Joe Jones of Squire Patton Boggs writes:
The Japanese Diet passed amendments to the Personal Information Protection Act on September 3, 2015, which will become effective within the next two years. While further details will be revealed in upcoming implementing regulations, several major changes, which are summarized below, are clear from the text of the statute. Companies doing business in Japan should take a close look at their privacy policies and personal data procedures in preparation for these changes.
More leeway to disclose anonymous data
“Anonymized” personal data – stripped of personal identifiers such as names and dates of birth – may now be transferred to third parties, including companies who would use the data for marketing purposes, without the subject’s consent. The disclosure must still be reported to the “Personal Information Protection Committee” (discussed further below), and must also be publicly announced. This is one of the few “pro-business” changes in the amendment, and will allow companies to use and sell “big data” about their customers, which was previously a gray area in Japanese data privacy law.
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