NTT COMWARE English Site



Privacy Policy

The Handling of Personal Information at NTT COMWARE

NTT COMWARE CORPORATION (hereinafter "NTT COMWARE") understands that protecting customers' personal information, including individual numbers and specific personal information, and handling it appropriately is a basic part of its business activities and it has a duty to society to do so.

NTT COMWARE has established the Personal Information Protection Policy described in detail below. In accordance with this policy, NTT COMWARE recognizes the importance of personal information, including individual numbers and specific personal information, and conducts personal information protection activities across the company.

NTT COMWARE's Personal Information Protection Policy

NTT COMWARE CORPORATION (hereinafter "NTT COMWARE") recognizes the importance of properly using personal information in today's advanced information society and declares that it will properly handle personal information, including individual numbers and specific personal information, in accordance with the following policy.

1. Compliance with Laws and Regulations

NTT COMWARE acts in accordance with the Act on the Protection of Personal Information, the Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures, Personal information protection management systems - Requirements (JISQ 15001) and other regulations. The other regulations include the Guidelines for the Act on the Protection of Personal Information and the Guidelines for Proper Handling of Specific Personal Information (for Business Operators).

2. Establishment and Continued Improvement of Personal Information ProtecManagement System

For the purpose of properly handling all of the personal information it handles, NTT COMWARE has established and implemented a personal information management system that complies with the NTT Group Information Security Policy, and it will maintain and continuously improve this system.

3. Proper Management of Personal Information

NTT COMWARE properly manages personal information as follows.

  1. Prior to the acquisition of personal information, NTT COMWARE clarifies the purposes of use of the personal information. NTT COMWARE acquires personal information by lawful and fair means and uses the personal information collected to the extent necessary to fulfill the stated purposes.
  2. NTT COMWARE will in principle not provide personal information to any third party without the consent of the person to whom the information pertains, except where the provision of the information is required by laws and regulations.
  3. NTT COMWARE respects that the people to whom the information pertains have the right to request that they be notified of the purposes of use of their personal information, that the information be disclosed to them, that the information be corrected, added to or cancelled, that the use of the information be stopped, that the information be deleted and that the disclosure of the information to third parties be stopped, and NTT COMWARE will swiftly respond to any such request.
  4. NTT COMWARE will swiftly and sincerely respond to any complaint or inquiry submitted in connection with the handling of personal information.
4.Implementation of Security Control Actions

NTT COMWARE takes the security control actions required by laws and regulations and those which fulfills the standards required for Privacy Mark registration and for the ISO/IEC 27001 certification of its information security management system and properly monitors its security, including actions involving its contractors.

  1. Organizational security control actions and human security control actions
    NTT COMWARE has appointed a personal information protection management representative. Under them, a security implementation management representative is appointed at each organization to properly manage personal information. NTT COMWARE provides training on methods for protecting and properly managing personal information to its officers, employees and other personnel to increase their awareness of the importance of these actions and to make sure that personal information protection activities are conducted.
  2. Technological security control actions
    NTT COMWARE controls access to personal information, implements protective measures to prevent unauthorized access and uses software to keep personal information accurate and protect it from leakage, loss, destruction or the like.
  3. Physical security control actions
    NTT COMWARE implements a range of measures including entry and exit control of buildings and floors where personal information is handled, protection from fire, lightning and the like and the prevention of loss, theft and equivalents when personal information is taken out of secure areas, transferred and stored.
  4. Understanding of the external environment
    When personal information is stored or handled outside Japan, NTT COMWARE understands the systems for the publication of information and for the production of personal information in countries where personal information is stored or handled to implement security control actions.

Established on February 15, 1999
Revised on March 9, 2022
NTT Shinagawa Twins Annex Building 1-9-1 Minato-ku, Tokyo

Masato Kuroiwa
President
President, Executive Officer
NTT COMWARE CORPORATION

Privacy Mark JUSE ISMS

Effected Areas:
Comprehensive services including the strategic planning, development, design, building, maintenance and operation of information communication systems

The Handling of Personal Information (Excluding Individual Numbers and Specific Personal Information)

1. Purposes of Use of Personal Information
(1) Customer personal information

NTT COMWARE uses the personal information it possesses for the following purposes.

  • To provide NTT COMWARE services and products, as well as related information, to conduct billing, to send notices of different changes, to send questionnaires and to answer inquiries
  • To develop, operate, maintain and improve different services and products
  • To collect feedback on NTT COMWARE research and other areas for incorporating it into future research and development, and future group operations
  • To conduct customer satisfaction surveys and market surveys
  • To administer the security of buildings and other areas which NTT COMWARE is responsible for managing
(2) Partner company employee personal information

In connection with outsourcing, NTT COMWARE may collect information about the employees of partner companies, i.e. temporary personnel staffing agencies and other companies under contract, either from the partner companies or from the employees themselves. NTT COMWARE uses partner company employee personal information to manage and supervise contractors involved in outsourcing and for the other purposes specified below.

  • To check the conclusion and implementation of contracts with partner companies
  • To give instructions to partner company employees and to manage their work and services
  • To check the skills possessed by partner company technicians
  • To manage the security of buildings and other facilities
  • To use the information in the implementation of measures to protect confidential information and other information
  • To implement NTT COMWARE's security measures
(3) Customers' personal information received in connection with commissioned services

NTT COMWARE uses the personal information it receives in connection with services commissioned to it for the following purposes.

  • NTT COMWARE uses the personal information received to perform the different support services requested by customers in its business.
  • NTT COMWARE uses the personal information received solely for fulfilling the terms of contracts and for performing commissioned services. NTT COMWARE may also provide personal information that it has received to its subcontractors or partners to perform the different support services that are requested.
2. Non-Provision of personal information to third parties

NTT COMWARE will not provide personal information it possesses to any third party without the prior consent of the person to whom the information pertains except:

  • When the provision of the information is mandatory under any law or regulation
  • When the provision of the information is necessary to protect a person's life, body or property and it is difficult to obtain the consent of the the person to whom the information pertains
  • When it is necessary to provide the information to improve public hygiene or the sound development of children and it is difficult to obtain the consent of the person to whom the information pertains
  • When any national government agency, local governing body or organization under contract with a national government agency or local governing body requires that NTT COMWARE cooperate in the carrying out of work stipulated by any law or regulation, and when there is a concern that obtaining the consent of the person to whom the information pertains may jeopardize the success of the work in question
  • When NTT COMWARE is considered an academic research institution and the provision of personal information is a necessary part of presenting academic research achievements or teaching about them (excluding cases where the provision of the information brings with it the risk of unreasonably infringing on the rights and interests of any individual)
  • When NTT COMWARE is considered an academic research institution and it needs to provide the personal information for academic research purposes (including cases where the academic research purposes constitute part of the purposes of providing the personal information and excluding cases where the provision of the information brings with it the risk of unreasonably infringing on the rights and interests of any individual) (This apples solely to joint academic research between the operator handling the personal information and a third party)
  • When NTT COMWARE provides personal information to any academic research institution or the like and where the institution needs to handle the personal information for academic research purposes (including cases where the academic research purposes constitute part of the purposes of providing the personal information and excluding cases where the provision of the information brings with it the risk of unreasonably infringing on the rights and interests of any individual).
3. Matters Concerning Joint Use of Personal Information and Pseudonymized Information

NTT COMWARE may jointly use personal information and pseudonymized information it possesses with specific parties. In this event, NTT COMWARE will give prior notice to customers or publish in advance the matters specified below.

  • Items of personal information that will be jointly used
  • Scope of the parties joint using the personal information
  • Purposes of use
  • Name and address of the person or the party responsible for managing the jointly used personal information or the name of the representative of the party, if it is a corporation
  • Method of acquisition
4. Outsourcing of Handling of Personal Information and Pseudonymized Information

NTT COMWARE may outsource the handling of personal information it possesses to fulfill the purposes of use stipulated in section 1.

5. Anonymized Information

NTT COMWARE may create anonymized information from personal information and provide it to third parties.

In this event, NTT COMWARE will publish the following on its website or by other means.

  • Information items concerning individuals contained in the anonymized information created by NTT COMWARE
  • Information items concerning individuals contained in the anonymized information provided to third parties
  • Methods of providing the anonymized information to third parties
  • Details of the security control actions implemented

NTT COMWARE conducts the necessary and appropriate supervision of employees and contractors handling anonymized information, including their subcontractors and equivalents, regarding their handling of anonymized information.

6. Pseudonymized Information

NTT COMWARE may create pseudonymized information from personal information it possesses to fulfill the purposes of use specified in section 1. If pseudonymized information will be used beyond the scope of its purposes of use, NTT COMWARE will make an announcement on its website or by other means.

7. Person-Related Information

NTT COMWARE will handle person-related information (information relating to any living individual that is not considered personal information, pseudonymized information or anonymized information, specifically including website view records and positional information) in the following manners.

(1) NTT COMWARE's provision of person-related information

When the third party to whom person-related information is provided is presumed to be acquiring the person-related information as personal data, NTT COMWARE will not offer person-related information to the third party without confirming that the prior consent of the customer has been obtained (including, when the third party is located outside Japan, the name of the country where the third party is located and the measures relating to the protection of personal information that are implemented, the measures taken by the third party to protect personal information and other information helpful to the person to whom the information pertains being provided to that person), except when the exceptions in section 2 apply.

(2) NTT COMWARE's acquisition of person-related information as personal data

NTT COMWARE will seek to obtain the prior consent of the customer when obtaining person-related information as personal data. However, when the party offering the person-related information has already obtained the consent of the customer, NTT COMWARE may substitute this consent for itself obtaining the prior consent of the customer.

8. Provision of Personal Information or Person-Related Information to Third Parties Outside Japan

NTT COMWARE may provide personal information or person-related information to third parties in foreign countries (except foreign countries whose system for the protection of personal information is considered to equivalent to the system in Japan for the purpose of protecting individuals' rights and interests). When it does so, NTT COMWARE will act as follows.

(1) Obtaining consent

NTT COMWARE will notify the customer of the items specified below to obtain their consent before providing the information to the third party.

  • Name of the country when the receiving party is located
  • System relating to personal information in the country
  • Personal information protection measures to be taken by the receiving third party
(2) Establishment of systems by third parties outside Japan

NTT COMWARE will take the necessary measures to ensure that the third parties outside Japan continuously implement adequate measures.

9. External Environment

NTT COMWARE may store or handle personal information it possesses outside Japan. If it does so, NTT COMWARE will understand the systems related to the protection of personal information in the individual countries and implement security control measures.

(1) Customer personal information
  • NTT COMWARE may store personal information in the United States of America to provide its services and products and to provide related information. For information about the systems related to the protection of personal information in the United States of America, click here (to go to the Personal Information Protection Committee Japan website).
(2) Partner company employee personal information
  • NTT COMWARE may store and handle a part of the personal information it possesses in the United States of America to implement security measures and use business tools. For information about the systems related to the protection of personal information in the United States of America, click here (to go to the Personal Information Protection Committee Japan website).
10. Inquiries Concerning Personal Information

To request the disclosure or correction of personal information, that its use be stopped, or other matters concerning personal information that is possessed by NTT COMWARE or to inquire about NTT COMWARE's handling of personal information, please contact the contact address below.

Please note that to request the disclosure or correction of personal information, that its use be stopped, or other matters concerning personal information it is required that you submit the request form designated by NTT COMWARE and a document that identifies the applicant as the person to whom the personal information pertains and pay a fee (1,000 yen, including consumption tax, incurred for the disclosure of information) to NTT COMWARE.

Notwithstanding the above, NTT COMWARE may be unable to respond to requests regarding all or part of the personal information related to the request in cases where it deems any of the following apply.

  • There is a deficiency in the application procedures taken by the customer.
  • The personal information related to the request does not exist in the personal information database possessed by NTT COMWARE.
  • The response to the request may harm the life, wellbeing, property or other rights or interests of the customer or of any third party.
  • Information disclosure or other responsive actions may significantly hinder NTT COMWARE's proper performance its business.
  • Information disclosure or other response actions would violate any other law or regulation.

Note: NTT COMWARE will handle the personal information acquired through inquiries regarding personal information to the extent necessary to handle the inquiry.

Personal Information Protection Management Representative: Kousei Watanabe, Executive Officer

Location and Contact Address for Inquiries:
NTT Shinagawa Twins Annex Building 1-9-1 Minato-ku, Tokyo 108-8019
General Affairs, General Affairs and Personnel Department, NTT COMWARE CORPORATION
03-5463-5776
click here to contact us

Name of the certified personal information protection organization and contact address for complaint resolution
■ Name of the certified personal information protection organization
JIPDEC

■ Contact address for complaint resolution
Office of the certified personal information protection organization
Address: Roppongi First Building 1-9-9 Roppongi, Minato-ku, Tokyo 106-0032 Japan
Telephone: 03-5860-7565 / 0120-700-779
Note:
This is not the contact address for inquiries regarding NTT COMWARE's products and services.
For inquiries regarding NTT COMWARE's products and services, see NTT COMWARE's website, https://www.nttcom.co.jp/.

The Handling of Individual Numbers and Specific Personal Information

The individual number and the specific personal information will be hereinafter collectively referred to as "specific personal data."

1. Purposes of Use of Specific Personal Data

NTT COMWARE will use the specific personal data it possesses within the scope specified below.

  • Work related to the preparation of payment records for remuneration, fees, contract money and prize money
  • Work related to the preparation of payment records for real estate usage fees and other fees
  • Work related to the preparation of payment records for compensation for the takeover of real estate and other matters
  • Work related to the preparation of payment records for brokerage commissions for transactions or the leasing of real estate and other matters

If a customer's specific personal data is obtained in writing directly from the customer, NTT COMWARE will expressly state the purposes of use thereof on a case-by-case basis except where any of the items in paragraph (4) of Article 21 of the Act on the Protection of Personal Information applies. However, this will not apply in cases where (i) or (ii) of paragraph (3) of Article 18 in the Act on the Protection of Personal Information as replaced pursuant to the provisions of paragraph (3) of Article 29 of the Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures apply.

2. Provision of Specific Personal Data for Third Parties

NTT COMWARE does not provide specific personal data to third parties. However, in the cases stipulated by any of the items in Article 19 of the Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures, it may provide necessary specific personal data to relevant third parties or receive necessary specific personal data from relevant third parties without obtaining the prior consent of the person to whom the data pertains.

3. Matters Concerning Joint Use of Specific Personal Data

NTT COMWARE does not jointly use specific personal data acquired from customers with any specific party.

4. Outsourcing of Handling of Specific Personal Data

NTT COMWARE may outsource the handling of specific personal data it possesses to fulfill the purposes of use specified in section 1.

5. Inquiries Concerning Specific Personal Data

To request the disclosure or correction of specific personal data, that its use be stopped, or other matters concerning specific personal data that is possessed by NTT COMWARE or to inquire about NTT COMWARE's handling of specific personal data, please contact the address below.

Please note that to request the disclosure or correction of specific personal data, that its use be stopped, or other matters concerning specific personal data it is required that you submit the request form designated by NTT COMWARE and a document that identifies the applicant as the person to whom the specific personal data pertains and pay a fee (1,000 yen, including consumption tax, incurred for the disclosure of information) to NTT COMWARE.

Notwithstanding the above, NTT COMWARE may be unable to respond to requests regarding all or part of the specific personal data related to the request in cases where it deems any of the following apply.

  • There is a deficiency in the application procedures taken by the customer.
  • The specific personal data related to the request does not exist in the specific personal data database possessed by NTT COMWARE.
  • The response to the request may harm the life, wellbeing, property or other rights or interests of the customer or of any third party.
  • Information disclosure or other responsive actions may significantly hinder NTT COMWARE's proper performance its business.
  • Information disclosure or other response actions would violate any other law or regulation.

Note: NTT COMWARE will handle the specific personal data acquired through inquiries regarding specific personal data to the extent necessary to handle the inquiry.

Personal Information Protection Management Representative: Kousei Watanabe, Executive Officer

Location and Contact Address for Inquiries:
NTT Shinagawa Twins Annex Building 1-9-1 Minato-ku, Tokyo 108-8019
General Affairs, General Affairs and Personnel Department, NTT COMWARE CORPORATION
03-5463-5776

click here to contact us

Name of the certified personal information protection organization and contact address for complaint resolution
■ Name of the certified personal information protection organization
JIPDEC

■ Contact address for complaint resolution
Office of the certified personal information protection organization
Address: Roppongi First Building 1-9-9 Roppongi, Minato-ku, Tokyo 106-0032 Japan
Telephone: 03-5860-7565 / 0120-700-779
Note:
This is not the contact address for inquiries regarding NTT COMWARE's products and services.
For inquiries regarding NTT COMWARE's products and services, see NTT COMWARE's website, https://www.nttcom.co.jp/.

The Handling of Personal Information of Retired Employees

Purposes of Use
  1. To respond to inquiries from retired employees
  2. To send information from NTT COMWARE
  3. To manage personnel records (including service, wage and health information) during the period when they were employed by NTT COMWARE
  4. To carry out work for taxes, social insurance and equivalent work
  5. To implement other activities necessary for the management of retired employees associated with the above items

Note: If the personal information of any retired employee is used beyond the scope of the purposes of use above, NTT COMWARE will separately notify the retired employee or announce the intended purposes of use to seek the consent of the retired employee.

Contact Address for Inquiries Regarding Personal Information of Retired Employees of NTT COMWARE

NTT Shinagawa Twins Annex Building 1-9-1 Minato-ku, Tokyo 108-8019

Personnel Affairs, General Affairs and Personnel Department, NTT COMWARE CORPORATION

click here to contact us

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