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.

The above statement is one of the long-valued corporate philosophies of Nikkei Research Inc.
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, suspension of provision to a third party, or the disclosure of third-party traceability records 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 Tetsuo Tamura, Managing Executive Officer. 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.
Established: January 4, 2005
Revision: April 1, 2020
Last revision: April 1, 2022

Masashi Shindo
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 such as his/her name, address, email address 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 such as his/her name, address, gender, age, marital status, number of people living in the same household, employer, annual income, email address, and telephone number 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 such as his/her name, address, gender, occupation, employer, work address, telephone number, place of residence, and email address 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 such as the address, name, business name, telephone number, and email address 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 applications for 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 such as the name, department, job title, and email address collected when our information is provided to the persons in charge of client companies and organizations by telephone or other means
Personal information such as the description of inquiry, name and email address the inquirer submitted on our company website Used for responding such inquiries.
Personal information of our database registrants regarding their user agent (browser type, version, OS, and terminal identification), IP address, cookies, advertising identifier (ADID, IDFA), browser URL, last access time and date) automatically obtained when they access websites we operate May be used for the analysis of obtained information such as browse history to provide information regarding the Nikkei Group’s products, services, etc., for our sales activities and the placement of advertisements according to the registrants’ interests.
(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.
Type of personal information to be collected Purpose of use of personal information to be collected
Personal information such as names, addresses, ages, genders, etc. 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 such as names, addresses, telephone numbers, etc. 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 such as the names, addresses, ages, telephone numbers, emal addresses, etc. 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 such as names, addresses, email addresses, IDs, etc., 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/transmitting 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 such as the names, job titles, etc. of officers, shareholders, etc. described in annual reports
Personal information such as the names, job titles, etc. properly disclosed on corporate websites, etc.
Personal information such as the names, time of entry/exit, location of entry/exit, etc. 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 captured in the video 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.
e) when the Third Party is an academic research institute or similar organization, and it is necessary for them to handle personal information for academic research purposes (except when the provision may cause an unjustifiable infringement of someone’s personal rights and interests even when the part of the purpose to handle personal information pertains to academic research purposes).
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 Masashi Shindo,
President
Nikkei Research Inc.
2-2-1, Uchikanda, Chiyoda-ku, Tokyo
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. Basic Policy for Security Management Measures for Personal Information
We have implemented the following company-wide measures to prevent the leakage of personal information:
  Outline
Formulation of basic policy
  • To ensure appropriate handling of personal data, we have formulated the basic policy concerning “Compliance with related laws and regulations/guidelines,” “Contact for inquiries and complaints,” etc.
Development of regulations concerning handling of personal data
  • At each of the collection, use, storage, provision, and erasure/disposal stage, we have developed personal data handling regulations concerning handling methods, responsible persons/persons in charge, and the scope of their responsibilities.
Organizational measures
  • We designate a person responsible for personal data handling. We have also clarified who can handle personal data among our employees and the scope of personal data they handle.
  • If the fact or sign of a violation of laws and regulations was discovered, we have developed a system through which a report is sent to the responsible person.
  • Regarding handling personal data, we conduct self-check regularly and audits by staff members from other departments.
Human measures
  • Regarding personal data handling-related precautions, we provide our employees with training regularly.
  • Personal data-related confidentiality clauses have been incorporated into various internal regulations.
Physical measures
  • In the area where personal data is handled, we control our employees for entry/exit and restrict the devices they are allowed to carry. We also have implemented the measure in which unauthorized employees have no access to personal data.
  • We have implemented the measures to prevent the theft or loss of devices, electronic media, books, etc., to handle personal data. We also implemented the steps to make personal data not easily identified when the device or electronic media are carried out of the office.
Technical measures
  • By controlling access, we limit the number of employees who handle personal data and the scope of the personal database and other data.
  • We have implemented a system to protect the personal data-related information system from fraudulent external access or unauthorized software.
External environment awareness
  • We conduct security management measures based on our understanding of the personal information protection-related systems in foreign countries where personal data is stored.
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/en_contact_privacy/
6. Procedures to Respond to “Request for Disclosure, etc.”
We will respond 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), suspension of use, etc. (suspension of use, erasure, suspension of provision to a third party), and the disclosure of third-party traceability records 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), suspension of use, etc. (suspension of use, erasure, and suspension of provision to a third party), and the disclosure of third-party traceability records of the retained personal data (the personal information that is subject to disclosure), please contact the following:
https://www.nikkei-r.co.jp/en_contact_privacy/
Additionally, for a request for the notification of the purpose of use, disclosure, correction, etc. (correction, addition or deletion of content), suspension of use, etc. (suspension of use, erasure and suspension of provision to a third party), and the disclosure of third-party traceability records, 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. Instances where Disclosure Requests is Denied
If the request falls under any of (1) through (9), we are unable to comply with any request for disclosure or other reasons. In this case, we will notify the applicant with an explanation.
  1. when we cannot confirm the identity of the applicant because the address on the application, the address on the document for identification purposes, and the address registered with our company do not match
  2. when we cannot confirm the authority of the designated agent when an agent submits the application
  3. when the submitted application is insufficient
  4. when the subject for disclosure is not personal data (personal information subject to be disclosed) in storage
  5. when such disclosure may harm the life, body, property, or other rights or interests of the applicant or a third party
  6. when such disclosure may encourage or induce illegal or prohibited acts
  7. when the personal data requested is not in our personal data in storage
  8. when such disclosure may present a significant difficulty to our appropriate business operations
  9. when such disclosure deems to be a violation of laws and regulations
8. Other
  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
Revision: August 4, 2021
Last revision: April 1, 2022
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