NIKKEI RESEARCH INC.

Policy on the Protection of Personal Information

1. Declaration of the Protection of Personal Information

We make every effort to conduct ourselves fairly and to protect our customers’ confidential data and the privacy of survey participants (respondents) to maintain the public’s trust.

This is Row 1 of Nikkei Research Inc.’s Corporate Philosophy. As a research organization which gains cooperation of many survey participants, we have set the protection of personal information of all stakeholders, including survey participants (respondents), customers, users of our website, and employees, as the basis of our business.

In June 1999, we formulated the “Nikkei Research Personal Information Protection Compliance Program” (which is now called the “Personal Information Protection Management System”), and established a personal information protection system. In August 1999, we were certified by Japan Information Processing Development Corporation (which is now called JIPDEC) to have a “PrivacyMark ®,” which is given to an enterprise processing personal information appropriately.

Recognizing social requests for the protection of personal information, we hereby clarify our policy, both internally and externally, on processing of personal information, and express our intention to implement the policy.
 
2. Basic Policy for the Protection of Personal Information
We observe the following:
  1. Collection, Use and Provision of Personal Information
    • We specify the purpose of use of personal information within the legitimate scope of our business, including various surveys, database services and consulting services, and collect personal information through legal and fair means.
    • We do not use the collected personal information beyond the scope necessary to achieve the specified purposes of use. Any use of personal information beyond the scope necessary to achieve the specified purposes of use will be made with the prior consent of the person himself/herself.
    • In principle, we do not provide the collected personal information to any third party. Any provision to a third party will be made with the prior consent of the person himself/herself.
  2. Compliance with laws and regulations, guidelines, and norms
    • We comply with various laws and regulations, and the guidelines set by the government which are related to the handling of personal information, such as the “Act on the Protection of Personal Information.”
    • We comply with various standards, including the “Marketing Research Code of Conduct” and the “Marketing Research Industry Personal Information Protection Guideline,” which are established by Japan Marketing Research Association, of which we are a member.
    • As an enterprise certified to have the PrivacyMark ®, we comply with the Japanese Industrial Standards “JIS Q 15001 Personal Information Protection Management Systems–Requirements.”
  3. Prevention of Leakage of Personal Information
    • We identify and analyze the risks related to personal information handled, and take safety management measures to prevent accidents, such as unauthorized access, leakage, loss, damage, or falsification.
    • In the event of any accident, such as unauthorized access, leakage, loss, damage, or falsification, we promptly take necessary corrective measures.
  4. Protection of Rights of the Person Himself/Herself
    • We promptly respond to any complaint or inquiry from the person himself/herself regarding the handling of personal information and/or the personal information protection system.
    • In the event that we receive a request for the notification of the purpose of use, disclosure, correction, addition or deletion of contents, suspension of use, erasure, and suspension of provision to a third party with regard to the retained personal data (the personal information that is subject to disclosure) from the person himself/herself, we will respond to the request without delay in accordance with various laws and regulations, guidelines, and norms.
  5. Organizational Measures
    • We establish and maintain the “Nikkei Research Personal Information Protection Management System,” which is the personal information protection system that complies with the Japanese Industrial Standards “JIS Q 15001 Personal Information Protection Management Systems–Requirements,” and continuously improve it. In order to ensure this, we will establish various regulations and provide necessary education.
    • Our personal information protection manager is Mr. Tokuhisa Suzuki, Director. We operate the “Nikkei Research Personal Information Protection Management System” appropriately under the management system with the personal information protection manager in charge, and ensure that all persons (employees) engaged in duties handle personal information in safe and appropriate manners.
    • We appoint an internal auditor in charge of protecting personal information, regularly audit the status of operations of the “Nikkei Research Personal Information Protection Management System,” and make improvements based on the results of the audit.
    • When we entrust the handling of personal information, we select a person/a company who will take sufficient safety management measures, conclude a necessary contract, and implement appropriate supervision.
    • This Policy on the Protection of Personal Information is made available for inspection at any time by posting it on our website or other means.
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Established: January 4, 2005
Last revision: December 1, 2018

Toshihiko Fukumoto
President
Nikkei Research Inc.
Handling of Personal Information at Nikkei Research Inc
Nikkei Research Inc. handles a large amount of personal information as a research organization. Our main duties are to conduct surveys, such as market researches, opinion surveys, and company surveys, and to create corporate databases. We handle the personal information collected in connection with these duties as follows under the “Policy on the Protection of Personal Information”:
1. Purpose of Use of Personal Information
(1)  Personal information directly collected from the person himself/herself in contact with him/her

When we collect personal information directly in writing or by other means from the person himself/herself in contact with him/her, in principle, we notify him/her of the purpose of use in advance in writing or orally.
The types of personal information to be collected in the above manner and the purposes of use thereof are as shown in the table below.
Type of personal information to be collected Purpose of use of personal information to be collected
Personal information collected in connection with the implementation of survey services Used for the following purposes when conducting surveys
・Selection of survey participants (respondents)
・Request for surveys, and sending of survey questionnaires
・Implementation record of surveys
・Sending of rewards
・Others (response to inquiries, confirmation of the contents of responses, information on sending destinations at the time of conducting the next survey, etc.)

When conducting a survey, we clarify the purpose of use, etc. of personal information in the survey to the survey participants (respondents) and obtain their consent.
Personal information collected at the time of the registration of the “research panel” who cooperate in the Internet survey Used for the conducting of the Internet surveys, and recruiting of participants for Central Location Tests (CLTs), focus group interviews, etc.

When participants register themselves as the “research panel” and when they apply for various surveys after the registration, we clarify the purpose of use of personal information to be collected and obtain their consent.
Personal information such as video, images, and audio recording focus group interviews, CLTs, etc. Used for the analysis and implementation record of focus group interviews, CLTs, etc.

Prior to recording images and/or audio, we clarify the purpose of use to the persons themselves and obtain their consent.
Personal information collected at the time of the membership registration of our membership website, “Global Marketing Campus” (“GMC”), and information on members collected as a result of use thereof Used for the provision of GMC member services, and/or security measures for the operation of GMC (see GMC member regulations for details)
Personal information of the persons in charge of the entrusted persons, such as outside partner companies, sole proprietors, and research interviewers. Used for the registration of entrusted persons, conclusion of contracts, order placement, project management and payment in connection with the entrusted services, such as the field operation
Personal information of employees Used for labor management and accounting procedures, such as payroll transfers
Personal information contained in resumes, job histories, etc. submitted by job seekers Used for the selection of employees
Personal information collected when receiving inquiries about our products, services, etc., and when accepting participation in seminars held by us May be used for the provision of information regarding the Nikkei Group’s or our products, services, etc., and for our sales activities
Personal information, such as business cards, of the persons in charge of client companies and organizations
Personal information collected when our information is provided to the persons in charge of client companies and organizations by telephone or other means
(2) Personal information collected by means other than directly from the person himself/herself

The types of personal information to be collected by means other than directly from the person himself/herself and the purposes of use thereof are as shown in the table below. In such a case, instead of the notice to the person himself/herself, we publish the purpose of use on our website or by other means.
Type of personal information to be collected Purpose of use of personal information to be collected
Personal information entered in the Basic Resident Register and/or electoral registers Used for the identification of target respondents, sending of request letters, survey questionnaires and rewards, visit of research interviewers, etc., in social surveys, opinion surveys, and academic research surveys entrusted by national and local government public institutions, educational institutions, media organizations, etc.
Personal information listed in telephone directories or those in the form of CD-ROM Used for the identification of target respondents, sending of survey questionnaires and rewards, visit of research interviewers, telephone inquiries, etc. in our surveys
Personal information of the persons, such as friends, introduced by the target respondents of the surveys conducted by us Used for the conducting of the Internet surveys, and solicitation of participants for CLTs, focus group interviews, etc.
Personal information, the handling of which is entrusted by client companies and organizations Used to the extent necessary for the implementation of the services entrusted by client companies and organizations (such as sending survey questionnaires, rewards, etc., handling inquiries, and updating personal information)

In making use of personal information, we confirm with client companies and organizations that the personal information has been legally and fairly collected and that the handling of the personal information entrusted to us is within the scope necessary to achieve the original purpose of use of such personal information. At the same time, we implement safety management equivalent to that used for the personal information collected by us.
Personal information, such as the voice and video of responders, collected at the time of communication at target stores, target call centers, etc. subject to mystery shopping observational surveys Used for the implementation record and quality control of the mystery shopping observational surveys
Personal information, such as the images of users and visitors, collected by cameras installed in target facilities subject to surveys Used for the analysis of the behavior of the users and visitors of target facilities
Personal information of corporate officers, executives, shareholders, etc. collected from enterprises through responses to surveys or by other means. Used for the update of the information in the corporate databases entrusted by Nikkei Inc.
Personal information of officers, shareholders, etc. described in annual reports
Personal information properly disclosed on corporate websites, etc.
Personal information recorded in the entry and exit record system installed in our premises Used for security management in the premises and employees’ action records
Personal information shot with the security cameras installed in our premises Used for security management in our premises
2. “Provision to a Third Party” of Personal Information
We do not provide personal information to any third party without the consent of the person himself/herself, except in the following cases, and even when providing personal information to a third party located in a foreign country (including an entrusted person/company located in a foreign country), we will obtain the consent of the person himself/herself appropriately in accordance with laws and regulations:
a) when required by laws and regulations;
b) when the provision of personal information is necessary for the protection of the life, body, or property of an individual and it is difficult to obtain the consent of the person himself/herself;
c) when the provision of personal information is particularly necessary for improving public health or promoting the sound growth of children and it is difficult to obtain the consent of the person himself/herself; and
d) when it is necessary to cooperate for the execution of the affairs prescribed by laws and regulations by a national or a local government, or a person/a company entrusted by either of them, and obtaining the consent of the person himself/herself is likely to impede the execution of the affairs.
3. Share of Personal Information
We may share the following personal information:
Items of personal information to be shared Names of companies or organizations, office addresses, departments, titles, telephone numbers, e-mail addresses, names, etc. of the persons in charge of client companies and organizations
Scope of persons sharing personal information Nikkei Research & Consulting (Thailand) Co., Ltd. (Thailand subsidiary of Nikkei Research Inc.)
Purpose of use of persons sharing personal information For the provision of information on the Nikkei group’s or our products, services, etc. and for the sales activities of the person sharing personal information and ours
Person responsible for the management of personal information to be shared Nikkei Research Inc.
Method for collection Declaration by the person himself/herself (e.g. registration on our website, and entry in an application form) at the time of business card exchange, telephone interviews, receipt of inquiries, and acceptance of participation in seminars.
4. Measures to Be Taken When Handling Personal Information of Individuals Residing in the EU
We collect and appropriately handle personal information of individuals residing in the EU for use for the purposes described in “1. Purpose of Use of Personal Information” above, in accordance with the laws and regulations of the EU, such as the General Data Protection Regulations (the “GDPR”). For any purpose of use, legal grounds are based on “necessity in a contract to which the person who is the subject of personal information is a party,” “the legitimate interests of a controller,” “the consent of the person who is the subject of personal information,” and “compliance with a legal obligation to which a controller is subject” in Article 6 of the GDPR. In addition, with regard to the personal information of individuals residing in the EU, we appropriately respond to any request from the person himself/herself regarding the correction, addition, deletion, suspension of use, or erasure of personal information, as well as data portability, the right to express an objection to the processing of personal information, the right not to be subject to a decision regarding individuals based on automated processing, and the withdrawal of consent for the handling of personal information by us.
We may handle the personal information of individuals residing in the EU after transferring it to a location outside the EU including Japan. In countries outside the EU, an adequacy decision on personal information protection by the European Commission has not been given, and the same rights of the person himself/herself as those under the GDPR may not be granted, but we will appropriately manage the personal information of individuals residing in the EU in accordance with appropriate protection measures established by the GDPR.
In handling the personal information of individuals residing in the EU, we appropriately manage it in the same way as other personal information. We also set the storage period for the personal information in accordance with the purpose of use, and when the purpose of use is achieved, we will dispose of it in an appropriate manner.
5. Inquiries on Personal Information
In conducting surveys, we set up an inquiry desk and clarify it on survey request letters, survey questionnaires, etc. Moreover, in case we cannot clarify it through written documents because the surveys are conducted by telephone, etc., we will inform of it orally. For inquiries about the handling of personal information and/or the management system for any individual survey, please contact the inquiry desk. For general inquiries about the handling of personal information by us and/or our management system, please contact the following:
https://www.nikkei-r.co.jp/contact_privacy/
6. Procedures to Respond to “Request for Disclosure, etc.”
We will respond without delay to any request from the person himself/herself or his/her agent for the notification of the purpose of use, disclosure, correction, etc. (correction, addition or deletion of contents) and suspension of use, etc. (suspension of use, erasure, and suspension of provision to a third party) of the retained personal data (the personal information that is subject to disclosure). For a request for the notification of the purpose of use, disclosure, correction, etc. (correction, addition or deletion of contents) and suspension of use, etc. (suspension of use, erasure, and suspension of provision to a third party) of the retained personal data (the personal information that is subject to disclosure), please contact the following:
https://www.nikkei-r.co.jp/contact_privacy/
Additionally, for a request for the notification of the purpose of use, disclosure, correction, etc. (correction, addition or deletion of content), and suspension of use, etc. (suspension of use, erasure and suspension of provision to a third party), procedures such as identity confirmation are required. We will send documents necessary for the application to an applicant.
Please note that we cannot respond to any request even if the applicant comes to our office directly.
7. Others
  1. We may change the “Policy on the Protection of Personal Information,” etc. in whole or in part. We will inform of any material changes on this website.
  2. We are not currently the target entity of the “authorized personal information protection organizations.”
Established: January 4, 2005
Last revision: December 1, 2018
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