Handling of Personal Information | CHUGAI PHARMACEUTICAL CO., LTD.

Updated on January 1, 2025

The Chugai Pharmaceutical Group has established the Group Privacy Statement as the Chugai Pharmaceutical Group’s attitude for handling personal data appropriately (including personal information as stipulated in the Personal Information Protection Law in Japan).

Category of personal information

The Company will directly or indirectly collect the following personal information within the scope of the business conducted by the Company by a legal and fair means.

General information: Name, gender, work place, work address, work telephone number, work e-mail address, medical subjects, department, workplace, title, job title, position, year of graduation, and graduated school,.
Health-related information: Information on medical care (Disease information, treatment/procedure information, test information, hospitalization/discharge information, etc.), information on health checkups/examinations, genomic data

Source of personal information

The Company may collect Personal Information directly from you as well as from the following third parties or media.

Chugai Group companies
Media such as social media and the Internet
Other third parties (Medical institutions, distributors, other companies in the same industry, contractors, etc.)

Purpose of Use

The Company shall publish the purpose of using the Personal Information on the website, etc., and the collected Personal Information shall be used for the Company’s business of manufacturing and selling drugs and medical devices, etc. within the scope of the purposes set forth below in this notice, within the scope reasonably recognized to be related thereto, or within the scope of other purposes notified individually.

Purpose of Use of Personal Information about Healthcare Professionals (Including doctors, pharmacists, pharmacy/drug store personnel, and other healthcare professionals)
- 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
- Grasp, 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 healthcare professionals and communication to them
- Request for and implementation of clinical trials, post-marketing surveys, etc.
- Securing safety in the application 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 healthcare professionals and researchers, for the purpose of securing transparency
- Others including smooth and appropriate communication with healthcare professionals and researchers
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 journals
- Communication on the Company product information, sales policies, etc.
- Understanding of credit and credit exposure management information
- Others including smooth and appropriate communication with personnel of business partners and competitors
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
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
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
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.
- Communication such as provision of information
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.
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
Purpose of Using Personal Information of Visitors to the Company’s Facilities
- Access control of visitors and factory tour guests
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
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
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
- Creation, management and maintenance of Shayukai member list
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.”
Purpose of use of genomic data that can authenticate you
- Implementation of the discovery research and the clinical research, etc. to create efficacy and safety information of medicinal products and medical devices
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

Third party provision

The Company may provide the collected personal information constituting the personal information database, etc. specified in the Act on the Protection of Personal Information of healthcare professionals (hereinafter referred to as “Personal Data”) to the following third parties for the purpose of use within the scope described in “Purpose of use” after taking appropriate measures based on laws and regulations.

Chugai Group companies
Related organizations, distributors, or other co-marketing pharmaceutical companies, etc.
Companies, etc. to which operations are outsourced (Cloud operating companies, CROs, vendors, etc.)

Pseudonymized Personal Information

Pseudonymized information refers to personal information processed so that a particular person cannot be identified unless it is collated with other information by taking measures based on the Personal Information Protection Act.

The Company may create pseudonymized information and properly handle such pseudonymized information for the purpose of use in drug discovery research and clinical research, etc. to create the efficacy and safety of drugs and medical devices (including use with AI learning data) by taking safety management measures in accordance with laws and regulations, etc.

Anonymized personal information

Anonymously processed information refers to personal information processed so as not to identify a particular person or restore such personal information by taking measures based on the Act on the Protection of Personal Information (hereinafter referred to as “Anonymously Processed Information”).

The Company may collect anonymized information, use it for analysis, analysis, research, etc., and continuously provide the information to third parties to the extent necessary for the operations after clearly indicating that the information is anonymized information. Items of information on individuals contained in the Anonymously Processed Information to be provided and the method of providing Anonymously Processed Information are as follows.

Anonymous Processed Information to create
Not applicable
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

Joint Use of Personal Data

The Company will inform you in advance on the website if it intends to co-use personal information constituting the personal information database, etc. specified in the Personal Information Protection Act (hereinafter referred to as the “Personal Data”) with specific items.

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

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.
Joint Use of Personal Data with Chugai Group companies
1. Personal Data of Healthcare Professionals such as doctors, dentists, pharmacists
  1. Scope of Joint Users
    - Chugai Group Companies outside of Japan
      - Overseas Group Companies
    - Chugai Group Companies in Japan
      - Domestic Group Companies
  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
    - For the purpose of achievement of the items described in 1. of “Purposes of Using Personal Information”
  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
    - Chugai Group Companies in Japan
      - Domestic Group Companies
  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
    - For the purpose of achievement of the items described in 2. and 3. of “Purposes of Using Personal Information”
  4. Name of the Entity Responsible for the Management of Personal Data
    - Chugai Pharmaceutical Co., Ltd.
3. Genomic data collected from clinical research, etc. that can authenticate you
  1. Scope of Joint Users
    - Chugai Group Companies outside of Japan
    - Chugai Group Companies in Japan
      - Chugai Clinical Research Center Co., Ltd.
      - Chugai Research Institute for Medical Science, Inc.,
  2. Categories of Personal Data subject to Joint Use
    - Genome data that can identify the data subjects
  3. Purposes of Joint Use
    - For the purpose of achievement of the items described in 13 of “Purposes of Using Personal Information”
  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 the company and Chugai Group companies in Japan
  1. Scope of Joint Users
    - Chugai Group Companies in Japan
      - Domestic Group Companies
  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.
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
    - Chugai Pharmaceutical Health Insurance Society
    - Chugai Group Companies in Japan
      - Domestic Group Companies
  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
    - 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.
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
    - For the purpose of achievement of the items described in 1. of “Purposes of Using Personal Information”
  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
    - For the purpose of achievement of the items described in 2. of “Purposes of Using Personal Information”
  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
    - For the purpose of achievement of the items described in 1. of “Purposes of Using Personal Information”
  4. Name of the Entity Responsible for the Management of Personal Data
    - Chugai Pharmaceutical Co., Ltd.

Cross-Border Transfer

The company will implement the safeguards required by national law in the cross-border transfer of your Personal Data (“cross-border transfer”). In the transfer of personal data between the Chugai Pharmaceutical Group, we have taken measures to protect it by concluding a data transfer agreement between Group companies to ensure a certain level of protection in accordance with applicable laws and regulations.

When handling personal data in foreign countries, the company takes safety management measures after collecting and grasping information related to the personal information protection system in the relevant country. Countries and regions where the company handles Personal Data include the following countries and regions where the company has overseas affiliates:. Please refer to the Personal Information Protection Commission website for an overview of the systems for protection of personal information in these countries and regions.

Countries and regions where the company handles personal data

EU, UK, Switzerland, US, China, Taiwan, Singapore

Investigation of systems, etc. related to protection of personal information in foreign countries (website of Personal Information Protection Commission)

https://www.ppc.go.jp/personalinfo/legal/kaiseihogohou/#gaikoku

Safety Management Measures

The company shall take necessary and appropriate safety management measures for the management of personal data (including personal information collected or intended to be collected, which is planned to be handled as personal data), including the prevention of leakage, loss, or damage. In addition, necessary and appropriate supervision will be given to employees and contractors (Including subcontractors, etc.) who handle personal data. The main contents of safety management measures for personal data are as follows.

(Formulation of Personal Information Protection Guidelines)
We have formulated the Group Privacy Declaration and this Announcement in order to comply with the Act on the Protection of Personal Information and other laws and regulations, etc. and to properly manage and protect personal data.
(Development of Disciplines on the Handling of Personal Data)
In order to properly collect, 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.
(Human Safety Management Measures)
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.

Procedure for requesting disclosure, etc. of Personal data the business holds

Personal data the business holds refers to personal data with the authority specified in the Personal Information Protection Act to disclose, correct, add or delete the contents, suspend use, delete, and suspend provision to third parties, other than those specified by the Cabinet Order as those in which the public interest or other interests are harmed if their presence or absence is made clear.
Personal data the business holds will be used within the scope of the purposes described in “Purpose of use”.
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 5. Application Procedures for Disclosing Personal Information.
Even if you wish to make a claim, you may not be able to exercise your rights specified in the preceding item if the scope of the claim exceeds the scope stipulated in laws and regulations or there are unavoidable circumstances, such as the following examples.
- It is necessary to protect your life, body, or property or other rights and interests of a third party.
- Cases where there is a risk of significant interference with the proper conduct of the company’s operations
- Violates any law other than the Personal Information Protection Act
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 ¥940 (¥110 for First-Class Mail (Daiisshu-Yubin), ¥480 or registered mail and ¥350 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”.

Contact information

If you have any questions, questions, or inquiries about your rights concerning your personal information or in connection with this notice, please contact:

Contact information
Personal Information Protection Promotion Secretariat
Chugai Pharmaceuticals, 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
TEL 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/