Group Privacy Policy Concerning Employment Management Information

Article 1 (Employment Management Information)

The information covered by this Policy ("Employment Management Information") is as follows. The Group acquires Employment Management Information as a result of voluntarily submission, or with the subject's consent, or in the course of the Group's operations.

If we receive health information, etc. (personal data) from a third party having obtained consent, we confirm the necessary matters and prepare and store records in accordance with Article 26 of the Personal Information Protection Act.

Article 2 (Purpose of Use)

The Group acquires and uses Employment Management Information within the scope of the following purposes of use; provided, however, that Employment Management Information that constitutes health information shall only be acquired and used for the purpose of use described in item 4.

1. To conduct recruitment and hiring procedures, social insurance procedures, provide allowances, communicate on work-related matters, conduct various procedures required by law, and other procedures necessary for employment management
2. To determine and pay remuneration (wages, bonuses, allowances, etc.), conduct withholding procedures, pay residence taxes, and conduct other necessary procedures for paying remuneration
3. To conduct evaluations (including personnel evaluations), determine assignment, decide promotions, transfers, administrative leave, reinstatement, and conduct other necessary procedures for personnel transfers
4. To enable companies to take appropriate measures for health management, safety management, early detection and treatment of illnesses, and other health-related matters so that employees can work while ensuring their health and so that companies can fulfill their duty to consider safety and for employees, etc. to conduct appropriate health management
5. To conduct procedures to transfer employer and for retirement, payment of retirement allowance, post-retirement communications, and other necessary procedures after retirement
6. To conduct procedures necessary for business activities, such as requesting customer introductions, hearing opinions on new products, confirming opinion proposals on business operations, and conducting, tabulating, and using questionnaire surveys, etc., in connection with the promotion of the company's business activities
7. In addition to each of the above, for the company to implement necessary matters in relation to personnel and labor affairs

Article 3 (Management and Protection of Personal Information)

1. The Group strictly manages Employment Management Information and does not disclose or provide data to third parties without the consent of the individual concerned, except in the following cases. In consideration of security, the Group takes measures to prevent and correct risks such as unauthorized access to Employment Management Information, and the loss, destruction, falsification, and leakage of Employment Management Information.
   1. When necessary to protect human life, health or property and when it is difficult to obtain consent from the individual concerned.
   2. When particularly necessary to improve public health or to promote the sound development of children and when it is difficult to obtain consent from the individual concerned
   3. When we need to cooperate with the performance of affairs prescribed in laws and regulations by a government organization or a local government, or a person entrusted by such parties, and when there is a possibility that obtaining consent from the individual concerned will hinder the performance of the affairs.
   4. When we entrust the handling of personal information in whole or in part to a third party to the extent necessary to achieve the purpose of the use in order to ensure the smoother performance of operations
   5. When employment management information is provided in association with business succession caused by a merger or other reason
   6. When otherwise required by laws and regulations
2. The Group shall take appropriate measures, as follows, from the perspective of preventing leaks, losses and falsifications, etc. of health information included in Employment Management Information.
   1. Each company's general manager shall confirm that health information is handled in accordance with a pre-determined method.
   2. Measures shall be taken to prevent theft or loss of information by restricting, etc. the removal of documents that contain health information (including electromagnetic recording media).
   3. Measures shall be taken to prevent information leaks, etc. by restricting access, managing passwords and preventing unauthorized access from outside, etc. with regard to information systems that handle health information that fall under the category of systematized and searchable personal data.
   4. When outsourcing the handling of health information, necessary and appropriate supervision of the contractor shall be conducted to ensure that the contractor takes appropriate security control measures for the health information concerned.

Article 4 (Shared Use)

The Group's Employment Management Information may be shared with the Group as follows.

Items of personal data to be shared:

Name, company name, affiliation, position, mobile telephone number, e-mail address, date of birth, and other general attribute information, as well as information necessary for personnel and labor management, such as wages, work status, and benefits

Scope of shared users

The Group

Purpose of use by users

For internal business communications, employee recruitment, and personnel and labor management

Article 5 (Outsourcing the Handling of Information)

The Group may outsource the handling of personal information that contains Employment Management Information in whole or in part, to the extent necessary to achieve the purpose of use. In such cases, the Group undertakes thorough screening for eligibility as a contractor, stipulates confidentiality obligations in contracts, and provides necessary and appropriate supervision to contractors.

Article 6 (Disclosure of Personal Information)

Upon request from the individual concerned to disclose their personal information under the Personal Information Protection Act, the Group shall, without delay, disclose such information to the individual concerned after confirming their identity (or notify the individual concerned of the non-existence of such personal information); provided, however, that this shall not apply when the Group does not assume the obligation to disclose pursuant to the Personal Information Protection Act and other applicable laws and regulations. Note that a fee that takes into consideration actual costs, will be charged for the disclosure of personal information.

Article 7 (Correction and Suspension of Use, etc. of Personal Information)

1. If a request pursuant to the provisions of the Personal Information Protection Act is received from an individual concerned to correct the content of Employment Management Information that falls under "personal information" defined in the Personal Information Protection Act, on the grounds that such information is untrue, the Group shall, except in cases in which special procedures have been prescribed in accordance with the provisions of other laws and regulations, conduct the necessary investigation, without delay, after confirming that the request is from the individual concerned or originated from the individual concerned, and shall correct the content or suspend use of the personal information based on the results of the investigation, and shall notify the individual concerned to that effect.
2. If a request is received from an individual concerned to suspend use or delete (hereinafter referred to as "Suspend Use, etc.") Employment Management Information that falls under "personal information" defined in the Personal Information Protection Act, on the grounds that the information has been handled beyond the scope of the publicized purpose of use or on the grounds that the information was acquired through wrongful means, the Group shall conduct the necessary investigation, without delay, and shall Suspend Use, etc. of the personal information based on the results of the investigation, and shall notify the individual concerned to that effect; provided, however, that if Suspending Use, etc. of personal information involves enormous expense or if Suspending Use, etc. is otherwise difficult, and if necessary alternative measures can be taken to protect the rights and interests of the individual concerned, the Group shall take such alternative measures.

Article 8 (Procedure to Amend this Privacy Policy)

The Group shall review and improve this Policy from time to time. The details in this Policy may be changed, except as otherwise provided by laws, regulations or otherwise in this Policy. The revised Privacy Policy shall become effective when posted on the Group's website in a prescribed manner.

Article 9 (Inquiries Hotline)

If you have any comments, questions or complaints regarding this Policy, or other inquiries regarding the handling of personal information, please contact your company's Personal Information Inquiries Hotline or the following inquiries hotline.