TSUNEISHI HOLDINGS CORPORATION
Policy on Protection of Personal Information (Privacy Policy)
TSUNEISHI HOLDINGS (hereinafter the “Company”) recognizes that the right to protect personal information is essential among the numerous rights of the individual. Protecting personal information is fundamental to the businesses of the Company group (hereinafter the “Group”) and our social responsibility. The Company has established the following policy on protection of personal information and will make it known to and observed by its officers, employees and cooperating workers.
1.
Observance of relevant laws and guidelines, etc
2.
Proper Collection of Personal Information
3.
Purposes of Use of Personal Information
(i)
To perform business administration of the Group companies;
(ii)
To provide integrated common services among the Group companies
(iii)
To provide and administer any information on the Company business
(iv)
To inform the Company’s shareholders, to provide various items of information, and to manage the Company’s shareholder information;
(v)
To execute rights or obligations based on laws and ordinances
(vi)
To respond to inquiries and requests from individuals about their personal information
(vii)
To perform personnel management and welfare of the Company’s employees, etc.
(viii)
To engage in activities concerning the Company’s CSR (Corporate Social Responsibility)
(ix)
To provide information about events, campaigns, services/products of the Group companies and to conduct surveys
(x)
To perform other businesses incidental to the items mentioned above
(xi)
In addition to the above, for purposes listed in “6. Shared Use of Personal Information.”
4.
Proper Handling of Personal Information
5.
Providing Personal Information to Third Parties
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 laws or ordinances;
(iii)
When it is necessary to protect lives, physical bodies, and/or property and it is difficult to obtain consent of the individual concerned;
(iv)
When it is especially required for improvement of public health or for promotion of sound growth of children and it is difficult to obtain consent of the individual concerned;
(v)
When there is a need to cooperate with a national or local government body or a person commissioned by such a body for the execution of a matter that is stipulated in laws or ordinances and obtaining consent of the individual concerned is likely to become a hindrance to the execution of the matter;
(vi)
Other cases in which providing personal information is authorized in the Act on the Protection of Personal Information.
2.
Notwithstanding the above, the Company will not provide specified personal information to third parties unless otherwise stated in laws or ordinances.
6.
Shared Use of Personal Information
(i)
Personal information items subject to shared use
・
Name, address, phone number, e-mail address, date of birth, workplace, gender, type of transaction, etc.
(ii)
Scope of those who will engage in shared use
・
Group companies of the Company
(iii)
Purposes of use
・
To execute contracts with the individual concerned;
・
To sell products and provide services offered by the Company and Group companies;
・
To provide information and conduct surveys etc. about the products and services offered by the Company and Group companies;
・
o notify the relevant company when the individual concerned has an inquiry or applies to use the products and services offered 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 items above;
(iv)
Entity responsible for the management of personal information at the Company.
TSUNEISHI HOLDINGS CORPORATION
7.
Supervision of Subcontractor Handling Personal Information
8.
Matters Related to Security Control Measures
(i)
Establishment of a basic policies
・
Basic policies are established regarding “Observance of relevant laws and guidelines, etc.” and “Contact point for dealing with a complaint” etc. to ensure that personal data is handled properly.
(ii)
Setting of rules for handling personal data
・
Rules are set for handling methods, person responsible, person in charge, and their duties for handling personal data per stage, such as acquisition, use, saving, providing, deleting, disposing, etc.
(iii)
Organizational security control measures
・
The handling status of personal data is periodically self-inspected and audited by other departments.
(iv)
Human security control measures
・
Periodic training is conducted for employees regarding points to consider in relation to handling personal data.
(v)
Physical security 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)
Technological security control measures
・
Access is controlled; the persons in charge and the range of the handled personal information database are limited.
9.
Procedures for Responding to Application for Disclosure, etc.
1.
When an individual wishes to inquire about the purpose of use of his/her personal data retained by the Company and to make corrections, additions, or deletions to the personal data, and/or suspend its use or erase the personal data, the individual can request disclosure of the retained personal data 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 charge (please consult with the Person in Charge of Handling Personal Information for the amount of charge).
2.
After the applicant is identified as the relevant individual, the Company checks the retained personal data, takes the necessary steps, and mails to the applicant a written answer to the request.
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.
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 identified;
(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
Department:General Affairs Department, TSUNEISHI HOLDINGS CORPORATION
Address:〒７２０－０３９３ 広島県福山市沼隈町常石１０８３番地
Telephone:084-987-1111
Reception time:Monday to Friday
(not including holidays and year-end and beginning period)
from 9:30 to 12:00 and 13:00 to 16:30
11.
Continuous Improvements in Privacy Policy and In-House Rules
Revised December 29, 2021
