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Policy on Management of Personal Information

NEC Fielding Policy on Management of Personal Information

 

Established November 1, 2001
Most recent revision October 1, 2013
Yasuyuki Nakae
President and CEO
NEC Fielding, Ltd.

 

NEC Fielding, Ltd. (“the Company”) provides IT support services for the promotion and advancement of information technology in our society. By ensuring stable maintenance and operation of information systems, we deliver the services and solutions that enable businesses to realize their potential.

 

As we pursue these goals, we consider the appropriate protection of personal information to be one of our most solemn duties to the communities we serve. We therefore establish, implement and maintain our Policy on Management of Personal Information as follows.

 

In consideration of the Company’s operational framework, the Company establishes a custodian for personal information in each department or section that handles personal information. The Company acquires, uses and provides personal information as appropriate based on the Japanese industrial standard JIS Q 15001:2006, “Personal information protection management systems—Requirements.”

We take appropriate measures to ensure that we do not handle personal information beyond the scope required to achieve the objectives specified for use of the personal information. The Company strictly complies with all laws, nationally stipulated policies and other norms with respect to the handling of personal information.
By devising the security measures that are necessary and appropriate, the Company strives to prevent and correct the leakage, destruction and loss of the personal information it handles.

 

Whenever we receive complaints or requests for advice or information from individuals regarding the handling of personal information and the Company’s management systems for the protection of personal information, we respond appropriately. Users are asked to contact the Company at the Company contact point indicated in advance.
The Company strives for the continuous improvement of its management systems for the protection of personal information, including its policies.

 

(This policy is the policy of NEC Fielding, Ltd. regarding the handling of personal information. It does not apply to NEC Corporation , other NEC Group affiliated companies or subsidiaries of NEC Fielding. For the policies of each of these companies, please inquire with the company in question in each case.)

A.Publication of the Purposes for which Personal Information is Used

  

When entrusted with personal information, the Company never uses that personal information outside the scope of its intended use as follows, except as separately notified.
The Company uses personal information appropriately in accordance with the Personal Information Protection Act of Japan and other laws and regulations, as well as the Company’s Policy on Management of Personal Information and its internal regulation. Personal information entrusted to the Company from other companies is used within the scope specified in the Company’s agreement with the entrusting company.

Types of Personal InformationPurposes of Use

(1)Personal information of customers

The following purposes in the business operations of the Company

・Provision of maintenance and support

・Contact, cooperation and negotiation with customers; execution of agreements; request for execution of agreements; etc.

・Notification of training sessions, seminars, exhibitions and other events; provision of products and service information, advertisements, etc.; proposal and provision of products and services; etc.

・Surveys and analysis to develop better products and services

(2)Personal information of business partners

・Contact, cooperation and negotiation with business partners regarding the Company’s operations; execution of agreements; request for execution of agreements; etc.

・Management of entry and exit of Company facilities

(3)Personal information of shareholders

・Exercise of rights and execution of duties in accordance with the Companies Act

・Provision of various accommodations from the Company regarding the status of shareholders

・Within the shareholder-Company relationship, various measures to ensure smooth and harmonious relationships as a member of an association and from the perspective of that association

・Preparation of shareholder data according to criteria specified in laws and regulations, and other shareholder management

(4)Personal information about people taking part in training, seminars and events

・Provision of information related to contact, training, seminars and events

・Provision of information about Company products and services, etc.

(5)Personal information about people seeking employment at the Company

・Contact, provision of information and selection of candidates

・Improvement of the Company’s website for people seeking employment at the Company

(6)Personal information about the Company’s employees (including former employees)

・Personnel and work management, etc.

・Health and safety management, etc.

・Transmission of materials and documents generated in the course of business activities, etc.

(7)Personal information accepted from business partners

・Execution of agreements with business partners in the course of the Company’s business operations, etc.

Personal information of persons other than (1) through (7) above who submit inquiries to the Company ・Contact, response management, transmission of related documents, etc.

 

・The Company may handle the personal information for purposes other than the above, provided that the Company discloses the purpose of use and obtains the individuals’ consent, or that said handling is permitted under the Personal Information Protection Act and other laws and regulations.

・The company may record or register the content of telephone inquiries for the purpose of responding promptly and appropriately, improving support services, and enabling the smooth execution of business operations.

・The Company may record audio or video using security cameras and similar equipment as a safety management measure, such as to prevent crime and respond to disasters.

B.Provision and Entrustment of Personal Information

 

The Company never provides or entrusts customers’ personal information to third parties except in the following cases:

 

1. The Company has obtained the customer’s consent

2. The disclosure is required for compliance with laws and regulations

3. The disclosure is necessary to protect human life, limb and/or property and the Company is unable to obtain the individual’s consent in a timely manner.

4. The disclosure is particularly necessary to improve public hygiene or support the sound upbringing of a child, and the Company is unable to obtain the individual’s consent in a timely manner.

5. A national or regional government body, or an organization or person entrusted to act on the former’s behalf, requires the Company’s cooperation to execute duties stipulated in laws and regulations, and it is believed that obtaining the individual’s consent for such cooperation would hinder the execution of said duties.

6. The Company’s operations are passed on to another company or organization through merger, division of operations or transfer of business.

7. The personal information is provided or entrusted to a Company affiliate, sales outlet, business partner or other person or organization, within the scope required to accomplish the “Purposes for which Personal Information is Used” listed in A. above. In such cases, the Company implements necessary safety measures before providing or entrusting the personal information, and performs necessary and appropriate supervision of the handling of the personal information.

C.Personal Information Subject to Disclosure

  

The Company informs individuals as follows with respect to their personal information subject to disclosure.

 

1. Name of the Company
NEC Fielding, Ltd.

2. Purposes of use of personal information subject to disclosure
(The following does not apply in the cases stipulated in the Personal Information Protection Act, Article 18, Paragraph 4, Items 1 through 3.)

Types of personal information subject to disclosurePurposes of Use

(1)Personal information subject to disclosure regarding customers

The following purposes regarding the Company’s operations

・Provision of maintenance and support

・Contact, cooperation and negotiation with customers; execution of agreements; request for execution of agreements; etc.

・Notification of training sessions, seminars, exhibitions and other events; provision of products and service information, advertisements, etc.; proposal and provision of products and services; etc.

・Surveys and analysis to develop better products and services

(2)Personal information subject to disclosure regarding business partners

・Contact, cooperation and negotiation with business partners regarding the Company’s operations; execution of agreements; request for execution of agreements; etc.

・Management of entry and exit of Company facilities

(3)Personal information subject to disclosure regarding shareholders

・Exercise of rights and execution of duties in accordance with the Companies Act

・Provision of various accommodations from the Company regarding the status of shareholders

・Within the shareholder-Company relationship, various measures to ensure smooth and harmonious relationships as a member of an association and from the perspective of that association

・Preparation of shareholder data according to criteria specified in laws and regulations, and other shareholder management

(4)Personal information subject to disclosure regarding people taking part in events

・Provision of information related to contact and events

・Provision of information about Company products and services, etc.

(5)Personal information subject to disclosure regarding people seeking employment at the Company

・Contact, provision of information and selection of candidates

・Improvement of the Company’s website for people seeking employment at the Company

(6)Personal information subject to disclosure regarding the Company’s employees (including former employees)

・Personnel and work management, etc.

・Health and safety management, etc.

・Transmission of materials and documents generated in the course of business activities, etc.

(7)Personal information accepted from business partners

・Execution of agreements with business partners in the course of the Company’s business operations, etc.

Personal information subject to disclosure regarding persons other than (1) through (6) above who submit inquiries to the Company ・Contact, response management, transmission of related documents, etc.

 

3. Procedure for responding to requests for disclosure
Please read “E. Items Related to Procedures for Responding to Requests for Disclosure” below.

4. Inquiries regarding the Company’s handling of personal information subject to disclosure
Please read “F. Contact Points for Inquiries/Complaints Regarding Personal Information” below.

D.Request to Customers Below the Age of 16

 

Customers below the age of 16 are asked to obtain parental consent before providing their personal information to the Company.

E.Items Related to Procedures for Responding to Requests for Disclosure

 

Individuals who have personal information subject to disclosure held by the Company or their representatives can request the disclosure, deletion, correction or suspension of use of the personal information subject to disclosure.

 

1.Contact points for requesting disclosure, etc.

 

If you would like to have your personal information disclosed, deleted or corrected, or have its use or provision to third parties suspended, please submit your request to the appropriate Company contact point where the information is registered.
If you do not know the contact point, please contact the Company as directed in “F. Contact Points for Inquiries/Complaints Regarding Personal Information” below.

 

2.Methods for requesting disclosure, etc. (formats for submitted documents and methods of confirming the identities of users or their representatives)

 

When submitting a request for disclosure, etc., please contact the appropriate contact point as described in “1. Contact points for requesting disclosure, etc.” to request the necessary form.
After entering all the required information on the request form sent to you by the Company, please enclose it with identification documents and send it to the contact point by mail. When sending the documents by mail, use a method that enables confirmation of delivery, such as registered mail or simple registered mail.

Requests for disclosure can be made by the user in question or by the user’s representative. If the request is made by a representative, please have the representative send Proof for the representative as well as the request form and the user’s identification documents to the contact point.

If the documents you submit are incomplete or some of the information is unclear, the Company will contact you. However, if the required documents are not submitted within the required time-frame, the Company will treat the matter as if no request for disclosure, etc. was submitted and return the sent documents to you.

 

3.When you submit a request for disclosure or request for notification of purposes of use, please include return postage in the amount indicated below. The Company will reply by registered mail.

 

¥540 per request

If the return postage is insufficient, or if return postage is not included, the Company will contact you. However, if the return postage is not paid within the required time-frame, the Company will treat the matter as if no request for disclosure, etc. was submitted and return the sent documents to you.

Depending on the details of the request for disclosure, etc., a separate fee may be payable.

 

4.Other notes regarding requests for disclosure, etc.

 

The procedures for requests for disclosure, etc. are subject to partial revision from time to time, to protect personal information and to respond to changes in laws and regulations. When submitting a request for disclosure, etc., please confirm the details of these procedures.
Please note that if any of the reasons for non-disclosure applies, the Company may be unable to respond to your request, or it may take time for the Company to respond.

 

Please note that a request for the suspension of use, deletion or suspension of provision to third parties of your personal information may result in your inability to use services that require the personal information.
Your request form, the documents confirming your identity and a copy of our reply will be used only within the scope required and kept on file, taking sufficient measures to ensure their security.
Additional personal information acquired by the Company as a result of your request for disclosure, etc. will be used only within the scope required to respond to your request.
Documents submitted in a request for disclosure, etc. will not be returned.

 

Replies will be sent to the requesting person at the address (in Japan) listed in the request form (to the requesting person’s representative if the request is sent by a representative).

F.Contact Points for Inquiries/Complaints Regarding Personal Information

 

Please send inquiries regarding your personal information held by the Company to the responsible contact point where you registered your customer information.

 

If you are not sure of the responsible contact point, please contact us using the inquiry form for consultation regarding protection of personal information. We will confirm the details of your inquiry and respond to you.
You can find the inquiry form under Contact Us on the Inquiries page.

 

Contact point for consultation on protection of personal information


Administrative and Legal Department
NEC Fielding, Ltd.
1-4-28 Mita, Minato-ku, Tokyo 108-0073


Inquiries received after operating hours will be handled on or after the following business day.

G.Notice Regarding the NEC Fielding Website

 

Some of the pages on the NEC Fielding website use cookies and Web beacons, to provide better service and improve convenience to you.

 

Most of the information provided on the Company’s website is available for use without disclosing or submitting personal information. Simply viewing a page does not cause the collection of personal information. For example, statistical analysis may be conducted on the number of page accesses on the website, but personal information is not included in the information used in that analysis.

 

The NEC Fielding website and websites operated by the Company may request that you provide personal information such as your name, address, telephone number and e-mail address when using the online shop (including delivery) or reserve a seminar. In such cases your personal information is protected from unlawful access during transmission through the use of SSL and other encryption technologies. Moreover, in accordance with the Company’s Privacy Policy, personal information is handled in a safe and secure environment and used only within the promised scope.
If you wish to receive services that require the submission of personal information, the Company cannot provide those services unless you submit the required personal information.

 

Cookies
Cookies are small amounts of data that are sent from our Web server to your browser to provide you with a smoothly functioning online experience.
The Company uses cookies to tailor its websites to the needs of customers and improve the website to deliver content and services that provide greater satisfaction to users. Depending on your browser settings, your browser may refuse cookies or warn you when it has received a cookie. In these cases, inability to use personalization features and other restrictions may occur.

 

Web beacons
Web beacons (clear GIFs) are a technology that uses GIF files and scripts to recognize the status of access from your computer and compile statistics on your rate of usage of specific Web pages and other information. Used together, Web beacons and cookies (discussed above) can be used to acquire detailed statistical information.
The NEC Fielding website uses Web beacons and other technologies to collect statistical information used to improve the website. By adjusting your browser settings, you can refuse cookies or receive a warning whenever cookies are accepted. Even in the case of such browser settings, however, Web beacons can confirm access status. However, the Company does not collect personal information using Web beacons.

H.Linking to Websites Other Than the NEC Fielding Website

 

The NEC Fielding website contains links to the websites of affiliated companies and third parties. These links are provided for the convenience of customers and business partners.
When you access these links, you leave the NEC Fielding website. Please be aware that the Company does not participate in the content posted on these linked websites and is not responsible for the handling of personal information on these websites.

I.Documents Related to Disclosure

 

Identification documents

Individual users

1. Please provide one copy of your personal identification indicating your name and address. This identification document must be one of the following: a driver’s license, passport, health-insurance card, alien registration card or basic resident registration card. (Please blot out the information on permanent domicile before sending.)

2. In addition to the above document, please include a copy of your certificate of residence (photocopy is not acceptable) or foreign resident registration ledger (photocopy is not acceptable).

 

Individual users as members of companies or other organizations

1.Please provide one copy of either your certificate of employment or your certification of school registration.

 

Identification documents for representatives

When submitted by a person exercising parental authority or adult guardian

One copy of each of the following two documents is required.

1. An official copy of the family register, official copy of part of the family register, family-court certificate, certificate of registered matters or other document identifying you as a person exercising parental authority or adult guardian. These documents must be prepared no earlier than 30 days before the request for disclosure, etc. Please blot out the information on permanent domicile before sending.

2. A document confirming the identity of the person exercising parental authority or adult guardian (please refer to “Identification documents: Individual users” above.)

 

For representatives appointed by the user

One copy of each of the following three documents is required.

1. Power of attorney (with the user’s signature and seal)

2. Certificate of official registration of seal for the seal impressed on the power of attorney

3. Documents confirming the identity of the representative (please refer to “Identification documents” above.)

 

Reasons for non-disclosure of personal information

・The address listed in the request form or the address listed on the identification document does not match the information managed by the Company, or the individual’s identity cannot be confirmed.

・In the case of submission by a representative, the right of representation of the representative cannot be confirmed.

・Required documents are missing or not in order.

・The details listed in the request form do not enable identification of the information managed by the Company.

・The information whose disclosure is requested does not correspond to the stored personal data described in the Personal Information Protection Law, Article 2, Paragraph 5.

・The life, limb, assets, or other rights and interests of the individual or a third party may be damaged by the disclosure.

・The disclosure is or may be exceptionally injurious to the appropriate execution of the Company’s operations.

・The disclosure may violate laws and regulations other than the Personal Information Protection Law.

J.PrivacyMark Logo

 

たいせつにします プライバシー

The Company has been awarded the PrivacyMark logo of the Japan Information Processing Development Center (JIPDEC).

 

The PrivacyMark Logo is awarded to businesses that conform to JIS Q 15001:2006, “Personal information protection management systems—Requirements” as having implemented appropriate measures for the protection of personal information.

 

When you click on the PrivacyMark, a separate window opens where you can visit the website of the JIPDEC PrivacyMark executive office.

K.Other

 

The Privacy Policy is subject to revision from time to time to improve the handling of personal information and to respond to revisions in the Personal Information Protection Act and other related laws and regulations. Revisions to the Privacy Policy are effective from the date on which they are posted (including the date on which the revised version appears).

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