Personal Information Protection Policy
PAL K.K. (“PAL”) is a provider of executive search and recruiting services in Japan. In operating its business, PAL must handle a great deal of personal information concerning candidates, clients, and employees. Therefore, PAL has established and implemented this Policy to commit to protecting personal information.
- PAL will specify the purposes for utilizing the personal information and will properly handle the personal information within the scope necessary to achieve such purposes. PAL will operate in a way to ensure the prevention of personal information being used other than for the intended purposes.
- PAL will obtain personal information only through legally acceptable and appropriate means.
- Except as allowed under applicable laws and regulations or in accordance with this Policy, PAL will not provide any personal information of any individual to a third party without the consent of that individual.
- In managing personal information, PAL will make efforts to take all necessary and appropriate measures to ensure the prevention and correction of any leakage, loss or damage of the personal information.
- In handling personal information, PAL will make efforts to ensure that the individual who has provided the information shall be properly involved in the handling process, and to keep the personal information accurate and updated to the extent possible.
- PAL will comply with laws and regulations pertaining to the protection of personal information, and will continuously work to strengthen this area as the company grows.
- PAL will establish a contact window to correspond to complaints and consultations concerning the protection of personal information and make efforts to properly respond to such complaints and consultations.
Established and implemented on January 1st, 2017
Regarding the handling of personal information
Personal information is the information of a Candidate as a living individual, which can identify the Candidate based on the name, address, telephone number, e-mail address, and educational information. Even if the Candidate cannot be identified by a specific information, such information will be treated as personal information if the Candidate can easily be identified as a result of such information being referenced with other information. In addition, information that includes individual identification codes (as defined in the “Act on the Protection of Personal Information”) will also be treated as personal information.
Purposes of use of personal information
PAL shall use personal information only for the following purposes, and shall not use any personal information beyond these purposes of use:
- Provision of information and services concerning job referrals
- Provision of personal information to Service Using Companies, etc., based on Candidates’ consent/application.
- Listening in on opinions or requests aimed at confirming Candidate’s situation after employment or dispatching, and improving services.
- Confirmation of the candidate’s application and commence as well as receiving notices from Service Using Companies.
- Statistically analyzing information for publication on websites and other media.
- Development and marketing of potential services.
- Advising and proposing recruitment plans for companies seeking workers.
- Managing inquiries, consultations and complaints, and/or resolving disputes.
- Hiring operations for PAL.
- Disclosure to third parties in accordance with this Policy.
- Making contact through generally shared information, such as publications and websites.
Voluntary nature of providing personal information
Although it is not necessary to provide all of the items asked for, if a Candidate fails to answer necessary question(s), such Candidate may not be able to obtain the services PAL provides.
Disclosure of personal information to the third party
PAL, as a recruiting agency, will provide personal information (limited to Company name, position title, job description, etc.) obtained from the Candidate or from public source, after examining the Candidate’s requests and adequacy, by sending or carrying the document to contracted companies who have agreed to the articles of properly handling personal information; provided, however, that PAL will promptly cease the disclosure to third parties when requested by the Candidate.
Notwithstanding the above, personal information may be disclosed without Candidate’s consent within the confines of applicable laws and regulations when:
A) It is necessary to protect the life, body or property of a person and it is difficult to obtain the consent of the Candidate.
B) The provision of personal information is especially necessary for improving public hygiene or promoting the sound growth of children and it is difficult to obtain the consent of the Candidate.
C) The provision of personal information is necessary for cooperating with a state institution, a local public body, or an individual or entity entrusted by such an institution or body to execute operations prescribed by law, and obtaining the consent of the Candidate might impede the execution of such operations.
D) The Candidate him/herself explicitly requests the provision or disclosure to the third party.
E) The disclosure and provision of personal information is allowed by laws and regulations.
Outsourcing of personal information handling process
PAL may outsource partial or all of the personal information handling duties. PAL shall be responsible for the handling of personal information by the outsourcing contractor.
Use of statistically-processed data
PAL may, based on the provided personal information, create statistical information which shall be processed in a manner that cannot identify any individual. PAL may, without restriction, use statistical information that cannot identify individuals.
Disclosure, etc., of personal information
In the event a Candidate requests for a notice, disclosure, correction, addition / deletion, suspension, or elimination for the use of Candidate’s personal information or suspension of provision to the third party, PAL shall take prompt actions according to its internal regulations. However, to the extent permitted under applicable laws and regulations, PAL may not be able to accommodate the request. In this case PAL will inform the Candidate.
Accuracy of personal information
PAL shall make efforts to keep accurate and updated the personal data provided, and to delete without delay personal data which becomes unnecessary for the purpose of use. However, Candidates are to be responsible for ensuring that the personal information they provide is accurate and up-to-date and truthful.
Restrictions on acquisition of sensitive personal information
PAL, as a general rule, shall not obtain any Candidate’s personal information which containing any of the following information unless otherwise permitted under applicable laws and regulations or the personal information has been provided by the Candidate directly:
A) Information relating to personal philosophy, belief or religion;
B) Information relating to race, ethnic background, family background, domicile (except for information on the prefecture where the Candidate is located), physical or mental disability, criminal record or other matters that may cause social discrimination;
C) Information relating to participation in acts of mass demonstration, exercising of petition rights or other political rights;
D) Information relating to health and medical conditions or sex life.
Please contact “PAL” through our website for any complaints or questions.