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Data Incidents Subject to Reporting under the Amended Enforcement Rules for the Act on the Protection of Personal Information

The Amendment to Part of Enforcement Rules for the Act on the Protection of Personal Information (Rules of the Personal Information Protection Commission No. 5) (the “Amended Enforcement Rules”) was promulgated along with the Amendment to the Relevant Guidelines (the “Amended Guidelines”) on December 27, 2023. Both amendments were open for public comment from September 14, 2023 to December 27, 2023 (the “Public Comments”). The Amended Enforcement Rules will come into force on April 1, 2024 (the “Enforcement Date”). The Amended Enforcement Rules expand the scope of data breach incidents that must be reported to the Personal Information Protection Commission of Japan (the “PPC”) and notified to the affected data subjects.  Also, the Amended Guidelines provide interpretations of the expanded...To read the full article, please see the PDF file

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河合 優子

Yuko has continuously advised a multitude of global and prominent companies on data privacy issues, including data breaches and security incidents, data privacy structures in the design of their business, cross-border data transfers, global data compliance, data governance and medical/genome data. During her many years of professional practice as a corporate lawyer, she has also conducted transactional and advisory work in cross-border and domestic M&As, joint ventures and business alliances, and general corporate matters for listed companies.
Her recent major books include, “Amendments to the Act on the Protection of Personal Information in 2020 and Practical Approaches” (Shojihomu, 2022) and “Corpus Juris Series - Personal Information Protection Legislation (Global)” (Shojihomu, 2020).
She has served as a member of Committee for Promoting Open-data in Public Transportation Sectors, of Ministry of Land, Infrastructure, Transport and Tourism of Japan, as well as a member of Tokyo Data Platform Case Study Project Review Board, Bureau of Digital Services, Tokyo Metropolitan Government.