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Privacy Policy

Handling of Clients' Personal Information

COMSYS Holdings Corporation (hereafter, “the Company”) aims to be the most preferred and valued enterprise by all of its stakeholders. Therefore, to earn the trust of its clients and society, the Company strictly adheres to laws and regulations concerning personal information, and takes the utmost care in managing and protecting such information.

Company Guidelines Concerning Personal Information
  • Personal information shall be acquired in a legal and fair manner, and is not to be obtained through inappropriate methods.
  • Appropriate steps shall be taken to ensure that information security measures are in place, including restricting illegal access to information, in order to prevent the loss, destruction, falsification, or leakage of personal information.
  • All laws and regulations, relevant guidelines, and contract stipulations with clients related to the protection of personal information shall be strictly adhered to. Special attention is given to the full protection of shareholder information received from shareholders and personal information obtained from clients through business operations.
  • When external parties are commissioned to provide transactions and services involving personal information, thoroughgoing management shall be undertaken, including such measures as concluding necessary contracts with those parties and following up to ensure that they are observing relevant rules and stipulations.
  • Efforts to implement, continue and improve relevant training shall be undertaken to ensure that all employees and members of the Company recognize the importance of personal information and handle it appropriately.

Hiroshi Tanabe
President, Representative Director
COMSYS Holdings Corporation

Purpose of Using Clients’ Personal Information

While observing the Personal Information Protection Law of Japan, the Company uses the personal information of its clients for the following reasons: to provide information and proposals to clients regarding business activities performed by the Company or its Group companies; to execute and conclude contracts; to carry out after-service; to contact and correspond with clients; to facilitate the development of new products and services; and to provide information deemed beneficial to clients.

Personal information in the Company’s possession is used for the following reasons:
  1. 1To solicit opinions and feedback from clients
  2. 2To respond to clients’ inquiries and requests for materials
  3. 3To conduct market surveys and facilitate the development of products and surveys
  4. 4To announce various events, seminars, promotions, and membership services
  5. 5To send e-mail services or publications
  6. 6To provide information related to products and services managed by the Company or its business partners
  7. 7To confirm work performed for accounting audit purposes
  8. 8To carry out other matters incidental or relevant to the Company’s business

To ensure the smooth execution of its business, the Company outsources some of its operations, which may involve placing personal information in the custody of third parties to the extent required to conduct these operations. In such cases, the Company undertakes appropriate supervision of this process, including the conclusion of contracts with the commissioned parties concerning the handling the personal information.

Provision of Personal Information to Third Parties

The Company does not provide personal information to commissioned third parties except in the following cases.

  1. 1When prior consent has been given by the client
  2. 2When the purpose for using the personal information is within the scope necessary to accomplish the outsourced operations
  3. 3When the personal information is used in a way that individuals cannot be identified, such as data for statistical purposes
  4. 4When authorities request personal information on the basis of laws and regulations
  5. 5When it is difficult to obtain consent from clients for personal information under circumstances in which it is necessary to protect human life, physical safety, or private property
  6. 6When it is difficult to obtain consent from clients for personal information under circumstances in which it is necessary to maintain public order or protect the well-being of children
  7. 7When concerns exist that attempting to gain consent from clients will pose an obstacle to the execution of work that is necessary to carry out in cooperation with national or local governments that have mandated such work through laws or ordinances

Disclosure, Correction, and Ceased Usage of Personal Information

In the event that a client makes a request to have his or her personal information disclosed, corrected or deleted, the Company will confirm the identity of the person making the request and respond accordingly within a reasonable period of time, as follows.

  1. 1A client’s personal information will be disclosed when he or she requests to see it.
  2. 2A client’s personal information will be corrected, supplemented, or deleted according to his or her request; however, this is only possible when details in the personal information differ from actual facts.
  3. 3A client’s personal information will be deleted or ceased from being used according to his or her request; however, this request may not be possible if the personal information is being held in accordance with laws or regulations.

Basic Policy on the Appropriate Handling of Specific Personal Information

COMSYS Holdings Corporation (the "Company") has established this basic policy to ensure appropriate handling of specific personal information as an organization.

1. Compliance with relevant laws, regulations, and guidelines, etc.

COMSYS will handle specific personal information, etc., appropriately in compliance with the Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures, the Act on the Protection of Personal Information, and the Guidelines for the Proper Handling of Specific Personal Information (for Business Operators).

2. Matters regarding measures for managing the security of personal data

COMSYS stipulates measures for managing the security of specific personal information, etc., separately under the Specific Personal Information Handling Regulations.

3. Contact for questions, etc.

If you have any questions or complaints, regarding the handling of specific personal information, etc. by the Company, please contact the following Inquiry Desk.

Human Resources Department, COMSYS Holdings Corporation
7-1, Higashigotanda 2-chome, Shinagawa-ku, Tokyo, 141-8647
TEL: 03-3448-7061 (weekdays: 09:00-17:30)
E-mail: mynumber_CHD@comsys.co.jp

Scope of our operations that handle individual identification numbers

  1. 1Clerical work to prepare income tax withholding slips, etc.
  2. 2Clerical work relating to notifications concerning health insurance and social pension insurance (including application, benefits, and subsidies)
  3. 3Clerical work relating to notifications concerning employment insurance (including application, benefits, and subsidies)
  4. 4Clerical work relating to notifications concerning employment insurance (including application, benefits, and subsidies)
  5. 5Clerical work relating to claims based on the Industrial Accident Compensation Insurance Act (limited to cases where is acting as an agent)
  6. 6Clerical work relating to notifications concerning Category III insured persons under the National Pension Act
  7. 7Clerical work relating to preparation of property formation savings declaration forms, notification forms, application forms, and statutory reports
  8. 8Clerical work relating to preparation of payment records for remuneration and fees, etc.
  9. 9Clerical work relating to preparation of payment records for dividends, distribution of surplus funds, and interest on funds; payment records for amounts deemed to be dividends, etc.; payment records for grants, etc.; payment records for consideration for transfer of shares, etc.; payment records for consideration for transfer of shares, etc., received by the registered shareholder; payment records for interest, etc.; records for free allocation of shares; and other statutory reports on shares, etc.
  10. 10Clerical work relating to preparation of payment records for real estate transactions, etc.
  11. 11Clerical work relating to corporate pension schemes (limited to tax-related clerical work)
  12. 12Clerical work relating to the Act to Facilitate the Employment of Persons with Disabilities
  13. 13Clerical work relating to the certification of reemployment assistance plans under the Employment Measures Act
  14. 14Clerical work relating to provision of information to insurance companies and mutual aid organizations for the preparation of payment statements for policyholders of life insurance, non-life insurance, and mutual aid insurance
  15. 15Clerical work relating to provision for the preparation of payment statements for each shareholding association, in relation to members of the COMSYS Holdings Board of Directors' Shareholding Association and the Employee Shareholding Association
  16. 16Clerical work relating to the granting of stock options (limited to tax-related work)
  17. 17Delegated clerical work, in cases where the administrator of clerical work using individual identification numbers or clerical worker relating to individual identification numbers has delegated the handling of all or part of the specific personal information

Clerical work associated with the above (including work handling specific personal information)