PwC Tax Japan Group Policy on Handling Personal Information, Specific Personal Information, and Client Confidential Information

The PwC Tax Japan Group (consisting of PwC Tax Japan, PwC Outsourcing Services LLC, PwC Labor and Social Security Attorney Corporation, PwC Gyoseishoshi-Hojin and PricewaterhouseCoopers WMS Pte. Ltd. Tokyo Branch; also individually or collectively ‘we’, ‘us’ and ‘our’) complies with laws, regulations and other related guidelines on the protection of personal information and specific personal information, and provides a high degree of protection for personal information and specific personal information in accordance with this policy. In addition, we comply with confidentiality-related laws and contractual obligations, including Articles 38 and 54 of Japan’s Certified Public Tax Accountant Law, and provide a high degree of protection for client confidential information at a higher level in accordance with this policy. The term ‘personal information’ on its own (without ‘specific’) in this policy refers to personal information excluding specific personal information.

1. Principles of collection and use

(1) Notification of purpose of use when collecting personal information and specific personal information

When we collect personal information and specific personal information, we will publicly announce the purpose of use in accordance with relevant laws and regulations. However, when collecting personal information directly from the data subject (the individual to whom the information pertains) in writing or by a method equivalent thereto, we will specify the purpose of use and notify the data subject of the purpose of use along with the items of personal information to be collected.

(2) Purpose of use of personal information

  1. Performance of our client services such as Certified Public Tax Accountant services, labour and social security attorney services, customs consulting, outsourcing and other services related thereto
  2. Provision of information through our publications (including those provided via website or email) and information on sales and subscription of such publications
  3. Providing information and conducting administrative matters related to seminars and workshops
  4. Selection and hiring of prospective employees and personnel management after hiring
  5. Making recommendations, gathering statistics, taking surveys etc. regarding our services
  6. Performing related reporting procedures based upon requests from public agencies (including any bodies designated by public agencies) both domestically and internationally
  7. Confirmation of identity based on laws and regulations, and confirmation and management of qualifications to use products and services
  8. Responses to inquiries from clients

The above purposes of use will be announced in the privacy policy on our website. In addition, when obtaining personal information directly from you in writing or otherwise, the purpose of use will be clearly indicated in advance, unless the relevant laws and regulations specifically stipulate that there is no explicit need to do so.

Purpose of use of specific personal information

The collection and use of specific personal information may be undertaken only for the following business purposes as required for the provision of tax and social security-related services for clients, employees (including prospective recruits) or external business partners in accordance with laws and regulations. The matters listed below refer to a series of affairs relating to the collection, storage, submission to authorities and administrative bodies, deletion and disposal of specific personal information.

  1. Matters related to withholding
  2. Matters related to the preparation of deduction for dependents (transfer) reports, insurance premium deduction reports and spousal special deduction reports
  3. Matters related to the preparation of personal income tax returns
  4. Matters related to resident tax
  5. Matters related to property formation housing savings and property formation pension savings declarations, notifications and application forms
  6. Matters related to employment insurance
  7. Matters related to health insurance and welfare pension insurance
  8. Matters related to the reporting of Category-3 insured persons under the national pension scheme
  9. Matters related to the preparation of records of compensation or fee payments
  10. Matters related to the preparation of records of real estate usage fee payments
  11. Matters related to the preparation of records of real estate transfer consideration payments
  12. Dividends, surplus distribution and basic interest payment records
  13. Other matters related to items 1-11

Purpose of collection and use of client confidential information

When collecting and using client confidential information, we will comply with Japan’s Certified Public Tax Accountant Law and other confidentiality-related laws and regulations, contractual obligations with clients, and code of conduct as a professional services firm.

(3) Provision to third parties

When providing personal information or client confidential information to third parties to achieve the specified purpose of use, we will do so only after obtaining the consent of the relevant person or client except in the following cases. At that time, if so requested by the data subject or the client, we will explain the items of information to be provided, the destination, and the purpose and place of use at the destination. We will not provide specific personal information to third parties with or without the consent of the data subject, except as required by laws and regulations.

<Provision of Personal Information to Third Parties under Article 27, Paragraph 2 of the Act on the Protection of Personal Information>

In accordance with Article 27, Paragraph 2 of the Act on the Protection of Personal Information, PwC Tax Japan provides a service that provides the results of an inquiry using the Qualified Billing Business Publication System Web-API provided by the National Tax Agency (the “System”) with the Qualified Billing Business Registration Number obtained from our clients of the service. We will provide personal data to our clients (domestic and foreign corporations or individual proprietors). In providing personal data to foreign entities, we comply with Article 28 of the Act on the Protection of Personal Information.

(i) Items of personal data provided to third parties

Information available through the System, including the status of registration as a Qualified Billing Business as of a certain date, classification as a corporation or individual, date of registration, date of revocation, date of expiration, location of registered head office (limited to cases where a request for publication has been made), and registered name

(ii) Method of obtaining personal data provided to third parties

Personal data are obtained mechanically using the System. The acquired personal data will be updated periodically using the System.

(iii) Method of provision to third parties

E-mail

(iv) Cessation of provision to third parties

Provision of personal data to third parties will be stopped upon request of the individual.
For more information, please contact

Invoice Response Support Team
jp_tax_qis_privacy@pwc.com

(4) Joint use

We may use the collected personal information jointly with member firms of the PwC global network and their designated subsidiaries (hereinafter collectively referred to as ‘PwC member firms’) to assist in the provision and improvement of worldwide services by the entire PwC global network. PwC member firms include firms located outside Japan. However, we have established a management system that complies with the standards required by the Act on the Protection of Personal Information and have taken necessary measures to ensure that the compliance system is maintained on an ongoing basis. If you have any questions, please contact us using the method described in ‘7. Comments and inquiries regarding the handling of personal information and specific personal information’.

The following personal information may be provided to PwC member firms by means of physical document, email or electromagnetic recording medium.

  • Name, age, address, telephone number, fax number, email address, workplace, department, job title
  • Matters pertaining to inquiries and services provided
  • Matters contributing to the provision and improvement of worldwide services throughout the PwC global network

The firm that collected the personal information from the data subject assumes responsibility for the management of personal data during this joint use.
We will not share the specific personal information that we collect with PwC member firms, except in cases where it is entrusted to a third party within the extent of the purpose of use and as is permitted by laws and regulations in exceptional cases.

(5) Provision to or receipt from third parties outside Japan

When providing personal information or client confidential information to companies or individuals outside Japan, or when receiving such information from companies or individuals outside Japan, we will comply with the relevant legal and contractual requirements and professional requirements.

(6) Ensuring the accuracy of the contents

We will collect personal information, specific personal information, and client confidential information appropriately in consideration of the purpose of use and within the scope necessary for achievement of the purpose of use. In addition, after collecting personal information and specific personal information, we will take appropriate measures to ensure that such information be kept accurate and up to date within the scope necessary for achieving the purpose of use.

(7) Retention

Personal information and client confidential information will not be unnecessarily retained for a period of time longer than necessary to achieve the purpose of use. Specific personal information will not be retained for a period exceeding that stipulated by laws and regulations.

2. Principle of respect for rights

We will respond appropriately requests for the disclosure of the personal information and specific personal information we hold, in accordance with relevant laws and regulations. If, as the result of such disclosure, any problems with the accuracy or currency of personal information and specific personal information are discovered, we will correct the information as necessary.

3. Implementation of security control actions

We will implement the necessary and appropriate measures and other security controls to prevent the leakage, loss, damage, and falsification of personal information and specific personal information. Please see this page for an outline of such measures.

4. Principle of continuous improvement

We will regularly inspect and improve our safety control system for personal information, specific personal information, and client confidential information.

5. Implementation of these rules

Regarding the handling of personal information, specific personal information, and client confidential information, we will comply with this policy and with relevant laws and regulations, related guidelines, contractual obligations, professional codes of conduct, internal rules, and the PwC Global Data Protection Policy. Compliance with these rules is the responsibility of each employee and staff member. Any person who violates these rules is subject to disciplinary punishment, including dismissal.

6. Procedures for responding to requests for disclosure of retained personal data

To make a request regarding your personal information (including requests for notification of the purpose of use, the disclosure, correction, addition, deletion, cessation of use or erasure of information, the cessation of provision of the data to third parties, and disclosure of records of provision to third parties), please contact us by telephone or mail as described in the following section. We will provide you with the required forms and fields, as well as instructions on how to fill them out.
Please note that you will be asked to bear the actual expenses required for the fulfilment of your request.

7. Comments and inquiries regarding the handling of personal information and specific personal information

We will respond appropriately to your comments and inquiries about the handling of personal information and specific personal information.
For any comments or inquiries regarding the handling of personal information and specific personal information, please contact us as follows:

PwC Tax Japan
1-2-1 Otemachi, Chiyoda-ku, Tokyo 100-0004
Tel: 03-6257-0600 (Main Line)
Hours: 9:15am-5:15pm (Monday to Friday, excluding national holidays)

Jun Takashima, Representative
PwC Tax Japan

Enforced: 3 April 2005
Revised: 1 July 2006
Revised: 17 June 2008
Revised: 1 August 2011
Revised: 1 July 2015 (PwC Tax Japan name changed)
Revised: 1 October 2015 (PwC Outsourcing Services LLC and
PwC Labor and Social Security Attorney Office names changed)
Revised: 1 February 2016 (Revised in accordance with the introduction of the Individual Number (‘My Number’) system)
Revised: 4 January 2017 (PwC Labor and Social Security Attorney Corporation name changed)
Revised: 27 February 2022
Revised: 1 April 2022

This English translation of the Japanese original is provided solely for the convenience of non-Japanese readers. In the case of any discrepancy between the Japanese original and this English translation, the Japanese original prevails.