Skip to main content
  • Data Protection

Proposed Amendment to the Ministerial Ordinances of the Act on the Protection of Personal Information of Japan: Pseudonymously Processed Information (Part III)

In this Part III to this newsletter, we will cover the details of pseudonymously processed information.  Please refer to Part I for a general introduction of the proposed amendment to the ministerial ordinances of the Act on the Protection of Personal Information (“APPI”) and Part II for an overview of the data breach notification in the case of Data Breach Incidents. The 2020 Amendment introduced the concept of “pseudonymously processed information” (kamei kakou jouhou) which means personal information that has been processed in a manner ensuring that the information can no longer identify an individual without additional information.  Under the APPI, if information constitutes personal information, a business operator must uniformly comply with all obligations set forth in the APPI,...To read the full article, please see the PDF file

*Updated to reflect the March 24 (2021) amendment to the relative ministerial ordnances. (March 29, 2021)

It is also available in PDF.
Data Protection Newsletter (March16, 2021) (1.05 MB / 3 pages) Download PDF [1.05 MB]


石川 智也

Noriya advises national and international clients from various industries, with a focus on multi-national data protection law projects, such as drafting policy, data transfer agreements and out-sourcing agreements, IT compliance questions, and data breach issues. Since he has experience working with local counsel in more than 80 jurisdictions, he has in depth knowledge of the similarities and differences among data protection laws in many jurisdictions. He can provide his advice taking into account the difference of Japanese laws and other main data protection laws such as the GDPR, CCPA, and PIPL (China).