This English version is provided for convenience. In the event of any inconsistency between the Japanese and English versions, the Japanese version shall prevail.
Okuizumi Administrative Procedures Office (the “Office”) recognizes the importance of personal information and confidential information handled in the course of its professional activities.
The Office handles personal information in accordance with Japan’s Act on the Protection of Personal Information, other applicable laws and regulations, the statutory duty of confidentiality applicable to Administrative Procedures Legal Specialists, and the professional rules of the relevant professional associations.
1. Basic Policy
The Office provides services relating to healthcare and life sciences, administrative procedures, business and regulatory support, the operation of healthcare institutions, professional issues faced by healthcare professionals, and support for individuals and families facing illness or disability.
In providing these services, the Office may handle highly sensitive information, including medical histories, clinical and dispensing information, test results, information concerning disabilities, long-term care and welfare, family relationships, employment matters, and other confidential information.
Considering the nature of such information and its potential impact on the rights and interests of individuals, the Office seeks to:
- clearly define the purposes of use;
- collect only information reasonably necessary for the relevant purpose;
- restrict access to information;
- implement appropriate security measures; and
- comply with its professional duties of confidentiality.
Information relating to deceased persons will also be handled with due regard for the rights and interests of their families and other relevant persons and for the Office’s professional confidentiality obligations.
2. Scope of This Policy
This Policy applies to personal information and related information collected by the Office concerning:
- visitors to the Office’s website;
- persons making inquiries or requesting consultations;
- clients and prospective clients;
- patients, family members, officers, employees, healthcare professionals, and other persons involved in a consultation or matter;
- persons making referrals, collaborating professionals, business partners, and representatives of relevant institutions; and
- persons communicating with the Office through seminars, meetings, research, expert interviews, or other professional activities.
Unless otherwise stated, terms used in this Policy have the meanings assigned to them under Japan’s Act on the Protection of Personal Information.
3. Categories of Information Collected
The Office may collect the following information to the extent reasonably necessary for its activities.
3.1 Identification and Contact Information
Name, date of birth, address, telephone number, email address, employer or affiliated organization, department, position, professional qualifications, identification documents, and other information necessary for identification and communication.
3.2 Information Required for Preliminary Review and Conflict Checks
A summary of the proposed consultation, the names of relevant companies, healthcare institutions, long-term care providers, public authorities, products, services, professionals, and other parties, the identity of the referring person, the relationship between the person making the inquiry and the patient or other relevant person, and information concerning existing or previous engagements.
3.3 Information Required to Perform Professional Services
Contracts, administrative documents, medical records, referral letters, examination and test results, prescription and dispensing information, long-term care records, disability and welfare documents, employment and payroll records, emails, photographs, audio or video recordings, factual chronologies, family information, and information relating to assets, contracts, businesses, and organizational operations.
3.4 Special Care-Required Personal Information
Medical history; physical, intellectual, or mental disability; health examination and test results; information concerning medical care, treatment, prescriptions, dispensing, medication, long-term care, and health guidance; and other information categorized as special care-required personal information under Japanese law.
3.5 Contract, Billing, and Payment Information
Engagement terms, billing information, bank account information, payment status, qualified invoice issuer registration numbers, and other information required for accounting and tax purposes.
3.6 Website Usage Information
IP address, cookies and similar identifiers, device, browser and operating-system information, pages viewed, date and time of access, referring sources, and information concerning interactions with the website.
3.7 Communications and Meeting Records
Emails, contact-form submissions, chat messages, online meetings, and other communications.
Where the Office records audio or video of a meeting, the Office will, except where otherwise permitted by law, normally provide prior notice and obtain any required consent.
4. Methods of Collection
The Office may collect information through:
- inquiries, consultation requests, agreements, document submissions, and meetings with the individual;
- family members, representatives, referring persons, healthcare institutions, companies, public authorities, and other relevant parties acting with the individual’s consent or other lawful authority;
- publicly available sources, including public registries, corporate records, websites, and professional directories;
- website analytics; and
- lawful notices, inquiries, or disclosures from public authorities or other institutions.
The Office will not obtain personal information by deception or other improper means.
When providing information concerning another individual, the person providing the information should obtain any consent or authority required by law. The Office may request confirmation of such consent or authority where appropriate.
5. Purposes of Use
The Office may use personal information for the following purposes:
- responding to inquiries and arranging meetings;
- obtaining an initial understanding of the matter;
- determining whether the Office can accept the matter and conducting conflict-of-interest checks;
- verifying identity, entering into agreements, and identifying the client;
- performing administrative procedures services, healthcare and life-sciences advisory services, factual organization, document preparation, administrative consultation preparation, and other agreed services;
- communicating and completing procedures with public authorities, healthcare institutions, long-term care or welfare organizations, companies, and other relevant institutions;
- coordinating, with appropriate consent or other lawful authority, with physicians, attorneys, patent attorneys, judicial scriveners, tax accountants, labor and social security attorneys, and other professionals;
- preparing and maintaining contracts, invoices, payment records, accounting and tax records, and professional records;
- providing progress reports, professional communications, and appropriate follow-up;
- responding to complaints, disputes, accidents, misuse, fraud, or information-security incidents;
- complying with laws, professional obligations, and lawful requests from public authorities;
- improving the quality of the Office’s services and website;
- creating and using statistical information that does not identify individuals;
- providing information regarding legal or regulatory developments, seminars, and services, provided that such communications will be discontinued within a reasonable period after an opt-out request; and
- purposes incidental or closely related to the purposes listed above.
Even where an inquiry does not result in an engagement, the Office may retain limited identifying information and response records for a reasonable period for conflict checks, prevention of duplicate consultations, recordkeeping, and dispute prevention.
Where the Office changes a purpose of use, the change will be limited to a purpose reasonably related to the original purpose, and the revised purpose will be notified to the individual or made publicly available.
6. Special Care-Required Personal Information
Except where otherwise permitted by law, the Office will obtain the individual’s prior consent before acquiring special care-required personal information, including medical history, clinical and dispensing information, disability information, and test results.
The Office will collect such information only to the extent reasonably required for the relevant matter and will apply appropriate access and disclosure restrictions.
Where information concerning a patient or another person is provided by a family member or other person, the Office will consider the individual’s wishes and decision-making capacity, the urgency of the circumstances, the authority of the person providing the information, and the purpose for which the information is required.
7. Individual Numbers and Specific Personal Information
The Office will not acquire or use Individual Numbers, commonly known as “My Number,” or Specific Personal Information beyond the purposes permitted by the Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures and other applicable laws.
Where an Individual Number is not required, the Office may ask that the number be masked before documents are submitted.
8. Disclosure to Third Parties
The Office will not provide personal data to a third party without the individual’s prior consent, except where:
- disclosure is required or permitted by law;
- disclosure is necessary to protect a person’s life, physical safety, or property and obtaining consent is difficult;
- disclosure is particularly necessary to improve public health or promote the sound development of children and obtaining consent is difficult;
- cooperation with a national or local government authority is necessary for the performance of duties prescribed by law, and obtaining consent may interfere with those duties; or
- disclosure is otherwise permitted under applicable law.
Where information is to be shared with physicians, attorneys, other professionals, healthcare institutions, public authorities, or other relevant parties, the Office will, except where otherwise permitted by law, explain the purpose, scope, and recipient of the disclosure and obtain any required consent.
The Office does not provide personal data to third parties using an opt-out arrangement.
If the Office introduces joint use of personal data, it will provide advance notice or public disclosure of the categories of information, the scope of joint users, the purposes of use, and the person responsible for management.
9. Service Providers
The Office may engage external service providers to perform services necessary for the purposes described in this Policy, including:
- website hosting and maintenance;
- email, cloud storage, and online meeting services;
- electronic contracts, invoicing, accounting, and payment services;
- printing, postal delivery, courier, and document-destruction services;
- information-system maintenance, security, and backup; and
- other services necessary for the operation of the Office.
The Office selects service providers after considering the nature of the information, the services to be provided, the provider’s security measures, and the relevant contractual terms, and exercises appropriate supervision as required by law.
10. Processing Outside Japan
Some cloud, email, online meeting, analytics, and other services used by the Office may involve storage or processing by providers located outside Japan or on servers located outside Japan.
Where applicable, the Office will consider the relevant foreign data-protection laws, the provider’s security measures and contractual terms, and will provide information, obtain consent, or take other measures required under applicable law.
11. Generative AI and Other External Information-Processing Services
Where the Office uses generative AI or another external information-processing service, it will consider applicable law, its professional duty of confidentiality, the service terms, whether submitted information may be retained or used for model training, and the service’s security controls.
As a general rule, the Office will not unnecessarily enter directly identifying information, special care-required personal information, trade secrets, or other confidential information into an external service.
Where the use of such information is necessary for the performance of professional services, the Office will consider appropriate measures, including anonymization or pseudonymization, suitable contractual and technical settings, consent, and other lawful safeguards.
12. Cookies and Website Analytics
The Office’s website may use cookies and similar technologies to understand website usage and improve the website.
The Office may use Google Analytics, a service provided by Google LLC. Through Google Analytics, the following information may be transmitted to Google LLC:
- cookies and other online identifiers;
- IP addresses;
- device, browser, and operating-system information;
- pages viewed, dates and times of access, and referring sources; and
- information concerning interactions with the website.
This information is used for website analytics, service improvement, security, and prevention of unauthorized access. The Office does not use information obtained through Google Analytics for the purpose of directly identifying individual users.
For information on Google’s handling of information, please refer to the Google Analytics Terms of Service and Google Privacy Policy.
Users may disable cookies through their browser settings or use an opt-out function provided by Google. Disabling cookies may affect the operation of certain website functions.
External Transmission Notice
Recipient: Google LLC
Information transmitted: cookie identifiers, IP address, device and browser information, browsing history, and interaction information
Purpose: website analytics, website improvement, and security
13. Security Measures
The Office implements necessary and appropriate organizational, personnel, physical, and technical safeguards according to the nature and circumstances of the information handled.
These measures may include:
13.1 Organizational Measures
Designation of a person responsible for personal information, internal handling procedures, incident-response procedures, periodic review, and monitoring of handling practices.
13.2 Personnel Measures
Training and guidance concerning confidentiality and personal-information handling, and appropriate supervision of staff and assistants.
13.3 Physical Measures
Secure storage of documents, devices, and recording media; restrictions on removal; locked storage; and secure destruction using methods designed to prevent restoration.
13.4 Technical Measures
Access controls, appropriate authentication, password management, multi-factor authentication where appropriate, encryption of communications and stored information, malware and unauthorized-access prevention, software updates, logging, and backups.
13.5 Service Provider and Foreign Environment Controls
Review of service-provider security measures and applicable foreign data-protection environments, together with appropriate contractual and supervisory measures.
Upon request, the Office will provide a general explanation of its security measures, except where disclosure is restricted by law or could itself create a security risk.
14. Retention and Disposal
The Office retains personal information only for the period reasonably necessary to accomplish the relevant purposes and to satisfy applicable legal, professional, contractual, accounting, tax, and dispute-prevention requirements.
When retention is no longer necessary, the Office will delete or securely dispose of the information using appropriate methods, including shredding paper documents and securely deleting electronic data.
Information contained in backups will be deleted on a reasonable schedule to the extent technically practicable.
15. Requests Concerning Retained Personal Data
Subject to applicable law, an individual may request:
- notification of the purposes of use;
- disclosure of retained personal data;
- correction, addition, or deletion;
- suspension of use or erasure;
- suspension of third-party provision; and
- disclosure of records concerning third-party provision.
Requests should be submitted through the contact form on the Office’s website.
The Office will verify the identity and authority of the requesting person and respond within a reasonable period and scope in accordance with applicable law.
The Office may request identification documents or other information necessary to verify identity. If postage or other actual costs will be charged, the Office will provide advance notice.
The Office may decline all or part of a request where permitted by law. Where reasonably possible, the Office will explain the reason for its decision.
16. Data Breach and Other Incidents
If personal data is leaked, lost, damaged, improperly accessed, or otherwise compromised, or if such an incident is reasonably suspected, the Office will investigate the circumstances and affected scope, take steps to prevent further harm, identify the cause, and implement appropriate corrective measures.
Where required by law, the Office will report the incident to the Personal Information Protection Commission of Japan or another relevant authority and notify affected individuals.
17. Minors and Persons Requiring Assistance in Decision-Making
Where personal information concerns a minor, an adult ward, or another person who may have difficulty providing fully informed instructions, the Office will consider whether consent or participation by a parent, guardian, adult guardian, or other appropriate person is required.
The Office will nevertheless respect the wishes, interests, and rights of the individual and will seek to provide explanations and confirm the individual’s wishes in a manner appropriate to the individual’s understanding and circumstances.
18. Case Studies, Research, Education, and Publications
Where information relating to a matter is used in a website article, social media post, seminar, training material, academic publication, research activity, case study, or other communication, the Office will either:
- sufficiently anonymize the information so that the relevant individual or organization cannot reasonably be identified; or
- obtain separate, express consent.
The Office will not publish information in a manner that violates its professional duty of confidentiality or unjustifiably harms the rights or interests of a client or another relevant person.
19. Links to External Websites
The Office’s website may contain links to external websites. The handling of personal information on an external website is governed by the policy of the operator of that website.
20. Changes to This Policy
The Office may revise this Policy in response to changes in law, professional services, information systems, or information-handling practices.
Material changes will be announced by publication on the Office’s website or by another appropriate method.
In the event of any inconsistency between the Japanese and English versions, the Japanese version shall prevail.
21. Contact
For inquiries, complaints, or requests concerning personal information, including requests for disclosure, correction, or suspension of use, please contact the Office through the contact form on its website.
Personal Information Handling Business Operator
Okuizumi Administrative Procedures Office
Representative and Person Responsible for Personal Information Handling
Kaoru Okuizumi
Administrative Procedures Legal Specialist
Contact Method
Contact form on the Office’s website
Effective date: [2026/2/15]
Last revised: [2026/7/14]