Funai Soken Holdings Inc.

Privacy Policy

Policy on Protection of Personal Information

  • The Company may acquire and use personal information limited to the extent required in relation to business activities or related processes conducted by the Company or a Group company. Furthermore, the use of personal information shall not exceed the purpose of use previously disclosed in provisions on disclosure.
  • Excluding when mandated by law, the Company shall not provide or disclose personal information to any third party without the consent of the individual.
  • The Company complies with laws concerning the handling of personal information and guidelines and other provisions outlined by the government.
  • The Company implements practical safety measures and corrective measures to prevent various risks, including unauthorized access to personal information, or personal information losses, leaks, modification, or damage.
  • The Company will respond rapidly via the following inquiry desk to requests from individuals for the confirmation, disclosure, correction, deletion, or suspension of use of personal information of that individual, as well as complaints related to personal information.
  • The Company shall establish a personal information protection management system for protecting personal information and work daily to make continuous improvements.
  • The Company shall establish internal provisions concerning the appropriate acquisition, management, and provision of personal information and build an internal structure for the appropriate management and protection of personal information. Furthermore, the Company shall conduct employee education concerning these internal provisions and systems.

Created: November 10, 2004
Latest revision: June 15, 2021

Funai Soken Holdings Inc.
Takayuki Nakatani, President and CEO
[Inquiries concerning the confirmation, disclosure, correction, deletion, or suspension of use of personal information]
Funai Consulting Inc. Customer Information Management Unit
Telephone: +81-6-6204-4666
[Inquiries concerning the handling of personal information]
Funai Soken Holdings Inc. Risk Management Department, Legal Team
Mail: [email protected]

Rules on Use of Personal Information

To ensure solid protection of privacy, we have instituted and publish a set of Rules on Use of Personal Information. Those rules are set forth below. Unless otherwise stated, the language used in the Rules on Use of Personal Information is in accordance with the Act on the Protection of Personal Information.

I. Purpose of Using Personal Information

Our use of personal information extends only to the scope of the purposes set forth below, except where:

  • Permission is received from the principal to use it for other purposes.
  • Exceptions are permitted under the Act on the Protection of Personal Information or other laws

We also use personal information obtained from sources such as the browsing histories and action histories of visitors to our website, usage histories of those who use our services, and questionnaire responses, to determine the kinds of functions and services people are interested in, and based on the findings, to place advertisements, develop services, and otherwise make use of the information within the scope of the purposes set forth below. (This includes usage after comparing browsing histories and other information received from Funai Soken Consulting Group companies other than Funai Soken Holdings and other third parties with personal information we already hold.)

  • Administrative purposes relating to company business (e.g., sending out necessary documentation, other necessary contact, work administration entries)
  • Seeking feedback regarding matters such as the business activities of Funai Soken Holdings or other Funai Soken Consulting Group companies
  • Responding to, and otherwise efficiently processing, inquiries submitted to Funai Soken Holdings or other Funai Soken Consulting Group companies
  • Administration of contracts, exercise of rights, or preservation of the legitimate interests of Funai Soken Holdings or other Funai Soken Consulting Group companies
  • Making improvements to the work of Funai Soken Holdings or other Funai Soken Consulting Group companies
  • Seeking clients’ opinions on a range of topics
  • Providing information to, and making contact with, people applying for employment at Funai Soken Holdings or other Funai Soken Consulting Group companies, and otherwise engaging in candidate screening activities
  • Personnel and labor management and other work-related administration pertaining to current Funai Soken Holdings or other Funai Soken Consulting Group company employees
  • Contact with former employees of Funai Soken Holdings or other Funai Soken Consulting Group companies as necessary regarding work, social activities, or other matters; obtaining information from them relating to their career history at Funai, duties, or duration at the company, or relating to safety management; or other matters relevant to former-employee management
  • Exercising of rights and performance of obligations stipulated by Funai Soken Holdings and shareholders in accordance with law
  • Shareholder management relating to shareholders of Funai Soken Holdings or other Funai Soken Consulting Group companies
  • Outsourcing some tasks within the necessary scope to achieve the above-listed purposes (i.e., outsourcing of services necessary for, or beneficial to, the performance of the company’s business)

We will disclose these purposes to people from whom we obtain personal information contained in documents filled out in the course of entering into contracts.

II. Obtaining Personal Information

We will acquire personal information by fair and lawful means within the necessary scope to achieve the purposes set forth in I. above. When collecting special care-required personal information (as defined in the Act on the Protection of Personal Information), we will observe the regulations stipulated by the act.

III. Sharing Personal Data with Third Parties

We will administer personal data properly, and will not provide personal data to any third party without prior agreement of the principal, except in the circumstances set forth below.

  • When doing so in accordance with the law
  • When there is a need to disclose or supply the personal data in order to protect life, physical wellbeing, or property, and it is impossible to obtain the principal’s approval
  • When there is a particular need to disclose or supply the personal data in order to uphold public health or promote the healthy development of children, and it is impossible to obtain the principal’s approval
  • When we are required to cooperate with procedures carried out by a national or local public body, or by a subcontractor thereof, and obtaining principals’ approval to disclose or supply their personal data would hinder the performance of such procedures
  • When the third party is an academic research
    institution and needs the personal data for its research purposes (includes cases in which academic research is only part of the purpose for handling the personal data, and excludes cases in which there is a risk of unfair infringement of an individual’s rights and interests
  • When stipulated by law
  • When the personal data is shared in conjunction with the outsourcing of all or some of our handling of personal data within the necessary scope to achieve the purposes of use
  • When the personal data is shared with a specific partner for joint use, and we notify the principals of such joint use and of:
    1. ➤The items of personal data subject to joint use
    2. ➤The scope of persons who will jointly use the personal data
    3. ➤The purposes for using the personal data of the participants in the joint-use
    4. ➤The name or title of those responsible for managing the personal data
    5. or we other otherwise make such information easily available to the principals.

IV. Entrusting Personal Data

We may provide personal data to third parties as part of our outsourcing of some tasks within the necessary scope to achieve the purposes set forth in I. above (e.g., partial outsourcing of consulting work or other tasks we undertake; outsourcing of services necessary for, or beneficial to, the performance of such tasks; outsourcing to ad production companies; and outsourcing to database builders). When entrusting personal data, we will conduct a thorough inspection of the trustee to ascertain that they have a sufficient framework in place for personal information protection, and will, in accordance with law, endeavor to prevent incidents by carrying out necessary and proper oversight through contracts, etc.

V. Joint Use of Personal Data

We at the Funai Soken Consulting Group seek to meet the diverse needs of a wide variety of clients not only through our core consulting services, but also by expanding our repertoire to cover peripheral areas so as to offer higher quality solutions.
To that end, personal data of clients, employees, and job applicants may be shared among group companies within the necessary scope to ensure work is performed smoothly and efficiently, to make credit decisions and ensure appropriate management of risk after making such decisions.
Notwithstanding the foregoing, when sharing personal data with third parties overseas, we will observe the stipulations of Article 28 of the Act on the Protection of Personal Information.

1. Personal Data Subject to Joint Use

  1. (1) The following attribute information pertaining to clients and/or business partners, and other information needed for their administration:
    Personal name, company name, business performance, tradename, personal address, company address, professional title, telephone number, fax number, website URL, business category, email address, chat service contact ID
  2. (2) Employee information
    Name, date of hiring, birth date, gender, education, address, assigned department, title, mobile phone number, email address, chat service ID, ID photo, career history at Funai
  3. (3) Job applicant information
    Name, address, birth date, gender, education, telephone number, email address, chat service ID, ID photo, motivation for applying for work with Funai, aptitude test results, resumé contents.

2. Joint-Use Partners

Group companies listed on the Funai Soken Holdings website.

3. Purpose of Joint Use

  1. (1) Purposes of joint use of client and/or business partner attribute information
    • Market research and data analysis for developing and researching new products and services
    • Direct mail and other notices regarding product and services
    • Fielding inquiries, requests for use, and other applications from clients regarding Funai Soken Consulting Group products and services, and relaying these to the pertinent group company
    • Otherwise ensuring proper, efficient interaction with clients
  2. (2) Purposes of joint use of employee information
    • Contacting employees about work matters
    • Employment and personnel administration, assignments (including secondments and transfers)
    • Maintaining an overview of the group’s human resources, assigning tasks
    • Maintaining appropriate working environments and improving labor efficiency
  3. (3) Purposes of joint use of job applicant information
    • Deliberating on applications, making hiring decisions, deliberating on and deciding hiring criteria, handling inquiries, and contact regarding administrative matters

4. Responsibility for Administration of Joint Use

Funai Soken Holdings Inc. Risk Management Department, Legal Team

5. Method of Acquiring Personal Data

Documents (business cards, business documents, questionnaires), electronic data (email, fill-in forms on relevant websites), by telephone, in person, recordings of meeting proceedings

VI. Personal Data Security Control Action

We have security control actions in place as necessary and appropriate to prevent personal data from being leaked, lost, or damaged. We also exercise necessary and appropriate supervision over employees who handle personal data.

(1) In-house Regulations
  1. ・In-house regulations set forth the obligations of those who carry out and those who are in responsible for personal data at all stages of its handling, including obtaining, use, storage, supply, and deletion or discarding
(2) Organization-wide Security Control Action
  1. ・In addition to establishing the position of Personal Data Officer, we have clearly defined which employees can handle personal data and the scope of personal data they can handle, and have established a framework for reporting and contact when a breach (or precursor of a breach) of the Act on the Protection of Personal Information, other law, or in-house regulations arises.
  2. ・We conduct regular inspections of personal data handling, through self-inspection and internal oversight.
(3) Personal Security Control Action
  1. ・Employees undergo regular training, and our employment regulations also cover nondisclosure issues.
(4) Physical Security Control Action
  1. ・In addition to regulation of employee access to offices and regulation of use of devices, we have measures in place to prevent unauthorized people from viewing personal data. When pertinent devices or electronic media are to be removed from company premises, password protection and other measures are taken to prevent the theft or loss of personal data.
(5) Technical Security Control Action
  1. ・Access restrictions are in place to limit the scope of people that handle personal data in accordance with employees’ level of responsibility.
  2. ・Security measures are in place to prevent unauthorized external access.
(6) Ensuring a Secure Environment Overseas
  1. ・If personal data is to be handled overseas, we first ascertain the pertinent country’s laws governing privacy and personal information, and implement necessary security control actions.

VII. Security Control Action Relating to Anonymously Processed Information

When providing databases of anonymously processed information for business use, we implement the following measures to ensure the security of the anonymously processed information.

(1) Restriction of Access
  1. Authorization to access anonymously processed information databases is limited to operators directly involved in the pertinent business, and is strictly overseen and supervised by the head of the relevant department.
(2) Monitoring of Handling
  1. We monitor the handling of anonymously processed information, and evaluate and review security control actions as appropriate.
(3) Prevention of Unauthorized Access
  1. We have appropriate security measures in place to prevent unauthorized external access to anonymously processed information databases.

VIII. Cookies

  1. (1) We place cookies on the devices of visitors to website we operate, and draw information from those cookies.
    NB:We use Google Analytics to study the way people visit our websites. Using the cookies we place on visitors’ devices, Google collects, records, and analyzes visitors’ browsing histories on our websites, and we receive analysis reports from Google. Data collected, recorded, and analyzed by Google Analytics includes no data whatsoever that can identify an individual. These data are administered by Google in accordance with its privacy policy. For more on Google Analytics’ terms of use, see the Google Analytics website; for more on Google’s privacy policy, see Google’s website.
  2. (2) We allow third-party advertisers and access-analysis service providers to place cookies on the devices of visitors to website we operate, and to draw information from those cookies. In these cases, use of those third-party cookies is governed by the pertinent third parties’ own privacy policies, cookie policies, and other regulations.

IX. Procedures for Requesting Disclosure, Correction, Cessation of Use etc., of Personal Data

We respond to requests—either from the principal or a proxy—for requesting disclosure and other actions relating to personal data in accordance with procedures prescribed by law. The procedures are as described below.

(1) Submitting Requests
  1. Funai Consulting Inc. Customer Information Management Unit
    Telephone: +81-6-6204-4666
(2) Sending Documents, Request Forms, etc.
  1. To request disclosure, correction, cessation of use, etc., of your personal information we hold, you must submit a Personal Information Disclosure, Correction, Cessation of Use, etc., Request Form. Forms are available upon request. To request one, please contact us as directed below.
(3) Principal and Proxy ID Documentation
  1. When submitting a request for disclosure, etc., of personal information, you must submit ID documentation to we can ascertain that you are the principal or duly authorized proxy.

Principal’s ID (any one of the following is acceptable)
  1. ・Copy of driver's license
  2. ・Copy of passport
  3. ・Copy of national health insurance card
  4. ・Copy of My Number card (only the front; DO NOT send in the part that shows your personal identification number)
  5. ・Copy of residence card; copy of special permanent resident certificate; or copy of alien registration card (limited to people who have special permanent resident status and have yet to switch over to the residence card)
  6. ・Copy of physically disabled certificate
  7. ・Seal registration certificate (issued no more than three months previously; stamp an impression of the registered seal in the margin)

Proxy’s ID

A document to ascertain proxy authority must be submitted along with the proxy’s ID documentation (as below).


・Document to ascertain proxy authority
  1. ➤If the proxy is a legal representative: A copy of an official document attesting to power of attorney
  2. ➤If the proxy is an agent appointed at the principal’s discretion: A letter of attorney (original—not a copy; issued no more than three months previously) signed by the principal
・Proxy’s personal identification documents
  1. Any one of the ID documents listed above are acceptable as proxy ID.
(4) Fees for Requesting Disclosure of Personal Data

We charge a fee of 500 yen (including consumption tax) for each request for notification of purpose of use or disclosure of personal data that can identify the principal we hold. To pay this fee, include 500 yen’s worth of postage stamps together with the Personal Information Disclosure, Correction, Cessation of Use, etc., Request Form and ID documentation (includes proxy ID documents if these are required).

  1. ・Further fees may be charged in cases where extraordinary methods are needed to disclose personal data or third-party records.
  2. ・We will notify you if the fee you pay is insufficient or if no fee is included in documents received from you. If you fail to pay any shortfall in fees within two weeks of the arrival of your request form (as per (2) above), your request will be deemed abandoned.
  3. ・Please note that once postage stamps are received, they will not be returned for any reason whatsoever (e.g., no disclosure of personal information).

X. Changes and Exceptions to This Policy

This policy is subject to change without notice for reasons including but not limited to law revisions and changes in Funai Soken Consulting Group policy. The policy is changed once the revised policy is posted on our website.

If, in relation to services we provide, etc., we specify rules pertaining to the purpose of use of personal information, sharing of personal information with third parties, contact details, or other matters that differ from this policy, the rules applicable to the pertinent service shall supersede this policy.

XI. Inquiries

Inquiries Regarding Confirmation, Disclosure, Correction, Deletion, and Cessation of Use of Personal Information

Funai Consulting Inc. Customer Information Management Unit
Telephone: +81-6-6204-4666

Enquiries Regarding Handling of Personal Information

Funai Soken Holdings Inc. Risk Management Department, Legal Team
Mail: [email protected]

Please note that we are unable to accept walk-in inquiries at company premises.

Last updated: April 1, 2022

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Funai Soken Holdings Inc.