Japan Privacy Law to Change in Mid-Year

    Mar 07, 2017

    Revisions to Japan’s Act on the Protection of Personal Information (APPI), combined with the start-up of a Personal Information Protection Commission (PPC), will likely impact the international community’s cross-border data transfers with Japan.  

    As summarized on, in a presentation in Washington, PPC Director Yoshikazu Okamoto spoke of these key aspects of the amended APPI, one of Asia’s oldest privacy laws, which was established in 2003:

    • The PPC will have centralized data protection authority over all ministries. It consists of a chairman and eight commissioners appointed by the prime minister, with consent of the Diet.
    • Consent will be required to use or disclose “special care-required personal information,” which includes data about a person’s race, creed, social status, medical record, criminal history, and crime-victim status.
    • Consent will not be needed to transfer or process anonymously processed information.
    • To improve the traceability of personal information that businesses share, the amended APPI calls for companies to keep records of how or from whom they obtained that information and to whom they transferred it.
    • The new APPI lists three types of legitimate transfers of personal information to a third party in another country: (1) transfers to a country the PPC says has an acceptable level of data protection; (2) transfers to a third party in a country that ensures the same level of data protection as Japan ensures; or (3) transfers with the data subject’s consent.
    • International transfers of personal information can continue if reasonable safeguards are in place.

    The amended APPI will take effect on May 30.


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