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Privacy Policy

I. Policy on Protection of Personal Information/Individual Numbers

  • ① The Company shall comply with the Act on the Protection of Personal Information, the Act on the Use of Numbers to Identify a Specific Individual in the Administrative Procedure, other relevant laws and regulations as well as social responsibilities, and shall endeavor to implement the protection of personal information (including specific personal information) and individual numbers (hereinafter referred to as "personal information/individual numbers").
  • ② The Company shall enhance the education of its directors, officers and employees, etc. in order to implement the protection of personal information/individual numbers.
  • ③ The Company shall establish appropriate organizational structures in order to implement the protection of personal information/individual numbers.
  • ④ The Company shall establish appropriate internal rules and regulations in order to implement the protection of personal information/individual numbers.
  • ⑤ The Company shall establish appropriate procedures for acquiring, providing, handling, etc. of personal information/individual numbers in order to implement the protection of personal information/individual numbers.
  • ⑥ The Company shall endeavor to improve information security in order to implement the protection of personal information/individual numbers.
  • ⑦ The Company shall conduct appropriate audits in order to implement the protection personal information/individual numbers.
  • ⑧ The Company shall continually review its systems for implementing the protection of personal information/individual numbers.

II. Purpose of Use

II-1. Purpose of Use for Personal Information

The Company shall use Personal Information within the scope of the Purpose of Use described below (including purposes ancillary and relating thereto) in order to carry out the business of the Company. However, the Specific Personal Information stipulated in the Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures shall be used within the scope of the "Purpose of Use of Individual Numbers and Specific Personal Information" separately described.

1Personal Information relating to medical practitioners such as physicians, dentists, veterinarians, pharmacists, clinical laboratory technicians, nurses, pharmacies/drug stores, medical science and pharmacology related researchers (including employees in the case of organizations; hereinafter the same shall apply), as well as patients, clinical study participants and other users of products (including services; hereinafter the same shall apply) (including past users, and individuals scheduled for use in the future)
  • ① Provision of products
  • ② Provision/collection of information related to products such as proper use, quality and safety
  • ③ Provision/collection/analysis of product marketing information such as status of use, actual conditions of use, and needs of use
  • ④ Provision/collection/consideration of scientific information and other information related to the business of the Company
  • ⑤ Implementation of clinical studies, post-marketing surveillance and other investigations/research related to the business of the Company
  • ⑥ Notifications/reports in accordance with laws and regulations and other standards
  • ⑦ Provision to third parties within the scope necessary to carry out the items above
2Personal Information pertaining to individuals that are (or that were) related to the Company by contract or by credit relationships (including those prior to the construction of the said relationship) in connection to the business of the Company, including clients of the Company such as product wholesalers, product materials suppliers and product manufacturers, creditors of the Company such as lenders, debtors owed to the Company such as borrowers, as well as consultants such as lawyers and accountants
  • ① Performance of obligations or exercise of rights based on the said contractual/credit relationships, or the response thereto
  • ② Provision/collection of information pertaining to the said contractual/credit relationships
  • ③ Construction of new contractual/credit relationships
  • ④ Management of business records
  • ⑤ Notifications/reports in accordance with laws and regulations and other standards
  • ⑥ Provision to third parties within the scope necessary to carry out the items above
3Personal Information of individuals that make consultations, communications or other access through PR-related points of contact, or other external points of contact or the Company's employees, etc. as external points of contact, or via the Company's website.
  • ① Responses and other communications regarding the said access
  • ② Management of access records
  • ③ Notifications/reports in accordance with laws and regulations and other standards
  • ④ Provision to third parties within the scope necessary to carry out the items above
4Personal Information of shareholders (including past shareholders)
  • ① Performance of obligations or exercise of rights in accordance with the Companies Act or other applicable laws and regulations or other standards, or the response thereto
  • ② Distribution of complimentary tickets for shareholders and other complimentary items sent to shareholders
  • ③ Management of shareholders to the extent necessary to carry out the above
  • ④ Notifications/reports in accordance with laws and regulations and other standards
  • ⑤ Provision to third parties within the scope necessary to carry out the items above
5Personal Information pertaining to employment applicants
  • ① Considerations/decisions regarding acceptance
  • ② Contact regarding acceptance
  • ③ Notifications/reports in accordance with laws and regulations and other standards
  • ④ Provision to third parties within the scope necessary to carry out the items above
6Personal Information of employees, etc. (including past employees, etc.) and their families
  • ① Human resources management including the proper distribution of personnel in the Group, salary payments and other labor management
  • ② Management of welfare programs as well as health and safety
  • ③ Training/education
  • ④ Notifications and other communications within the scope necessary to carry out the business of the Company
  • ⑤ Notifications/reports in accordance with laws and regulations and other standards
  • ⑥ Provision to third parties within the scope necessary to carry out the items above

Notwithstanding the above, for notifications or other communications from the Company to the individuals for whom the Company legally retains full names and contact information, the Company may use this information to the extent necessary to carry out the business of the Company.
(Note)
1. Please refer to the business objectives specified in Article 2 of the Articles of Incorporation of the Company regarding the business conducted by the Company.
2. The Company may alter the Purpose of Use as appropriate to the extent and method permitted by law.

II-2. Purpose of Use for Individual Numbers /Specific Personal Information

The Company shall use Individual Numbers/Specific Personal Information within the scope of the Purpose of Use described below:

  • ① Affairs regarding production of documentation and report relating to employment/retirement income
  • ② Affairs regarding production of payment records and report relating to earnings, fees, etc.
  • ③ Affairs regarding production of payment records and report relating to real property fees, etc.
  • ④ Affairs regarding production of payment records and report relating to dividends, etc.
  • ⑤ Affairs regarding production of documentation and report on employment insurance
  • ⑥ Affairs regarding production of documentation and report on health insurance
  • ⑦ Affairs regarding production of documentation and report on employee / national pension plans
  • ⑧ Affairs regarding production of documentation and report on asset accumulation savings/pensions

(Note) The Company may alter the Purposes of Use as appropriate to the extent and method permitted by laws.

III. Joint Use of Personal Data

The Company uses personal data by means of joint use as follows.

1Personal data included in the Nihon Ultmarc Inc. Medical Database (MDB)

The Company uses personal data included in its Medical Database (MDB) with Nihon Ultmarc Inc. The entity and/or person responsible for management of personal data used by means of joint use is Nihon Ultmarc Inc. For information regarding items included in such personal data, the scope of entities and/or persons allowed to such personal data, and purposes of use of such personal data, please visit their website at: https://www.ultmarc.co.jp/privacy/shared_use/index.html (in Japanese only).

2Personal data relating to medical practitioners such as physicians, dentists, veterinarians, pharmacists, clinical laboratory technicians, nurses, pharmacies/drug stores, medical science and pharmacology related researchers (i)
  • ① Personal data items
    Name, gender, place of work, work address, work phone number, department, e-mail address, date of birth, school name/graduation year, job classification, and other information necessary to achieve the Purpose of Use described in II above
  • ② Scope of entities and/or persons for joint use of personal data
    Sumitomo Dainippon Pharma group companies worldwide
  • ③ Purposes of use of personal data
    Purposes of use as described in II above (including similar purposes of use by entities and/or persons with which the data is used by means of joint use)
  • ④ Name of entity and/or person responsible for management of personal data
    Sumitomo Dainippon Pharma Co., Ltd.
3Personal data relating to medical practitioners such as physicians, dentists, veterinarians, pharmacists, clinical laboratory technicians, nurses, pharmacies/drug stores, medical science and pharmacology related researchers (ii)
  • ① Personal data items
    Name, gender, place of work, work address, work phone number, department, e-mail address, school name/graduation year, job classification, and other information necessary to achieve the Purpose of Use described in II above
  • ② Scope of entities and/or persons for joint use of personal data
    Sumitomo Dainippon Pharma Co., Ltd. and Novartis Pharma K.K.
  • ③ Purposes of use of personal data
    Purposes of use as described in II above (including similar purposes of use by entities and/or persons with which the data is used by means of joint use)
  • ④ Name of entity and/or person responsible for management of personal data
    Novartis Pharma K.K.
4Personal data relating to medical practitioners such as physicians, dentists, veterinarians, pharmacists, clinical laboratory technicians, nurses, pharmacies/drug stores, medical science and pharmacology related researchers (iii)
  • ① Personal data items
    Name, gender, place of work, work address, work phone number, department, e-mail address, school name/graduation year, job classification, and other information necessary to achieve the Purpose of Use described in II above
  • ② Scope of entities and/or persons for joint use of personal data
    Sumitomo Dainippon Pharma Co., Ltd. and Eli Lilly Japan K.K.
  • ③ Purposes of use of personal data
    Purposes of use as described in II above (including similar purposes of use by entities and/or persons with which the data is used by means of joint use)
  • ④ Name of entity and/or person responsible for management of personal data
    Sumitomo Dainippon Pharma Co., Ltd.
    Eli Lilly Japan K.K.
5Personal data relating to patients, clinical study participants, etc.
  • ① Personal data items
    Information required for clinical study, safety management efforts, PMS operations, etc.
  • ② Scope of entities and/or persons for joint use of personal data
    Sumitomo Dainippon Pharma group companies worldwide engaged in research, development, manufacturing and sale of medicine and other pharmaceutical products
  • ③ Purposes of use of personal data
    Purposes of use as described in II above (including similar purposes of use by entities and/or persons with which the data is used by means of joint use)
  • ④ Name of entity and/or person responsible for management of personal data
    Sumitomo Dainippon Pharma Co., Ltd.
6Personal data on employees, etc. (including past employees, etc.) and their families (i)
  • ① Personal data items
    Name, gender, date of birth, date entered company, address, phone number, family information, academic history, affiliation, workplace, position, e-mail address, HR/personnel management status, and other information necessary to achieve the Purpose of Use described in II above
  • ② Scope of entities and/or persons for joint use of personal data
    Sumitomo Dainippon Pharma group companies worldwide
  • ③ Purposes of use of personal data
    Purposes of use as described in II above (including similar purposes of use by entities and/or persons with which the data is used by means of joint use)
  • ④ Name of entity and/or person responsible for management of personal data
    Sumitomo Dainippon Pharma Co., Ltd.
7Personal data on employees, etc. (including past employees, etc.) and their families (ii)
  • ① Personal data items
    Name, gender, date of birth, affiliation, position, workplace, employee classification, date entered company, educational background, attendance, disciplinary action, postal code, address, e-mail address, and other information necessary to the conducting of labor-management negotiations
  • ② Scope of entities and/or persons for joint use of personal data
    Sumitomo Dainippon Pharma Workers Union
  • ③ Purposes of use of personal data
    Purposes of use as described in II above (including similar purposes of use by entities and/or persons with which the data is used by means of joint use)
  • ④ Name of entity and/or person responsible for management of personal data
    Sumitomo Dainippon Pharma Co., Ltd.
8Personal data on employees, etc. (including past employees, etc.) and their families (iii)
  • ① Personal data items
    Name, gender, date of birth, date entered company, address, phone number, family information, academic history, affiliation, workplace, position, e-mail address, HR/personnel management status, medical checkup results (use only with Sumitomo Dainippon Pharma Health Insurance Society) and other information necessary to achieve the Purpose of Use described in II above
  • ② Scope of entities and/or persons for joint use of personal data
    Sumitomo Dainippon Pharma Health Insurance Society, Sumitomo Dainippon Pharma Pension Fund, Sumitomo Dainippon Pharma Employee Shareholding Association, and other organizations and entities connected to Sumitomo Dainippon Pharma Co., Ltd.
  • ③ Purposes of use of personal data
    Purposes of use as described in II above (including similar purposes of use by entities and/or persons with which the data is used by means of joint use)
  • ④ Name of entity and/or person responsible for management of personal data
    Sumitomo Dainippon Pharma Co., Ltd.

IV. Procedures for Requesting Disclosure and Other Actions

1Requests which can be processed

The Company will process the following requests from the Individual regarding Retained Personal Data by which such Individual can be identified in accordance with the Act on the Protection of Personal Information (hereinafter referred to as "the Act").

  • ① Requests for "notification of Purpose of Use" (requests under Article 27 (2) of the Act)
  • ② Requests for "disclosure" (requests under Article 28 (1) of the Act)
  • ③ Requests for "correction, supplement or deletion" (requests under Article 29 (1) of the Act)
  • ④ Requests for "discontinuation of use or erasure" (requests under Article 30 (1) of the Act)
  • ⑤ Requests for "discontinuation of provision to third parties" (requests under Article 30 (3) of the Act)
2Requests regarding Retained Personal Data registered on the Company website

For "Confirmation of Purpose of Use" for the Retained Personal Data registered, please visit the corresponding registration page on the website.

3Request Method

Requests should be made by filling out the designated forms and sending them to the address below , along with the necessary identification documentation.
Please note that requests made by phone, fax, e-mail or during face-to-face meetings cannot be accepted.
Please also note that requests must be made through the Personal Information/Individual Number Consultation Desk and cannot be accepted through a company's employee of other divisions who normally contacts with Individual.

Address
Personal Information/Individual Number Consultation Desk
Sumitomo Dainippon Pharma. Co., Ltd.
1-13-1 Kyobashi, Chuo-ku, Tokyo 104-8356

4Request Form

Please download and print out the file corresponding to the desired request from the links below.

  • ① Requests for "notification of Purpose of Use" → "Request for Notification of Purpose of Use of Retained Personal Data Form"

    WORD 54KBPDF 166KB

  • ② Requests for "disclosure" → "Request for Disclosure of Retained Personal Data Form"

    WORD 46KBPDF 165KB

  • ③ Requests for "correction, supplement or deletion" →"Request for Modification of Retained Personal Data Form"

    WORD 46KBPDF 167KB

  • ④ Requests for "discontinuation of use or erasure" → "Request for Discontinuation of Retained Personal Data Form"

    WORD 47KBPDF 167KB

  • ⑤ Requests for "discontinuation of provision to third parties" → "Request for Discontinuation of Retained Personal Data to Third parties Form"

    WORD 46KBPDF 165KB

5Documents necessary to confirm identity

Please prepare the documents listed in both ① and ② below. However, multiple copies are not required in the event multiple requests are being made concurrently.
These documents will be returned with the response letter.

  • ① One copy of "driver's license" or "passport"
  • ② One original of "Residency Register" or "Seal Registration Certificate" (issued within the previous three months)
6Requests by a representative

For requests being made by a representative, please contact separately the Personal Information/Individual Number Consultation Desk for information regarding the documents required to confirm status as a representative.

7Request processing fee

Requests for notification of Purpose of Use and Requests for disclosure both require ¥600 processing fee per request to be paid. Please include ¥600 worth of postal stamps with your request and application documents. No processing fees are charged for other requests.
Please note that this fee may change without notice. In addition, please understand the postal stamps received in payment will be used to send the response letter and thus they cannot be returned.

8Response

Responses to requests will be sent by registered mail or certified mail that requires identity confirmation of requester, to the address listed in the Residency Registry or Seal Registration Certificate provided.
Response letters will be sent within around one month of receiving requests, but please understand that responses may arrive later as circumstances dictate.

9When requests cannot be accepted

Please note that requests cannot be accepted in the following situations.

  • ① When request paperwork has been improperly prepared (due to omissions on request form, errors in entry method or content, missing documents, missing or unpaid fees, etc.)
  • ② When the identity of the Individual making the request cannot be confirmed, or when the Individual's representative cannot be confirmed as a representative
  • ③ When requests are made regarding Personal Information not classified as the Retained Personal Data
  • ④ For requests for "notification of Purpose of Use" relating to Retained Personal Data, 1) when the Purpose of Use for the Retained Persona Data is clear from the Purpose of Use publicized by the Company (as outlined in II-1 and II-2 above); 2) when the notification of Purpose of Use to the Individual or publication of the Purposes of Use may harm the life, body, property, or other rights or interests of the Individual or third parties; 3) when notification of Purpose of Use to the Individual or publication of the Purposes of Use may harm the Company's rights or legitimate interests; or 4) in the event that the Company needs to cooperate with a national organ or a local authority to execute affairs stipulated in laws and regulations, and notification of Purpose of Use to the Individual or publication of the Purposes of Use may interfere with the execution of such affairs.
  • ⑤ For requests for "disclosure" relating to Retained Personal Data, when disclosure 1) may harm the life, body, property, or other rights or interests of the Individual or third parties; 2) may adversely affect the Company's proper operations; or 3) may violate any other laws or regulations.
  • ⑥ For requests for "correction, supplement or deletion" relating to Retained Personal Data, when 1) request is not made for the reason the content of the Retained Personal Data which identifies the Individual is not accurate or 2) any other laws or regulations requires a specific procedure in regards to "correction, supplement or deletion" of such Retained Personal Data.
  • ⑦ For requests for "discontinuation of use or erasure" relating to the Retained Personal Data, when 1) request is not made for the reason the handling of the Retained Personal Data which identifies the Individual is in violation of Article 16 of the Act or the acquisition of the Retained Personal Data is made in violation of Article 17 of the Act; 2) the reason for the request cannot be found; or 3) a costly expenditure is required to fulfill the request of discontinuation or erasure relating to the Retained Personal Request or the fulfillment of such request is otherwise difficult and the necessary alternative for such request will be taken to protect the rights and interests of the Individual.
  • ⑧ For requests for "discontinuation of provision to third parties" for the Retained Personal Data, when 1) request is not made for the reason the provision of the Retained Personal Data which identifies the Individual is in violation of Article 23(1) of the Act; 2) the reason for the request cannot be found; or 3) a costly expenditure is required to fulfill the request of "discontinuation of provision to third parties" for the Retained Personal Data provision or the fulfillment of such request is otherwise difficult and the necessary alternative for such request will be taken to protect the rights and interests of the Individual.
  • * If you are a California resident, more information regarding your rights are here.

V. Complaints and Consultation Desk

For complaints or consultations regarding Personal Information/Individual Number, please contact the Company's Personal Information/Individual Number Consultation Desk.

Personal Information/Individual Number Consultation Desk

VI. Publication of Items Related to Retained Personal Data

  • ① Name of Company Handling Personal Information
    Sumitomo Dainippon Pharma. Co., Ltd.
  • ② Purposes of Use for all Retained Personal Data
    As outlined in II-1 and II-2 above
  • ③ Procedures for Requesting Disclosure and Other Actions in Regards to Retained Personal Data
    As outlined in IV above
  • ④ Company Contact for Complaints Regarding the Company's Handling of Retained Personal Data
    As outlined in V above
  • ⑤ Name of Authorized Personal Information Protection Organization and Complaint Resolution Contact
    The Company is a member of the Federation of Pharmaceutical Manufacturers' Association of Japan, which has been certified by the Minister of Health, Labour and Welfare as an Authorized Personal Information Protection Organization. This organization handles complaints and consultations regarding the handling of Personal Information by member companies.

    Personal Information/Protection Center Personal Information/Protection Center

    Website: http://www.fpmaj.gr.jp/ (in Japanese only)

VII. Provision of Anonymously Processed Information to Third Parties, etc.

The Company acquires Anonymously Processed Information prepared by a third party and provides it to different third parties on an ongoing basis. The Company takes necessary and appropriate measures for the security control of the Anonymously Processed Information, including prevention of any leakage or loss of, or damage to, the Anonymously Processed Information.
The items of information concerning an individual contained in the Anonymously Processed Information and the method of provision of the Anonymously Processed Information are as described below:

  • ① Items of information concerning an individual contained in Anonymously Processed Information
    The month and year of birth, age, sex, information relating to medical care (disease information, treatment information, examination information, information regarding hospital visits and admission to and discharge from hospitals, etc.), information regarding qualification for medical insurance (when insurance coverage started, whether the individual is a supporter or dependent, etc.), information regarding medical checkups (history and results, etc.)
  • ② Method of provision of Anonymously Processed Information
    Anonymously Processed Information is provided by any of the following methods:
  • 1. Upload to a server;
  • 2. Provision in an electronic or magnetic recording medium; or
  • 3. Sending by e-mail.

VIII. Explanation of Terms Used

1Personal Information

Personal Information is information relating to a living individual which falls under either of the following:

  • ① Information containing a name, date of birth, or other descriptions, etc. (meaning any and all matters (excluding an Individual Identification Code) stated, recorded or otherwise expressed using sound, motion or other methods in a document, drawing or electronic or magnetic record) whereby a specific individual can be identified (including those which can be readily collated with other information and thereby identify a specific individual); or
  • ② Information containing an Individual Identification Code.
2 Individual Identification Code

An "Individual Identification Code" is a set of characters, letters, numbers, symbols or other codes, as prescribed by Cabinet Order, that falls under either of the following:

  • ① A set of characters, letters, numbers, symbols or other codes indicating a description of the physical characteristics of a specific individual, converted into codes in order to be processed by a computer and by which such specific individual can be identified; or
  • ② A set of characters, letters, numbers, symbols or other codes assigned in relation to the use of services or the purchase of goods by an individual, or indicated or electronically or magnetically recorded on a card or document issued to an individual, each of which is uniquely assigned to or indicated or recorded for each individual to enable identification of that specific user or purchaser, or of a specific recipient of the issued card or document.
3 Individual Number

Individual Number is the number that is provided by transformation from a Resident Register Code and designated for the purpose of identifying an individual registered in the Residence Registry marked with such Resident Register Code.

4Specific Personal Information

Specific Personal Information is Personal Information that includes Individual Number (including and any number, symbol or other marking other than the Resident Register Code used in place of an Individual Number by which such Individual Number can be identified).

5Personal Information Database

Personal Information Databases is a set of information which includes Personal Information as set forth below:

  • ① a set of information structurally organized which enables certain Personal Information to be retrieved by using a computer; or,
  • ② in addition to what is listed in the preceding item, a set of information structurally organized which enables certain Personal Information to be easily retrieved (i.e. a set of information structurally organized which enables certain Personal Information to be easily retrieved by uniformly managing Personal Information included in it, including tables of contents, indexes and others which make retrieval.)
6Personal Data

Personal Data is the Personal Information which composes the Personal Information Database.

7Retained Personal Data

Retained Personal Data is the Personal Data that a business operator handling Personal Information has the authority to disclose; correct of contents, supplement or delete; discontinue use of; erase and discontinue provision to third parties except for the following Personal Data which may harm the public interest or other interests if its presence or absence is known or the Personal Data that will be deleted within the period of less than 6 months.

  • ① which, if its presence or absence is known, may harm the life, body, property, or other rights or interests of the Individual or third parties,
  • ② which, if its presence or absence is known, may incite or induce illegal or unjust act,
  • ③ which, if its presence or absence is known, may imperil national security, damage trust with other countries or international organizations, suffer disadvantage in negotiations with other countries or international organization,
  • ④ which, if its presence or absence is known, may hinder the prevention, crackdown or investigations of crimes, or the maintenance of any other public safety and order.
8Individual

Individual is a specific person identified by Personal Information or Individual Number.

9Anonymously Processed Information

Anonymously Processed Information is information relating to an individual that is produced by processing Personal Information so that it can neither identify a specific individual by taking actions prescribed in the following, nor be restored to the Personal Information:

  • ① Deleting a part of the descriptions, etc. contained in Personal Information (including replacing a part of the descriptions, etc. with other descriptions, etc. by a means with no regularity that allows restoration of the part of the descriptions, etc.; and
  • ② Deleting all Individual Identification Codes contained in Personal Information (including replacing the Individual Identification Codes with other descriptions, etc. by a means with no regularity that allows restoration of the Individual Identification Codes).