handling Personal Information. The Company will respond to the application in accordance with the Act on the Protection of Personal Information.
- Person in Charge of Handling Personal Information:
Department: General Affairs Department, TSUNEISHI ENGINEERING Co., Ltd.
- Address: 1083 Tsuneishi, Numakuma-cho, Fukuyama City, Hiroshima Prefecture 720-0393, Japan
Telephone: 084-987-3003
Reception time: Monday to Friday (excluding holidays and year-end and beginning period) from 9:30 to 12:00 and 13:00 to 16:30
11. Continual Improvements to the Privacy Policy and In-House Rules
The Company will continue to improve the Privacy Policy and the internal rules so that protection of personal information being requested by society is effectively implemented.
Revised: April 1, 2022
Published: October 12, 2018
