Accounting outsourcing Tohmatsu Co. Ltd., Privacy Policy (Declaration of Protection of Personal Information )

As a business operator handling personal information as defined under the Act on the Protection of Personal Information (hereinafter the “Personal Information Protection Act” or the “Act”), Accounting Outsourcing Tohmatsu Co., Ltd. (hereinafter referred to as "AOT") recognizes the need and importance of protection of personal information.
To ensure rigorous protection of personal information, AOT will comply with the newly established basic policy below concerning protection of personal information, and will familiarize all personnel with this policy.

1. Basic Policy

1. AOT will comply with the Personal Information Protection Act, guidelines issued by relevant authorities and other laws and regulations concerning proper handling of personal information.
2. AOT will collect personal information in an appropriate manner, and except as otherwise provided for by law, will use such information received within the purpose of use of personal information that has been announced in advance, or notified or expressly indicated at the time of receipt.
3. In order to prevent loss, alteration or leakage of personal information, AOT will implement appropriate safety procedures for handling of personal information, including information security measures.
4. AOT will review, on a regular basis, its management system and efforts for the protection of personal information to attain continuous improvement.

2. Handling of Personal Information

By posting the “Declaration of Protection of Personal Information” on this website, AOT announces in advance the purposes of use of personal information and the potential joint use of personal information.
In the acquisition and usage of individual personal information, AOT will specify the purpose of use as much as possible, and will use personal information within the scope of the purpose that is deemed to have consented by the individual. AOT will indicate the purpose of usage clearly on Individual personal information register and AOT will set up and perform checking steps to be taken to prevent any deviance from the usage of purpose on Personal Information managers’own responsibilities in each departments where any personal information is handled.

(1) Purposes of Use of Personal Information

(i) To introduce and/or provide various services (including the relevant procedures, in case there are confirmation procedures which are necessary to check independence and conflicts of interest, etc. in the relation with accounting audit and assurance services by Deloitte Touche Tohmatsu LLC),
(ii) To provide information through publications (including newsletters and other information provided on websites, by email, and by other means) issued by AOT or each entity of Deloitte Touche Tohmatsu (Japan Group), and information on their sale and subscription;
(iii) To inform about and operate various seminars and study sessions;
(iv) To select and hire personnel (including, directors and any other staff engaged in business within AOT, irrespective of their names) and to manage them after the hiring;
(v) To make proposals, take statistics, conduct researches and respond to requests for advice from public organizations concerning services provided by AOT or each entity of Deloitte Touche Tohmatsu (Japan Group), and to otherwise engage in contribution to society;
(vi) To respond to various inquiries from you; and
(vii) To implement comprehensive risk management based, inter alia, on the requirements for compliance with laws and regulations and quality control.

* “Deloitte Touche Tohmatsu (Japan Group)” is consisting of member firms in Japan of Deloitte Touche Tohmatsu Limited (a UK private company limited by guarantee; hereinafter “DTTL”). Please click here for the Privacy Policy of each entity of Deloitte Touche Tohmatsu (Japan Group).

(2) Joint Use

Joint Use by Entities of Deloitte Touche Tohmatsu (Japan Group)

AOT may jointly use any personal data acquired by AOT with any other related entity or entities of Deloitte Touche Tohmatsu (Japan Group) or with any other member firm or firms of DTTL within the scope of any of the above-mentioned purposes.

(i) Items that may be co-used

＜Outside Information＞
• Name (including the place of work, division to which the person belongs, title, position, that could lead us to identify the name of the relevant person), address, telephone number, facsimile number, email address, matters requested by the relevant person.
• Matters concerning the inquiries
• Matters concerning services provided to
* The above items exclude any personal information within the scope of outsourcing contract handled by Accounting Outsourcing Tohmatsu K.K. in connection with its outsourcing services.

＜Inside Information (Information on Personnel)＞
• Name and other information concerning employment and evaluation management

(ii) Scope of joint users:

•  Deloitte Touche Tohmatsu (Japan Group) (please click here for the list of entities)
•  Member firms of DTTL (please click here for the list of member firms)
• Tohmatsu Corporate Health Insurance Kumiai (Japan) (for employee information)

(iii) Entity responsible for management of joint use: Deloitte Touche Tohmatsu LLC

(3) Provision to Third Parties

As a rule, AOT（and/or entities of Deloitte Touche Tohmatsu (Japan Group)） will not provide personal data to any third party except where such provision is permitted by applicable laws or regulations, or where the person is deemed to have consented to such provision under the purpose or policy of applicable laws and regulations.

3. Management of Personal Information

(1) AOT will safely manage personal information and take appropriate information security measures against unauthorized access, computer viruses in order to prevent loss, destruction, alteration or leakage of personal information.

(2) AOT will appoint an individual responsible for management of personal information in each division to implement appropriate control over personal information. Each entity of Deloitte Touche Tohmatsu (Japan Group) will ensure appropriate handling of personal information in its day-to-day business by offering training programs focused on protection and method of proper management of personal information for partners, directors and other staff.

(3) AOT will appropriately supervise its personnel and outsources with respect to the handling of personal information.

4. Procedures to Comply with Requests for Disclosure of Retained Personal Data

Upon request for disclosure or correction under the Personal Information Protection Act of any personal data retained by AOT, AOT will appropriately meet such request pursuant to laws and regulations. When there is a request to correct personal information retained by AOT, please contact Personal Information Manager as shown in “5 Complaints/Inquiries”. AOT will respond accordingly including identification confirmation, fees and other procedures.

5. Complaints/Inquiries

If you have complaints, opinions or questions regarding the handling of personal information by AOT, please contact as indicated below.

【Personal Information manager】
TEL：052-565-5518
FAX：052-565-5535
Please contact here

【”Authorized Personal Information Protection Organizations” that we are to be a target entity and the complaint window】
Japan Institute for Promotion of Digital Economy and Community (JIPDEC)
PrivacyMark Promotion Center
Roppongi First Building, 1-9-9, Roppongi, Minato-ku, Tokyo 106-0032
Phone: +81-3-5860-7551

Online Privacy Policy

Deloitte Touche Tohmatsu (Japan Group), is consisting of member firms in Japan of DTTL. DTTL has established an online privacy policy for adequate and good-faith handling of personal information received via website.

Regarding personal information received via website, our online privacy policy/statement will apply to the matters of characteristics of website, among other matters. Such policy is referred to 1) DTTL global’s policy/statement (click here to the reference) for the matters on the DTTL global website, and, 2) each member firms(including Deloitte Touche Tohmatsu (Japan Group))’s policy established in each companies for the matters on their own websites managed by them(our)selves each.

When you choose to register or submit information via this website, you are deemed to have agreed that the said policy applies to such information, with the understanding that this website contains links to other websites (that are not governed by Deloitte Touche Tohmatsu (Japan Group)’s and/or DTTL global’s privacy policy/statement, i.e., websites under control of other DTTL member firms ).

• Please click here to refer to our online privacy policy in Japan.

* With respect to any personal information sent to us via our website (either DTTL global’s or Deloitte Touche Tohmatsu (Japan Group)’s) in Japan, any matter (application for a seminar, for example) for which an individual‘s consent will be obtained in the application forms and/or files sent, etc. under the specific guidance and/or notes explaining the handling with the personal information stated herein, such individual consent and/or acknowledge shall, by its nature, prevail over the above-mentioned privacy policy.