Privacy Policy of the Sawai Group in Japan
Sawai Group Holdings Co., Ltd. and its Japanese consolidated subsidiaries have established a common group privacy policy as follows.
Privacy Policy of the Sawai Group in Japan

FrontAct Inc. (hereinafter referred to as "our company") will handle personal information and individual numbers in accordance with the "Domestic Sawai Group Privacy Policy" and the following provisions.

I. Policy on Protection of Personal Information/Individual Numbers

  • ①The Company shall comply with the Act on the Protection of Personal Information, the Act on the Use of Numbers to Identify a Specific Individual in the Administrative Procedure, other relevant laws and regulations as well as social norms, and shall endeavor to implement the protection of personal information (including specific personal information) and individual numbers (hereinafter referred to as "personal information/individual numbers").
  • ②The Company shall enhance the education of its directors, officers and employees, etc. in order to implement the protection of personal information/individual numbers.
  • ③The Company shall establish appropriate organizational structures in order to implement the protection of personal information/individual numbers.
  • ④The Company shall establish appropriate internal rules and regulations in order to implement the protection of personal information/individual numbers.
  • ⑤The Company shall establish appropriate procedures for acquiring, providing, handling, etc. of personal information/individual numbers in order to implement the protection of personal information/individual numbers.
  • ⑥The Company shall endeavor to improve information security in order to implement the protection of personal information/individual numbers.
  • ⑦The Company shall conduct appropriate audits in order to implement the protection personal information/individual numbers.
  • ⑧The Company shall continually review its systems for implementing the protection of personal information/individual numbers.

II. Purpose of Use

II-1. Purpose of Use for Personal Information

The Company shall use Personal Information within the scope of the Purpose of Use described below (including purposes ancillary and relating thereto) in order to carry out the business of the Company. However, the Specific Personal Information stipulated in the Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures shall be used within the scope of the "Purpose of Use of Individual Numbers and Specific Personal Information" separately described.

1Personal Information relating to medical practitioners such as physicians, dentists, veterinarians, pharmacists, clinical laboratory technicians, nurses, pharmacies/drug stores, engineering, medical science and pharmacology related researchers (including employees in the case of organizations; hereinafter the same shall apply), as well as patients, customer, clinical trial participants and other users of products (including services; hereinafter the same shall apply) (including past users, and individuals scheduled for use in the future)
  • ①Provision of products
  • ②Provision/collection of information related to products such as proper use, quality and safety
  • ③Provision/collection/analysis of product marketing information such as status of use, actual conditions of use, and needs of use
  • ④Provision/collection/consideration of scientific information and other information related to the business of the Company
  • ⑤Implementation of clinical trials, post-marketing surveillance and other investigations/research related to the business of the Company
  • ⑥Notifications/reports in accordance with laws and regulations and other standards
  • ⑦Provision to third parties within the scope necessary to carry out the items above
2Personal Information pertaining to individuals that are (or that were) related to the Company by contract or by credit relationships (including those prior to the construction of the said relationship) in connection to the business of the Company, including clients of the Company such as product wholesalers, product materials suppliers and product manufacturers, creditors of the Company such as lenders, debtors owed to the Company such as borrowers, as well as consultants such as lawyers and accountants
  • ①Performance of obligations or exercise of rights based on the said contractual/credit relationships, or the response thereto
  • ②Provision/collection of information pertaining to the said contractual/credit relationships
  • ③Construction of new contractual/credit relationships
  • ④Management of business records
  • ⑤Notifications/reports in accordance with laws and regulations and other standards
  • ⑥Provision to third parties within the scope necessary to carry out the items above
3Personal Information of individuals that make consultations, communications or other access through PR-related points of contact, or other external points of contact or the Company's directors, officers and employees, etc. ("employees, etc.") as external points of contact, or via the Company's website.
  • ①Responses and other communications regarding the said access
  • ②Management of access records
  • ③Notifications/reports in accordance with laws and regulations and other standards
  • ④Provision to third parties within the scope necessary to carry out the items above
4Personal Information of employees, etc. (including past employees, etc.) and their families
  • ①Human resources management including the proper distribution of personnel in the Group, salary payments and other labor management
  • ②Management of welfare programs as well as health and safety
  • ③Training/education
  • ④Notifications and other communications within the scope necessary to carry out the business of the Company
  • ⑤Notifications/reports in accordance with laws and regulations and other standards
  • ⑥Provision to third parties within the scope necessary to carry out the items above

Notwithstanding the above, for notifications or other communications from the Company to the individuals for whom the Company legally retains full names and contact information, the Company may use this information to the extent necessary to carry out the business of the Company.

(Note)
1. Please refer to the business objectives specified in Company profile.
2. The Company may alter the Purpose of Use as appropriate to the extent and method permitted by law.

II-2. Purpose of Use for Individual Numbers /Specific Personal Information

The Company shall use Individual Numbers/Specific Personal Information within the scope of the Purpose of Use described below:

  • ①Affairs regarding production of documentation and report relating to employment/retirement income
  • ②Affairs regarding production of payment records and report relating to earnings, fees, etc.
  • ③Affairs regarding production of payment records and report relating to real property fees, etc.
  • ④Affairs regarding production of payment records and report relating to dividends, etc.
  • ⑤Affairs regarding production of documentation and report on employment insurance
  • ⑥Affairs regarding production of documentation and report on health insurance
  • ⑦Affairs regarding production of documentation and report on employee / national pension plans
  • ⑧Affairs regarding production of documentation and report on asset accumulation savings/pensions

(Note) The Company may alter the Purposes of Use as appropriate to the extent and method permitted by laws.

III. Joint Use of Personal Data

The Company uses personal data by means of joint use as follows.

1Personal data relating to medical practitioners such as physicians, dentists, veterinarians, pharmacists, clinical laboratory technicians, nurses, pharmacies/drug stores, engineering ,medical science and pharmacology related researchers,　and customer.
  • ①Personal data items
    Name, gender, place of work, work address, work phone number, department, e-mail address, and other information necessary to achieve the Purpose of Use described in II above
  • ②Scope of entities and/or persons for joint use of personal data
    Sawai Group companies in Japan, as identified at the beginning of the Sawai Group Privacy Policy (Japan) FrontAct Co., Ltd.
    Business partners and joint research partners with FrontAct Co., Ltd.
  • ③Purposes of use of personal data
    Purposes of use as described in II above (including similar purposes of use by entities and/or persons with which the data is used by means of joint use)
  • ④Name and address of entity and/or person responsible for management of personal data, and name of representative
    FrontAct Co., Ltd.
    (The address and the name of the representative are as described in the Corporate Profile on its website.)
2Personal data relating to patients, clinical trial participants, etc.
  • ①Personal data items
    Information required for clinical trials, safety management efforts, PMS operations, etc.
  • ②Scope of entities and/or persons for joint use of personal data
    Sawai Group companies in Japan, as identified at the beginning of the Sawai Group Privacy Policy (Japan) FrontAct Co., Ltd.
    Business partners and joint research partners with FrontAct Co., Ltd.
  • ③Purposes of use of personal data
    Purposes of use as described in II above (including similar purposes of use by entities and/or persons with which the data is used by means of joint use)
  • ④Name of and address of entity and/or person responsible for management of personal data, and name of representative
    FrontAct Co., Ltd.
    (The address and the name of the representative are as described in the Corporate Profile on its website.)
3Personal data on employees, etc. (including past employees, etc.) and their families (i)
  • ①Personal data items
    Name, gender, date of birth, date entered company, address, phone number, family information, academic history, affiliation, workplace, position, e-mail address, HR/personnel management status, and other information necessary to achieve the Purpose of Use described in II above
  • ②Scope of entities and/or persons for joint use of personal data
    Sawai Group companies in Japan, as identified at the beginning of the Sawai Group Privacy Policy (Japan)
  • ③Purposes of use of personal data
    Purposes of use as described in II above (including similar purposes of use by entities and/or persons with which the data is used by means of joint use)
  • ④Name of and address of entity and/or person responsible for management of personal data, and name of representative
    Sawai Group Holdings Co., Ltd.
    (Information regarding the location of its head office and the name of its representative can be found in the “Company Overview” section of Sawai Group Holdings Co., Ltd.)
4Personal data on employees, etc. (including past employees, etc.) and their families(ii)
  • ①Personal data items
    Name, gender, date of birth, date entered company, address, phone number, family information, affiliation, workplace, position, e-mail address, HR/personnel management status, medical checkup results (use only with the Osaka Pharmaceutical Health Insurance Association, and Industrial Machine Health Insurance Society.) and other information necessary to achieve the Purpose of Use described in II above
  • ②Scope of entities and/or persons for joint use of personal data
    Sawai Group Holdings Employee Shareholding Association, Osaka Pharmaceutical Health Insurance Association, and Industrial Machine Health Insurance Society.
  • ③Purposes of use of personal data
    Purposes of use as described in II above (including similar purposes of use by entities and/or persons with which the data is used by means of joint use)
  • ④Name of and address of entity and/or person responsible for management of personal data, and name of representative
    Sawai Group Holdings Co., Ltd.
    (Information regarding the location of its head office and the name of its representative can be found in the “Company Overview” section of Sawai Group Holdings Co., Ltd.)
    Industrial Machine Health Insurance Society.
    (The address and the name of the representative are as described in the Corporate Profile on Industrial Machine Health Insurance Society.)

IV. Procedures for Requesting Disclosure and Other Actions

1Requests which can be processed

The Company will process the following requests from the Individual regarding Retained Personal Data by which such Individual can be identified and Records of Third Party Provision (including requests for disclosure through provision by electronic or magnetic record) in accordance with the Act on the Protection of Personal Information (hereinafter referred to as "the Act").

<Requests regarding Retained Personal Data>

  • ①Requests for "notification of Purpose of Use" (requests under Article 32 (2) of the Act)
  • ②Requests for "disclosure" (requests under Article 33 (1) of the Act)
  • ③Requests for "correction, supplement or deletion" (requests under Article 34 (1) of the Act)
  • ④Requests for "discontinuation of use or erasure" (requests under Article 35 (1) or (5) of the Act)
  • ⑤Requests for "discontinuation of provision to third parties" (requests under Article 35 (3) or (5) of the Act)

<Requests regarding Records of Third Party Provision>

  • ⑥Requests for "disclosure of Records of Third Party Provision" (requests under Article 33 (5) of the Act)
2Requests regarding Retained Personal Data registered on the Company website

For "Confirmation of Purpose of Use" for the Retained Personal Data registered, please visit the corresponding registration page on the website.

3Request Method

Requests should be made by filling out the designated forms and sending them to the address below, along with the necessary identification documentation.
Please note that requests made by phone, fax, e-mail or during face-to-face meetings cannot be accepted.
Please also note that requests must be made through the Personal Information/Individual Number Consultation Desk and cannot be accepted through a company's employee of other divisions who normally contacts with Individual.

Address
Personal Information/Individual Number Consultation Desk
FrontAct . Co., Ltd.
NMF Kayabacho Bldg. 5F, 1-17-24 Shinkawa, Chuo-ku, Tokyo 104-0033

4Request Form

Please download and print out the file corresponding to the desired request from the links below.

<Request regarding Retained Personal Data>

  • ① Requests for "notification of Purpose of Use" → "Request for Notification of Purpose of Use of Retained Personal Data Form"
  • ② Requests for "disclosure" →　"Request for Disclosure of Retained Personal Data Form"
  • ③ Requests for "correction, supplement or deletion" →"Request for Modification of Retained Personal Data Form"
  • ④ Requests for "discontinuation of use or erasure" → "Request for Discontinuation of Use or Erasure of Retained Personal Data Form"
  • ⑤ Requests for "discontinuation of provision to third parties" → "Request for Discontinuation of Provision of Retained Personal Data to Third Parties Form"

<Request regarding Records of Third Party Provision>

  • ⑥Requests for "disclosure of Records of Third Party Provision" → "Request for Disclosure of Records of Third Party Provision Form"
5Documents necessary to confirm identity

Please prepare the documents listed in both ① and ② below. However, multiple copies are not required in the event multiple requests are being made concurrently.
These documents will be returned with the response letter.

  • ①One copy of "driver's license" or "passport"
  • ②One original of "Residency Register" or "Seal Registration Certificate" (issued within the previous three months)
6Requests by a representative

For requests being made by a representative, please contact separately the Personal Information/Individual Number Consultation Desk for information regarding the documents required to confirm status as a representative.

7Request processing fee

Requests for notification of Purpose of Use, requests for disclosure, and requests for disclosure of Records of Third Party Provision require ￥800 processing fee per request. Please include ￥800 worth of postal stamps with your request and application documents. No processing fees are charged for other requests.
Please note that this fee may change without notice. In addition, please understand the postal stamps received in payment cannot be returned.

8Response

Responses to requests will be sent by registered mail or certified mail that requires identity confirmation of requester, to the address listed in the Residency Registry or Seal Registration Certificate provided.
Response letters will be sent within around two weeks from receiving requests, but please understand that responses may arrive later as circumstances dictate.

9When requests cannot be accepted

Please note that requests cannot be accepted in the following situations.

  • ①When request paperwork has been improperly prepared (due to omissions on request form, errors in entry method or content, missing documents, missing or unpaid fees, etc.)
  • ②When the identity of the Individual making the request cannot be confirmed, or when the Individual's representative cannot be confirmed as a representative
  • ③When requests are made regarding Personal Information not classified as the Retained Personal Data
  • ④For requests for "notification of Purpose of Use" relating to Retained Personal Data, 1) when the Purpose of Use for the Retained Persona Data is clear from the Purpose of Use publicized by the Company (as outlined in II-1 and II-2 above); 2) when the notification of Purpose of Use to the Individual or publication of the Purposes of Use may harm the life, body, property, or other rights or interests of the Individual or third parties; 3) when notification of Purpose of Use to the Individual or publication of the Purposes of Use may harm the Company's rights or legitimate interests; or 4) in the event that the Company needs to cooperate with a national organ or a local authority to execute affairs stipulated in laws and regulations, and notification of Purpose of Use to the Individual or publication of the Purposes of Use may interfere with the execution of such affairs.
  • ⑤For requests for "disclosure" relating to Retained Personal Data, when disclosure 1) may harm the life, body, property, or other rights or interests of the Individual or third parties; 2) may adversely affect the Company's proper operations; or 3) may violate any other laws or regulations.
  • ⑥For requests for "correction, supplement or deletion" relating to Retained Personal Data, when 1) request is not made for the reason the content of the Retained Personal Data which identifies the Individual is not accurate or 2) any other laws or regulations requires a specific procedure in regards to "correction, supplement or deletion" of such Retained Personal Data.
  • ⑦For requests for "discontinuation of use or erasure" relating to the Retained Personal Data, when 1) request is not made for the reason the handling of the Retained Personal Data which identifies the Individual is in violation of Article 16 of the Act or the acquisition of the Retained Personal Data is made in violation of Article 17 of the Act; 2) the reason for the request cannot be found; or 3) a costly expenditure is required to fulfill the request of discontinuation or erasure relating to the Retained Personal Request or the fulfillment of such request is otherwise difficult and the necessary alternative for such request will be taken to protect the rights and interests of the Individual.
  • ⑧For requests for "discontinuation of provision to third parties" for the Retained Personal Data, when 1) request is not made for the reason the provision of the Retained Personal Data which identifies the Individual is in violation of Article 23(1) of the Act; 2) the reason for the request cannot be found; or 3) a costly expenditure is required to fulfill the request of "discontinuation of provision to third parties" for the Retained Personal Data provision or the fulfillment of such request is otherwise difficult and the necessary alternative for such request will be taken to protect the rights and interests of the Individual.

V. Complaints and Consultation Desk

For complaints or consultations regarding Personal Information/Individual Number, please contact the Company's Personal Information/Individual Number Consultation Desk.

Personal Information/Individual Number Consultation Desk
FrontAct . Co., Ltd.
NMF Kayabacho Bldg. 5F, 1-17-24 Shinkawa, Chuo-ku, Tokyo 104-0033
Inquiry Form
Hours of Operation: 9:00-12:00 a.m., 1:00-5:00 p.m.
(Not open on Saturdays, Sundays, year-end holidays or other company holidays.)

VI. Publication of Items Related to Retained Personal Data

  • ①Name and address of Company Handling Personal Information and name of representative
    FrontAct. Co., Ltd.
    (The address and the name of the representative are as described in the Corporate Profile on its website.)
  • ②Purposes of Use for all Retained Personal Data
    As outlined in II-1 and II-2 above
  • ③Procedures for Requesting Disclosure and Other Actions in Regards to Retained Personal Data
    As outlined in IV above
  • ④Measures taken for security control of Retained Personal Data
    The Company has taken the following measures as necessary and appropriate measures for security control of Personal Data such as the prevention of any leakage or loss of, or damage to Personal Data. When the Company entrusts handling of Personal Data, the Company carries out necessary and appropriate supervision over the entrusted entity in order to ensure security control of relevant Personal Data.
    1) Formulation of a basic policy
    • To ensure proper handling of Personal Data, the Company has established a basic policy which sets forth compliance with the Act, other relevant laws and regulations as well as social norms, and development of appropriate organizational systems, among other things.
    2) Establishment of regulations regarding handling of Personal Data
    • The Company has established internal regulations that set forth methods of handling of Personal Data at each phase of acquisition, utilization, storage, provision, deletion, destruction, etc., as well as the duties and responsibility of the employees, etc. and persons in charge of handling of Personal Data.
    3) Systematic security control measures
    • The Company designates persons in charge of handling of Personal Data, and clarifies the scope of the employees, etc. who handle Personal Data and the scope of Personal Data to be handled by them. The Company has also established systems to report to a person in charge in cases where any breach of applicable laws or internal regulations, or any indication of such breach, is observed.
    • The Company periodically conducts self-inspections and undergoes audits by the internal auditing department on the handling of Personal Data.
    4) Human security control measures
    • The Company provides periodical training to its employees, etc. regarding matters that require attention in handling Personal Data.
    • The Company specifies rules regarding confidentiality of Personal Data in its employment regulations.
    5) Physical security control measures
    • The Company controls entry and exit of its employees, etc. in and from the areas where Personal Data is handled, and has measures in place to prevent any unauthorized person from accessing Personal Data.
    • The Company has conducted measures to prevent any leakage or loss of, or damage to, equipment or recording media, etc. which handle Personal Data, and has measures in place to prevent easy identification of Personal Data when any such equipment or media is carried out, including when transporting the same within its business sites.
    6) Technical security control measures
    • The Company implements access control and limits the scope of persons who handle the Personal Information Database and the scope of the Personal Information Database handled by them.
    • The Company has introduced mechanisms to protect information systems that handle Personal Data from unauthorized access from outside or unauthorized software.
    7) Understanding of circumstances of external environment
    • The Company conducts security control measures by understanding the respective systems to protect Personal Information in foreign countries where Personal Data is stored.
  • ⑤Company Contact for Complaints Regarding the Company's Handling of Retained Personal Data
    As outlined in V above

VII. Provision of Anonymously Processed Information to Third Parties, etc.

The Company acquires Anonymously Processed Information prepared by a third party and provides it to different third parties on an ongoing basis. The Company takes necessary and appropriate measures for the security control of the Anonymously Processed Information, including prevention of any leakage or loss of, or damage to, the Anonymously Processed Information.
The items of information concerning an individual contained in the Anonymously Processed Information and the method of provision of the Anonymously Processed Information are as described below:

  • ①Items of information concerning an individual contained in Anonymously Processed Information
    The month and year of birth, age, sex, information relating to medical care (disease information, treatment information, examination information, information regarding hospital visits and admission to and discharge from hospitals, etc.), information regarding qualification for medical insurance (when insurance coverage started, whether the individual is a supporter or dependent, etc.), information regarding medical checkups (history and results, etc.)
  • ②Method of provision of Anonymously Processed Information
    Anonymously Processed Information is provided by any of the following methods:
    • 1. Upload to a server;
    • 2. Provision in an electronic or magnetic recording medium; or
    • 3. Sending by e-mail.

VIII. Handling of Personal Information related to specific services provided by the Company

Our specific services may have different individual privacy policies which apply to handling of personal information received from you in connection with such services. Please click here to see our individual privacy policies.

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