Name of business operator

SB Atwork Corp.

Name or job title of administrator (or representative), his or her department and contact information

Name of administrator: Person in charge of administration of personal information protection Wataru Itani
Job title: Senior Director of Management Base Division & CISO
Contact information: aw-contact@aw.softbank.co.jp

Purpose of Use of Personal Information

• 1.Matters to be put in accessible conditions for the individual related to retained personal data in the event that personal information is obtained from the individual concerned in writing, etc. (Including from the website or by e-mail. Hereinafter referred to as “in writing”)

  Category	Purpose of Use
  Customer information	Outsourcing service related to human resource administration Notification of information pertaining to services of safety and health management outsourcing service Provision of fringe benefit service Utilization of analysis and results of analysis for improving fringe benefit service
  Shareholder information	Notification service
  Business partner information	Order receiving/placing service Claim/payment service
  Employee information	Labor management Temporary staffer contract management Provision of fringe benefit service Utilization of analysis and results of analysis for improving fringe benefit service

• 2.Purpose of use in the event that personal information is directly obtained other than in writing from the individual concerned

  Category	Purpose of Use
  Customer information	Outsourcing service related to human resource administration Notification of information pertaining to services of safety and health management outsourcing service
  Employee information	Provision of fringe benefit service Utilization of analysis and results of analysis for improving fringe benefit service

• 3.Purpose of use in the event that personal information is indirectly obtained 

  Category	Purpose of Use
  Customer information	Outsourcing service related to human resource administration Safety and health management outsourcing service
  Employee information	Provision of fringe benefit service Utilization of analysis and results of analysis for improving fringe benefit service

Matters pertaining to cases where personal information is to be provided to third parties

SB Atwork shall not provide personal information to third parties except in the following cases.

• When the customer’s consent has been obtained
• When it is required by laws and ordinances

Outsourcing of personal information handling

SB Atwork outsources the performance of some of its services to outside contractors in order to provide better services to customers. SB Atwork may provide personal information to the service outsourcing agent. In that case, SB Atwork selects an outsourcing agent deemed to be handling personal information appropriately and takes the necessary measures to prevent the leakage of personal information of customers such as by including in agreements provisions for appropriate management of personal information and obligation of confidentiality, and implement proper management.

Disclosure, correction/deletion, and right to refuse use or provision of personal information

Personal information that is subject to disclosure refers to personal information comprising a collection of information systematically organized for which SB Atwork has the right to respond to all requests by the individual concerned for disclosure, correction of information content, addition or deletion, discontinuation of use, erasure and discontinuation of provision to a third party.

• (1) Disclosure of personal information that is subject to disclosure (including records of provision to third parties)

  SB Atwork shall disclose personal information that is subject to disclosure to the individual concerned without delay when it is requested by the individual concerned to disclose such personal information. SB Atwork shall also notify the individual concerned when personally identifiable personal information does not exist.

  • a) When there is a risk of harm to the life, body, property or other rights or interests of the individual concerned or a third party
  • b) When there is a risk of material impediment to the proper execution of business of the concerned business operator
  • c) When it violates laws and ordinances

  (2) Correction, addition or deletion of personal information that is subject to disclosure

  When SB Atwork is requested to correct, add or delete personal information that is subject to disclosure on the grounds that the details are false as a result of disclosure, SB Atwork shall conduct the necessary investigation without delay and correct, etc. the personal information that is subject to disclosure based on such results, as well as notify the individual concerned thereof without delay (including the contents of correction, etc.) after making corrections, etc.

  (3) Right to refuse use or provision of personal information that is subject to disclosure

  When SB Atwork is requested by the individual concerned to discontinue the use, erase or discontinue provision to a third party of personal information that is subject to disclosure, SB Atwork shall respond to such request. SB Atwork shall also notify the individual concerned without delay after taking such measures. However, when any of the circumstances mentioned in the proviso in a) to c) of (1) applies, SB Atwork is unable to respond to such request, and in that case, shall notify the individual concerned to that effect and shall explain the reason without delay.

  (4) Notification of purpose of use, disclosure, correction of content, addition or deletion, discontinuation of use, erasure

  When the customer or job seeker requests notification of the purpose of use, disclosure, correction of the content, addition or deletion, discontinuation of use, and erasure, among other things, of personal information of the individual concerned obtained by SB Atwork, the customer or job seeker is required to make such request by mail to the following Personal Information Complaint and Consultation Counter after attaching identification documents in the prescribed form.
  Since the prescribed form will be sent to you by mail, please request the Personal Information Complaint and Consultation Counter by e-mail, telephone or mail.

Voluntariness of provision of personal information

Whether or not the customer provides personal information to SB Atwork is voluntary. However, if SB Atwork does not receive the necessary information, it may not be able to appropriately provide certain services.

Obtaining personal information by means that are difficult to recognize by the individual concerned

Cookies are used to enable the customer to view SB Atwork’s website more conveniently when the customer revisits the website. Cookies do not violate the customer’s privacy and do not have adverse effects on the customer’s computer.

All personal information input in SB Atwork’s website is encrypted using SSL (Secure Sockets Layer) technology. In addition, measures are taken to protect information within the website, including the installation of a firewall. However, it should be noted that security cannot be guaranteed completely due to the nature of Internet communication.

Matters concerning security control measures

SB Atwork takes the following security control measures regarding personal information that we have obtained or are attempting to obtain.

(1) Formulation of basic policy

To ensure the proper handling of personal information, we have formulated and published “Personal Information Protection Policy”.

(2) Establishing discipline over the handling of personal information

We have established and thoroughly enforced regulations regarding the protection of personal information, including handling methods, responsible persons, persons in charge, and their duties.

(3) Organizational security control measures

In addition to appointing a person responsible for the handling of personal information, we clarify the employees who handle personal information and the scope of personal information handled by such employees, and have a system in place for reporting to the person responsible in the event that a violation of the law or regulations is detected or any sign of such a violation is detected. We conduct regular self-inspections and internal audits on the handling of personal information.

(4) Personnel security control measures

We regularly educate and train our employees on points to keep in mind when handling personal information. Confidentiality regarding personal information is included in the Rules of Employment.

(5) Physical security control measures

In areas where personal information is handled, we contrrol the entry/exit of employees and restrict the devices they bring into the office to prevent unauthorized persons from viewing personal information. We take measures to prevent theft or loss of equipments, electronic media and documents that handle personal information, and to ensure that personal information is not easily revealed when such equipments, electronic media, etc. are carried, including when moving within the floor.

(6) Technical security control measures

Access controls are in place to limit the scope of persons in charge and the personal information databases handled. A mechanism is in place to protect the information system that handle personal information from unauthorized external access and unauthorized software.

(7) Understanding the external environment

When personal information is provided to or entrusted to a third party outside of Japan, it will be provided after we confirm that the third party has appropriate security control measures in place, or, after notifying the individual of the below and obtaining the individual’s consent.

・Name of the third party country.

・Information on the personal information protection system in that country.

・Information on the security control measures taken by the third party.

Name of business operator

SB Atwork Corp.

Compliance with relevant laws and ordinances and guidelines

SB Atwork shall properly handle specific personal information by complying with the Act on the Use of Numbers to Identify a Specific Individual in the Administrative Procedure, the Act on the Protection of Personal Information, and the Guidelines for Proper Handling of Specific Personal Information (for business operators).

Matters concerning security control measures

SB Atwork has separately formulated Rules for the Handling of Specific Personal Information as a security control measure for specific personal information.

Scope of personal information

“Personal information” in this policy means information which can identify a specific individual provided either directly by the job applicant who applied to SB Atwork in SB Atwork’s recruitment activities by telecommunication, floppy disk, printed material, magneto-optical disk, regardless of the medium or means, or indirectly by the staffing agency, temp-staff agency or other agencies. Specifically, it refers to the following information.

• Entry of name, age, gender, date of birth, telephone number, e-mail address, professional career and other information
• Call history between SB Atwork and the job applicant for purpose of mailing, e-mail and other recruitment activities
• Information other than the foregoing that can be easily matched with other information and therefore leads to the identification of specific individuals

Non-use other than for the intended purpose

SB Atwork shall use the obtained personal information only for the purpose of SB Atwork’s recruitment activities and appropriate employment management after recruitment, regardless of the channel by which such information was obtained, including online and offline channels. SB Atwork shall not use the obtained personal information for any other purposes.

Matters concerning security control measures

SB Atwork takes the appropriate security control measures on the organizational, personnel, physical and technical fronts for the purpose of preventing risks such as unauthorized access, loss, alteration and leakage by understanding the risks of personal information held and keeping such information accurate and up-to-date.

SB Atwork shall not disclose the obtained personal information to a third party except in the following cases.

• When the prior consent of the individual concerned has been obtained
• When provision of personal information is requested by legal bodies such as the police, prosecutor and court
• When it is required by laws and ordinances
• When provision of personal information is necessary for the protection of the life, body or property of a person and it is difficult to obtain the consent of the individual concerned

Disclosure, correction or deletion of personal information

SB Atwork works to always keep the obtained personal information accurate and up-to-date. When the disclosure, correction or deletion of personal information is requested, the response is determined according to the following categories after strict identity verification.

• Personal information of those in the middle of recruitment activities

  SB Atwork shall agree to disclose, correct or delete personal information to a reasonable extent as requested by the individual concerned. However, SB Atwork shall not agree to disclose information pertaining to decisions on hiring since the disclosure thereof may have be a material impediment to the proper implementation of business.

• Personal information of those who were not hired

  SB Atwork shall destroy and delete such information by an appropriate method after two months from the completion of recruitment activities.