Privacy

Personal Information Protection Policy

Revised: February 1, 2015
Enacted: October 1, 2003
SB AtWork Corp.
Representative Director, President: Eiji Shimagami

SB AtWork complies with laws and ordinances regarding the protection of rights and personal information of the individual concerned, fully recognizing its social mission regarding the protection of all personal information handled by SB AtWork in conducting contracting/outsourcing service related to human resource administration. In addition, SB AtWork has established a personal information protection management system to realize the following policy and hereby declares its commitment to make companywide efforts to continue improving the system with a constant awareness of the latest trends in IT technology and changes in social demands and business environment, among other things.

  • 1.SB AtWork shall ensure that personal information is fairly and lawfully obtained, used and provided only for executing its service, hiring employees, and administering human resources, and that personal information is handled only within the scope required for achieving the specified purpose of use. SB AtWork shall take measures to ensure that such information is not used for other purposes.
  • 2.SB AtWork shall comply with laws, ordinances, national guidelines and regulations regarding personal information protection.
  • 3.Regarding risks such as leakage and damage of personal information, SB AtWork shall take reasonable security measures to prevent such accidents and shall continuously improve the personal information security system by investing business resources according to the actual conditions of its service. Furthermore, if anything goes wrong, SB AtWork shall promptly take corrective measures.
  • 4.SB AtWork shall promptly and appropriately respond in good faith to any complaints and inquiries concerning the handling of personal information.
  • 5.SB AtWork shall continue to improve the personal information protection management system by properly reviewing it in a timely manner in view of changes in the environment surrounding SB AtWork.

SB AtWork shall disseminate this policy to all employees and ensure that they thoroughly understand this policy and shall take measures to make this policy available to anyone at all times by posting it on the company website, for example.

Privacy

Name of business operator

SB AtWork Corp.

Name or job title of administrator (or representative), his or her department and contact information

Name of administrator: Person in charge of administration of personal information protection Tsuneo Misawa
Job title: Director, COO & CISO
Contact information: Telephone 03-6889-2700

Purpose of Use of Personal Information

  • 1.Matters to be put in accessible conditions for the individual related to retained personal data in the event that personal information is obtained from the individual concerned in writing, etc. (Including from the website or by e-mail. Hereinafter referred to as “in writing”) (Article 24 of the Act on the Protection of Personal Information (hereinafter referred to as “the Act”))

    Category Purpose of Use
    Customer information Outsourcing service related to human resource administration
    Notification of information pertaining to services of safety and health management outsourcing service
    Provision of fringe benefit service
    Utilization of analysis and results of analysis for improving fringe benefit service
    Shareholder information Notification service
    Business partner information Order receiving/placing service
    Claim/payment service
    Employee information Labor management
    Temporary staffer contract management
    Provision of fringe benefit service
    Utilization of analysis and results of analysis for improving fringe benefit service
  • 2.Purpose of use in the event that personal information is directly obtained other than in writing from the individual concerned

    Category Purpose of Use
    Customer information Outsourcing service related to human resource administration
    Notification of information pertaining to services of safety and health management outsourcing service
    Employee information Provision of fringe benefit service
    Utilization of analysis and results of analysis for improving fringe benefit service
  • 3.Purpose of use in the event that personal information is indirectly obtained (Article 18, Paragraph 1 of the Act)

    Category Purpose of Use
    Customer information Outsourcing service related to human resource administration
    Safety and health management outsourcing service
    Employee information Provision of fringe benefit service
    Utilization of analysis and results of analysis for improving fringe benefit service

Matters pertaining to cases where personal information is to be provided to third parties

SB AtWork shall not provide personal information to third parties except in the following cases.

  • When the customer’s consent has been obtained
  • When it is required by laws and ordinances

Outsourcing of personal information handling

SB AtWork outsources the performance of some of its services to outside contractors in order to provide better services to customers. SB AtWork may provide personal information to the service outsourcing agent. In that case, SB AtWork selects an outsourcing agent deemed to be handling personal information appropriately and takes the necessary measures to prevent the leakage of personal information of customers such as by including in agreements provisions for appropriate management of personal information and obligation of confidentiality, and implement proper management.

Disclosure, correction/deletion, and right to refuse use or provision of personal information

Personal information that is subject to disclosure refers to personal information comprising a collection of information systematically organized for which SB AtWork has the right to respond to all requests by the individual concerned for disclosure, correction of information content, addition or deletion, discontinuation of use, erasure and discontinuation of provision to a third party.

  • (1) Disclosure of personal information that is subject to disclosure

    SB AtWork shall disclose personal information that is subject to disclosure to the individual concerned without delay when it is requested by the individual concerned to disclose such personal information. SB AtWork shall also notify the individual concerned when personally identifiable personal information does not exist.

    • a) When there is a risk of harm to the life, body, property or other rights or interests of the individual concerned or a third party
    • b) When there is a risk of material impediment to the proper execution of business of the concerned business operator
    • c) When it violates laws and ordinances
    (2) Correction, addition or deletion of personal information that is subject to disclosure

    When SB AtWork is requested to correct, add or delete personal information that is subject to disclosure on the grounds that the details are false as a result of disclosure, SB AtWork shall conduct the necessary investigation without delay and correct, etc. the personal information that is subject to disclosure based on such results, as well as notify the individual concerned thereof without delay (including the contents of correction, etc.) after making corrections, etc.

    (3) Right to refuse use or provision of personal information that is subject to disclosure

    When SB AtWork is requested by the individual concerned to discontinue the use, erase or discontinue provision to a third party of personal information that is subject to disclosure, SB AtWork shall respond to such request. SB AtWork shall also notify the individual concerned without delay after taking such measures. However, when any of the circumstances mentioned in the proviso in a) to c) of (1) applies, SB AtWork is unable to respond to such request, and in that case, shall notify the individual concerned to that effect and shall explain the reason without delay.

    (4) Notification of purpose of use, disclosure, correction of content, addition or deletion, discontinuation of use, erasure

    When the customer or job seeker requests notification of the purpose of use, disclosure, correction of the content, addition or deletion, discontinuation of use, and erasure, among other things, of personal information of the individual concerned obtained by SB AtWork, the customer or job seeker is required to make such request by mail to the following Personal Information Complaint and Consultation Counter after attaching identification documents in the prescribed form.
    Since the prescribed form will be sent to you by mail, please request the Personal Information Complaint and Consultation Counter by e-mail, telephone or mail.

Voluntariness of provision of personal information

Whether or not the customer provides personal information to SB AtWork is voluntary. However, if SB AtWork does not receive the necessary information, it may not be able to appropriately provide certain services.

Obtaining personal information by means that are difficult to recognize by the individual concerned

Cookies are used to enable the customer to view SB AtWork’s website more conveniently when the customer revisits the website. Cookies do not violate the customer’s privacy and do not have adverse effects on the customer’s computer.

All personal information input in SB AtWork’s website is encrypted using SSL (Secure Sockets Layer) technology. In addition, measures are taken to protect information within the website, including the installation of a firewall. However, it should be noted that security cannot be guaranteed completely due to the nature of Internet communication.

Basic Policy on the Proper Handling of Specific Personal Information

Enacted: October 1, 2015
SB AtWork Corp.
Representative Director, President: Eiji Shimagami

In an effort to ensure the proper handling of specific personal information, etc. on a companywide basis, SB AtWork has formulated this basic policy.

Name of business operator

SB AtWork Corp.

Compliance with relevant laws and ordinances and guidelines

SB AtWork shall properly handle specific personal information by complying with the Act on the Use of Numbers to Identify a Specific Individual in the Administrative Procedure, the Act on the Protection of Personal Information, and the Guidelines for Proper Handling of Specific Personal Information (for business operators).

Matters concerning security control measures

SB AtWork has separately formulated Rules for the Handling of Specific Personal Information as a security control measure for specific personal information.

Privacy Policy for Recruitment

Scope of personal information

“Personal information” in this policy means information which can identify a specific individual provided either directly by the job applicant who applied to SB AtWork in SB AtWork’s recruitment activities by telecommunication, floppy disk, printed material, magneto-optical disk, regardless of the medium or means, or indirectly by the staffing agency, temp-staff agency or other agencies. Specifically, it refers to the following information.

  • Entry of name, age, gender, date of birth, telephone number, e-mail address, professional career and other information
  • Call history between SB AtWork and the job applicant for purpose of mailing, e-mail and other recruitment activities
  • Information other than the foregoing that can be easily matched with other information and therefore leads to the identification of specific individuals

Non-use other than for the intended purpose

SB AtWork shall use the obtained personal information only for the purpose of SB AtWork’s recruitment activities and appropriate employment management after recruitment, regardless of the channel by which such information was obtained, including online and offline channels. SB AtWork shall not use the obtained personal information for any other purposes.

Matters concerning security control measures

SB AtWork takes the following appropriate security control measures on the organizational, personnel, physical and technical fronts for the purpose of preventing risks such as unauthorized access, loss, alteration and leakage by understanding the risks of personal information held and keeping such information accurate and up-to-date.

  • Organizational security control measures

    SB AtWork has established the Privacy Policy for Recruitment and strives to ensure thorough compliance with this policy.
    SB AtWork has appointed a Chief Privacy Officer to ensure management and supervision.
    SB AtWork has appointed a Chief Privacy Officer to ensure management and supervision.

  • Personnel security control measures

    SB AtWork conducts education and training of employees based on this policy in order to share the latest information on personal information protection activities, make them aware of the importance of the responsibility thereof, and familiarize them with concrete personal information protection measures.

    SB AtWork concludes nondisclosure agreements with employees at the time of their recruitment or at the time of conclusion of the outsourcing agreement.

  • Physical security control measures

    SB AtWork has installed an authentication system for floor entry/exit to manage the entry and exit log. The lockable cabinet is designated as the storage place for personal information, and storage is carried out after the administrator is clearly identified.

    Information systems, equipment and facilities that handle personal information are installed in physically compartmentalized areas, and entry/exit management is conducted by means of an authentication system.
    Printing resume and other information containing personal information for any purpose other than backup is prohibited.
    Making copies of resume and other information containing personal information for any purpose other than backup is prohibited.
    Files are required to be encrypted when personal information is provided by e-mail from the staffing agency or the temp-staff agency.

  • Technical security control measures

    Staff who are allowed access to personal information are limited on the system to monitor and manage the information access log.
    Considering the vulnerability of the Internet, sending personal information by e-mail is prohibited in principle. If sending such information by e-mail cannot be avoided, e-mail is sent by protecting it with a password.

Non-provision to a third party

SB AtWork shall not disclose the obtained personal information to a third party except in the following cases.

  • When the prior consent of the individual concerned has been obtained
  • When provision of personal information is requested by legal bodies such as the police, prosecutor and court
  • When it is required by laws and ordinances
  • When provision of personal information is necessary for the protection of the life, body or property of a person and it is difficult to obtain the consent of the individual concerned

Disclosure, correction or deletion of personal information

SB AtWork works to always keep the obtained personal information accurate and up-to-date. When the disclosure, correction or deletion of personal information is requested, the response is determined according to the following categories after strict identity verification.

  • Personal information of those in the middle of recruitment activities
    SB AtWork shall agree to disclose, correct or delete personal information to a reasonable extent as requested by the individual concerned. However, SB AtWork shall not agree to disclose information pertaining to decisions on hiring since the disclosure thereof may have be a material impediment to the proper implementation of business.
  • Personal information of those hired
    SB AtWork shall manage and maintain such information within the scope of employment management after their employment.
  • Personal information of those who were not hired
    SB AtWork shall destroy and delete such information by an appropriate method after two months from the completion of recruitment activities.

Information Desk

Inquiries concerning the handling of customer’s personal information and specific personal information are accepted at the following desk. Inquiries concerning SB AtWork’s business operations are not accepted at the following e-mail address.

Address
Shiodome Sumitomo Building 1-9-2 Higashi-shimbashi, Minato-ku, Tokyo 105-0021
SB AtWork Corp. Personal Information Complaint and Consultation Desk
E-mail address aw-contact@aw.softbank.co.jp
TEL 03-6889-2700 (business hours: 9:00-17:30*)

*We respond to inquiries received during weekends, holidays, at the year-end and New Year, and Golden Week on or after the following business day.