Handling of Personal Information

Updated on March 9, 2023

Privacy Policy

Recognizing the importance of personal information and observing the Act on the Protection of Personal Information (hereinafter referred to as “the Act”), and other laws and regulations, Chugai Pharmaceutical Co., Ltd. (hereinafter referred to as “the Company”) shall establish the Privacy Policy (hereinafter referred to as “the Policy”) as a guideline for appropriate control and protection of personal information.

  • Acquisition of Personal Information
    The Company will acquire personal information in an appropriate and fair manner within the business scope of the Company.
  • Announcement of the Purposes of Using Personal Information
    The Company will announce on its website the purposes of using personal information whenever it intends to collect and acquire personal information.
    For purposes of using personal information, please see Purposes of Using Personal Information
    The Company will use personal information within the scope of the purposes announced.
  • Provision of Personal Data
    The Company will observe the Act when providing personal data to a third party.
  • Handling of Personal Data by a Subcontractor
    In case of consigning handling of personal data to subcontractors, the Company will select an entity that is deemed as handling personal data appropriately and manage the contracted entity necessarily and appropriately so that personal data is under safe control.
  • Shared Use of Personal Data
    In the case of shared use of personal data with other specified entities, the fact will be announced beforehand on the website of the Company.
    For shared use, please see Joint Use of Personal Data
  • Safe Control of Personal Data
    The Company will provide appropriately safety management measures to protect personal data against being divulged, lost, damaged and falsified.
    For safety management measures, please see “Safety Management Measures”.
  • Disclosure of Personal Data
    When a request is received from an individual or his/her legally authorized representatives regarding notice of the purpose of use, disclosure, amendment and suspension of use, etc. of his/her personal data possessed by the Company, the Company will respond to such request in accordance with laws and regulations.
    For request of disclosure, etc., please see Personal Data Possessed by Chugai Pharmaceuticals
  • Internal Organization for Protection of Personal Information
    The Company will control and protect personal information appropriately by appointing a Supervisor in Charge of Personal Information Protection and establishing a Personal Information Protection Promotion Secretariat within the Company.
  • Internal Rules and Education on Protection of Personal Information
    The Company shall establish the internal rules in order to implement the Policy, which will be thoroughly disseminated, understood and observed by all of its officers and employees through continuous education and training.

The Policy is subject to change without notice in order to enhance the Company’s personal information protection system.

Purposes of Using Personal Information

The Company will use personal information for the manufacturing and sales of its medical products and medical devices.

  1. Purposes of Using Personal Information of Medical-Related Persons Including Doctors, Pharmacists, Pharmacies and Researchers
    • Provision and collection of information for appropriate use of medical products and medical devices
    • Provision and collection of information on quality, safety and efficacy of medical products and medical devices
    • Acquisition, communication and provision of vendors of biological-origin products
    • Provision of information such as urgent safety information and a package insert after modification
    • Surveys and analyses of how a medical product or a medical device is used and the needs of users, etc.
    • Communication and provision of information on side-effects occurred and on product recall
    • Medical and pharmaceutical surveys, studies and development
    • Provision and collection of medical and academic information
    • Authentication of members of an internet site for medical-related persons and communication to them
    • Request and execution of a clinical test and a post-marketing survey, etc.
    • Securing safety of medical products and medical devices
    • Exchange of safety information with Chugai Group companies outside of Japan
    • Notification and reporting to governmental agencies and/or member organizations
    • Collection and control of information on processing payments
    • Provision and disclosure of information on payment to medical-related persons and researchers, for the purpose of securing transparency
    • Others including smooth and appropriate communication with medical-related personnel and researchers
  2. Purposes of Using Personal Information of Personnel of Business Partners and Competitors
    • Communication with personnel of business partners, outside contracted vendors and competitors
    • Contribution of articles to magazines
    • Communication on our products and sales policies
    • Understanding of credit and credit exposure management information
    • Others including smooth and appropriate communication with personnel of business partners and competitors
  3. Purposes of Using Personal Information of Various Suppliers
    • Exchange and communication of technical and facility information
    • Others including smooth and appropriate communication with various suppliers
  4. Purposes of Using Personal Information of Shareholders of the Company
    • Performing obligations as specified in the Companies Act and response to executing shareholders’ rights on behalf of the shareholders of the Company
    • Distribution of a business report and other handouts
    • Others including smooth and appropriate communication with shareholders of the Company
  5. Purposes of Using Personal Information of Persons in relation to activities of Corporate Communications Department of the Company
    • Releasing information to investors and media and distribution of event information
    • Examination, investigation and response regarding consultations and reports
    • Public relation activities both within and outside of the Company
    • Website membership authentication for journalists, member contact, and confirmation of access status
    • Others including smooth and appropriate communication with persons in relation to the department
  6. Purposes of Using Personal Information of Patients and their Families
    • Provision to healthcare professionals and collection of information for appropriate use of medical products and medical devices
    • Provision of information, such as the experiences of patients and their families, to promote disease awareness
    • Survey and analysis of how a medical product or a medical device is used and the needs of users, etc.
  7. Purpose of Using Personal Information of Participants/Research Subjects in Research and Development Activities (including Clinical Trials, Clinical Research, etc.)
    • Contact and measures for health injury
    • Research contributing to health promotion and consideration of development of medical products and medical devices, etc.
  8. Purpose of Using Personal Information of Participants in Various Events, such as Medical Forums and Seminars
    • Announcements and management of medical-related forums, seminars and various events for the general public
  9. Purpose of Using Personal Information of Visitors to the Company’s Facilities
    • Access control of visitors and factory tour guests
  10. Purposes of Using Personal Information of Users of the Company’s Contact
    (All telephone conversations will be recorded for the following purposes.)
    • Understanding, examination, investigation, and response to details of consultations and communications
    • Enhancing skills of telephone operators and realization of better customer service
    • Feed-back of details of consultations and responses to medical-information staff of the Company
    • Communication and provision of medical information to product manufacturers and distributors
    • Others including smooth and appropriate communication with users of the Company’s contact
  11. Purposes of Using Personal Information of Applicants and Recruitment Candidates of the Company
    • Examination and Communication of decisions for success/failure of applicants
    • Recruitment selection operations (selection process and communication of results; also includes use for the future verification and analysis of recruitment selection activities and as reference for recruitment selection activities in the future)
    • Others including smooth and appropriate communication with the applicants and recruitment candidates
  12. Purposes of Using Personal Information of Family Members of Current Employees and Former Employees of the Company
    • Employment control, provision and communication of welfare programs and other HR-related services to current employees
    • Issuance and communication of various certificates
    • Creation, management and maintenance of Shayukai member list
    • Reports, consultation and inquiries related to the management of Shayukai

    The purpose of use in this Section 12 shall also apply to personal information concerning former employees, etc. of Chugai Group companies in Japan, except for “issuance and communication of various certificates.”

  13. Purposes of Using Personal Information related to genome data that can be authenticated
    • Implementation of the discovery research and the clinical research, etc. to create efficacy and safety information of medicinal products and medical devices
  14. Purposes of Using Specific Personal Information of medical-related personnel, corporation in the business relationship and related entities
    • Submission statutory reports to the income tax with regard to payment of remuneration, etc.to the tax office

Provision of Personal Data to a Third Party

The Company may provide personal data on medical-related persons to other medical-related persons, our affiliated companies and related entities, or business partners in order to achieve “Purposes of Using Personal Information”. If an individual so requests, the Company shall immediately suspend providing his/her personal data to third parties.
Please see Procedures for Treatment of an Application for Disclosure of Personal Data.

  1. Categories of Personal Data to be Provided to a Third Party
    Individual’s name, e-mail address, institution’s name, address and phone number of work site, type of diagnosis and treatment in charge, department, job title, job position, year of graduation, university graduated from, year of starting as a practitioner, membership to academic associations, membership in doctor associations, sales performance, prescribing information.
  2. Method of Providing Personal Data to a Third Party
    Oral, in writing, electronic communication etc.

Joint Use of Personal Data

The Company uses personal data as indicated below, possession with specified parties.

  1. Joint Use of Personal Data with Nihon Ultmarc Inc.
    1. The company uses Personal Data stored in the medical data base (MDB) managed and stored by Nihon Ultmarc, Inc. with specified companies.
      Please see the website of Nihon Ultmarc Inc., for categories of personal data subject to shared use, scope of shared users, purposes of shared use and name of the entity responsible for the management of personal data.
  2. Joint Use of Personal Data with Chugai Group companies
    1. Personal Data of medical-related personnel such as doctors, dentists, pharmacists
      1. Scope of Joint Users
      2. Categories of Personal Data subject to Joint Use
        • Name / gender / name, address, phone number and e-mail address of work-site (medical institution) / area of medical treatment in charge / department / job title / position / year of graduation / graduated school,.
      3. Purposes of Joint Use
      4. Name of the Entity Responsible for the Management of Personal Data
        • Chugai Pharmaceutical Co., Ltd.
    2. Personal Data of Business Partners, Competitors and Clients, etc.
      1. Scope of Joint Users
      2. Categories of Personal Data subject to Joint Use
        • Name / name, address, phone number and email address of work site / department / job title / position
      3. Purposes of Joint Use
      4. Name of the Entity Responsible for the Management of Personal Data
        • Chugai Pharmaceutical Co., Ltd.
    3. Genome Data acquired by clinical research, etc.
      1. Scope of Joint Users
      2. Categories of Personal Data subject to Joint Use
        • Genome data that can identify the data subjects
      3. Purposes of Joint Use
      4. Name of the Entity Responsible for the Management of Personal Data
        • Chugai Pharmaceutical Co., Ltd.
    4. Purpose of using personal information on former employees of our company and Chugai Group companies in Japan
      1. Scope of Joint Users
      2. Categories of Personal Data subject to Joint Use
        • Name / gender / date of birth / name of work site / e-mail address / year of joining the company / profiles such as self-introduction :/ work history / employee number at the time of employment
      3. Purposes of Joint Use
        • For the purpose of achievement of the items described in 12. of “Purposes of Using Personal Information”
      4. Name of the Entity Responsible for the Management of Personal Data
        • Chugai Pharmaceutical Co., Ltd.
  3. Joint Use of Personal Data with Chugai Pharmaceutical Health Insurance Society and Chugai Group companies in Japan
    1. Personal Data of Family Members of Current Employees and Former Employees of the Company
      1. Scope of Joint Users
      2. Categories of Personal Data subject to Joint Use
        • Address, name, gender, date of birth, age, relationship, date of certification as dependent, date of removal as dependent
      3. Purposes of Joint Use
      4. Name of the Entity Responsible for the Management of Personal Data
        • Chugai Pharmaceutical Co., Ltd.
  4. Joint use with entities that have business relationship with the Company, such as joint promotion of drugs (“Entities”)
    1. Personal Data of medical professionals such as doctors, dentists, and pharmacists held by Entities
      1. Scope of Joint Users
        • Novartis Pharma K.K.
      2. Categories of Personal Data subject to Joint Use
        • Address, telephone number, e-mail address, information on the use of the target product, contents of responses to studies based on questionnaires about the target product, number of patients in possession, status of adoption of the target product, intention to prescribe (treatment policy), participation in lectures, etc.
      3. Purposes of Joint Use
      4. Name of the Entity Responsible for the Management of Personal Data
        • Novartis Pharma K.K.
    2. Personal Data of employees of Entities
      1. Scope of Joint Users
        • Novartis Pharma K.K.
      2. Categories of Personal Data subject to Joint Use
        • Name, organization, address, telephone number, e-mail address, etc.
      3. Purposes of Joint Use
      4. Name of the Entity Responsible for the Management of Personal Data
        • Novartis Pharma K.K.
    3. Personal Data of healthcare professionals such as doctors, dentists, and pharmacists held by the Company
      1. Scope of Joint Users
        • Novartis Pharma K.K.
      2. Categories of Personal Data subject to Joint Use
        • Address, telephone number, e-mail address, information on the use of the target product, contents of responses to studies based on questionnaires about the target product, number of patients in possession, status of adoption of the target product, intention to prescribe (treatment policy), participation in lectures, etc.
      3. Purposes of Joint Use
      4. Name of the Entity Responsible for the Management of Personal Data
        • Chugai Pharmaceutical Co., Ltd.

Pseudonymously Processed Information

The Company may process in accordance with laws and regulations personal information to create pseudonymously processed information so that a specific individual cannot be identified unless it is collated with other information.
The created pseudonymously processed information is intended for use in drug discovery research and clinical research to create efficacy and safety of pharmaceuticals and medical devices, and is handled appropriately by implementing safety management measures in accordance with laws and regulations.

Anonymously Processed Information

Pursuant to laws and regulations, the Company acquires anonymously processed information processed by an appropriate method so that the processed information can neither to be able to identify a specific individual nor be able to restore the personal information, and use it for analysis, survey, etc.
In addition, to the extent necessary for business, it may be provided continuously to a third party after clearly indicating that the information is anonymously processed information.

  1. Anonymous Processed Information to create
    Not applicable
  2. Anonymous Processed Information to be provided to Third Parties
    1. Categories of Anonymously Processed Information Provided to Third Parties
      1. Physical information such as gender, age, height, weight etc., and attribute information such as patient ID, patient’s date of birth, etc.
      2. Information related to medical treatment (disease information, treatment/treatment information, examination information, hospitalization/discharge information, etc.), medical checkups and medical examinations
    2. Provision Method of Anonymous Processed Information
      1. Provision via a server that is properly managing access

Safety Management Measures

The Company will take necessary and appropriate safety management measures to control personal data, such as preventing leakage, loss, or damage.
The Company will also conduct necessary and appropriate supervision of employees and contractors (including subcontractors) handling personal data.
The main measures for the security management of personal data are as follows:

(Formulation of Personal Information Protection Guidelines)
The Company has established the Policy as a guideline for the proper management and protection of personal information in compliance with the Act and other laws and regulations.

(Development of Disciplines on the Handling of Personal Data)
In order to properly acquire, use, store, provide, delete, and dispose of personal data, the Company has established a system of internal responsibility.

(Organizational Safety Management Measures)
The Company has established a secretariat for the protection of personal information on the handling of personal data and has established a system for reporting to the secretariat for the protection of personal information in the event of any violation of the Act etc..

(Measures for Human Security Management)
The Company provides training to employees on matters of concern regarding the handling of personal data.

(Physical Safety Management Measures)
The Company takes measures to prevent theft or loss of equipment, electronic media, and documents that handle personal data.

(Technical Safety Management Measures)
In addition to implementing access control, the Company has introduced a mechanism to protect information systems that handle personal data from unauthorized access from outside sources.

(Understanding of External Environments)
When handling personal data in foreign countries, the Company collects and understands information related to the personal information protection system of the country concerned and takes security control measures.
Countries and regions in which the Company handle personal data include the following countries and regions in which Chugai Group companies outside of Japan are located.
For an overview of the systems for protecting personal information in these countries and regions, please visit the website of the Personal Information Protection Commission.

Personal Data Possessed by Chugai Pharmaceuticals

  1. Purposes
    The Company will use retained personal data for the purposes shown in its “Purposes of Using Personal Information”.
  2. Procedures for Treatment of an Application for Disclosure of Personal Data
    When a request is received from an individual or his/her representatives, the Company will honestly respond to a request for notification of the purposes of use, disclosure, correction, addition, deletion, suspension of using or erasing personal data (hereinafter collectively referred to as “Request for Disclosures”) in accordance with the Act.
    For details, please see Application Procedures for Disclosing Personal Information.
  3. All inquiries should be directed to:
    Personal Information Protection Promotion Secretariat
    Chugai Pharmaceutical, Co., Ltd.
    2-1-1, Nihonbashi Muromachi, Chuo-ku, Tokyo 103-8324
    Inquiry Form

    Membership to a Certified Personal Information Protection Organization
    The Company is a member of 'The Federation of Pharmaceutical Manufacturers' Associations of Japan, a certified personal information protection organization of the Ministry of Health, Labour and Welfare. The Federation accepts complaints and consultations on personal information handled by its members.

    * Please direct your inquiries to:
    Personal Information Protection Center
    The Federation of Pharmaceutical Manufacturers’ Associations of Japan
    MFPR Nihonbashi Honcho Building, 3-7-2, Nihonbashi Honcho, Chuo-ku, Tokyo 103-0023
    03-5843-6494
    (Office hours: 10:00 - 16:00; Closed: Saturdays, Sundays, National Holidays, Year-end holidays and others designated by the Federation)
    URL: http://www.fpmaj.gr.jp/

Application Procedures for Disclosing Personal Information

  1. Sending an Application

    Fill out an Application Form (A) and documents for identification of the applicant (B) and send to us by mail. If you wish to receive a written reply, please enclose postal stamps equivalent to ¥839 (¥84 for First-Class Mail (Daiisshu-Yubin), ¥435 for registered mail and ¥320 for a delivery certificate).
    A medical-related person may apply to an MR in charge.

    • * In the case that the designated amount of postal stamps are not included in the application, a notification of the fact will be sent to the applicant. However, an application will be deemed as not made if the shortfall amount is not sent to us within the designated period.
    • * For application regarding the cancer gene panel test, please read carefully the “Explanation Document on Procedures for Providing Sequence Data [PDF 199KB]”, and then submit (A) Application for Disclosure of Sequence Data and (B) Documents for Identification of the Applicant by mail without enclosing stamps.
    1. (A) Application
      An Application for Disclosure, etc. of Personal [PDF 99KB]
      • * Please use the following application form regarding the cancer gene panel test.
      An Application for Disclosure of Sequence Data [PDF 170KB]
    2. (B) Documents for Identification of the Applicant
      A copy of a driver’s license, a passport an Individual Number Card (only the front side of the card, which does not contain Individual Number) or a certified copy of resident certificate (without Individual Number; a non-certified copy is not allowed.)
      (If you wish to receive a written reply to your request for disclosure, the reply to the application will be sent to the address indicated in these documents. Changes of mailing address after sending an application should be notified to us immediately.)
      Application by a proxy requires the following document in addition to the above.
      Application by a Juvenile or by a Lawful Guardian of the Juvenile Applicant
      • Copy of family register: 1 copy
      • Copy of a driver’s license, a passport an Individual Number Card (only the front side of the card, which does not contain Individual Number) or a certified copy of resident certificate (without Individual Number; a non-certified copy is not allowed.): 1 copy
        Application by a Proxy who is Assigned to Apply on behalf of the Applicant
      • A letter of proxy signed and sealed by the applicant [PDF 40KB]
      • A copy of a seal registration certificate
      • A copy of a driver’s license, a passport an Individual Number Card (only the front side of the card, which does not contain Individual Number) or a certified copy of resident certificate(without Individual Number; a non-certified copy is not allowed.) of the proxy
      • * All documents for identification of the applicant will be destroyed within 6 months of the date of application.
    3. (C) Documents to be sent to:
      Personal Information Protection Promotion Secretariat
      Chugai Pharmaceuticals, Co., Ltd.
      2-1-1, Nihonbashi Muromachi, Chuo-Ku, Tokyo 103-8324
  2. Reply to the Application
    Reply will be sent within around one month after the identification confirmation.
    • * For a disclosure application regarding the cancer gene panel test, we will send a storage medium to the address of the individual specified in the Documents for Identification of the Applicant approximately one month after identification due to the nature of sequence data.
    • * For other request application and inquiries regarding the cancer gene panel test, please contact the inquiry desk specified in “Handling of Personal Data”.
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