Protection of Personal Information

Basic Policy Regarding Protection of Personal Information (Privacy Policy)

In order to appropriately protect information concerning an insured person, etc. him/herself (information from which a specific individual can be identified (“Personal Information”)), including the name, address, gender, date of birth, and phone number of an insured person, etc., as well as applicability-related information (information about the acquisition or loss of eligibility, standard remuneration, etc.), cash benefits-related information (including funeral; maternity; allowances for childbirth, injury, or sickness, etc.; patient cost-sharing reimbursements; and additional benefits), Rezept-related information (information about medical expenses, medical consultation/treatment, etc.), health screening-related information (health screening data, etc.), health management-related information (information about the usage of health facilities, Society-hosted events, etc.), the Society handles Personal Information according to the following policy.

The Health Insurance Society implements appropriate safety measures to safeguard the personal information it obtains on its members against leaks, loss, damage, or improper access.
The Health Insurance Society uses the personal information provided by members solely for purposes considered beneficial for members, such as health maintenance and promotion. In addition, it uses Individual Numbers only within the scope of the purposes specified in the Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedure.
The Society will not provide Personal Information about an insured person, etc. to a third party unless the prior consent has been obtained from the insured person, etc. The Society will not provide Personal Information about an insured person, etc. that contains his/her individual number (“Specific Personal Information”) to a third party with or without his/her consent except for the cases specified in the Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures. Provided, however, that the Society may provide Personal Information about an insured person, etc. that does not constitute Specific Personal Information to a third party without the prior consent of the relevant member if the situation falls under any of the items of Article 27, Paragraph (1) of the Act on the Protection of Personal Information (Act No. 57 of May 30, 2003).
In addition to training and raising awareness among employees regarding personal information protection, the Health Insurance Society will strive to manage personal information appropriately by assigning persons responsible for such management at each section that handles personal information.
When subcontracting its business operations, the Health Insurance Society will carry out reviews and implement improvements to strengthen personal information protection measures. When concluding business subcontracting agreements, it will carefully examine the competence of subcontractors and consider issues relevant to personal information protection in the content of such agreements.
An insured person, etc. may notify the Society through its point of contact if he/she wishes to inquire about, correct, or otherwise make a request concerning his/her Personal Information, and the Society will promptly respond to such a request to the extent considered reasonable according to the Health Insurance Act and other laws and regulations, its personal information protection and management regulations, and other rules.
In addition to complying with laws, regulations, and other standards concerning the handling of members' personal information, the Health Insurance Society continually reviews and strives to improve the content of this Privacy Policy.
This basic policy, the personal information protection and management regulations, and other rules may be revised as appropriate to reflect any enactment, revision or abolition of laws and regulations, and changes in circumstances.
Inquiries regarding the Society’s handling and management of Personal Information can be sent to its point of contact as shown below.

Contact	Advantest Health Insurance Society
Address	Ikebukuro FN building 3-9-10, Higashi Ikebukuro, Toshima-ku, TOKYO
TELL	03-6709-2270
Office hours	From am 8:40 - pm 5:30（Excluding Sundays, holidays, year-end and New Year holidays）

Purposes of use of personal information

The Society publishes the main purposes of use of personal information it handles in its normal business operations in accordance with the applicable provisions of laws and guidelines, as follows.

Purposes of use necessary for payments of insurance benefits to insured persons, etc.
(1) Cases associated with internal use by the Health Insurance Society, etc.
- To provide insurance benefits and additional benefits
(2) Cases involving information provision to other business operators, etc.
- To outsource translation work related to overseas medical expenses
- To check treatment expense details and calculate NHI points
- To claim compensation from non-life insurance companies, etc. in relation to an act of a third party
- To implement the undertakings regarding benefits for high-cost medical care jointly with the National Federation of Health Insurance Societies and provide consultation on benefits
Purposes of use necessary for the collection of premiums, etc.
(1) Cases associated with internal use by the Health Insurance Society, etc.
- To confirm the eligibility of insured persons and identify their monthly remuneration and bonus amounts
- Collection of health insurance premiums
- To certify dependents (certification of eligibility at the time of enrollment and certification through eligibility surveys regularly conducted)
- To issue health insurance certificates
(2) Cases involving information provision to other business operators, etc.
- To outsource the processing of data on the eligibility of insured persons, etc.
To outsource the processing of data on the eligibility of insured persons, etc.
(1) Cases associated with internal use by the Health Insurance Society, etc.
- To provide information about health screening, health guidance and consultation, and health management seminars aimed at maintaining and enhancing the health of insured persons, etc.
- To provide subsidies for health screening to insured persons
- To confirm the eligibility of insured persons, etc., and send information to insured persons, etc., in relation to their participation in physical activity encouragement programs
- To subsidize insured persons in relation to home treatment support activities
- To notify insured persons of their medical care cost information
- To confirm the eligibility of insured persons who have applied for a loan for high-cost medical expenses, remit the loaned money to them, and obtain their consent to the terms of repayment
- To confirm the eligibility of insured persons who have applied for a loan for childbirth money, remit the loaned money to them, and obtain their consent to the terms of repayment
- To confirm the eligibility of insured persons who have applied for a loan for home treatment support money, remit the loaned money to them, and obtain their consent to the terms of repayment
(2) Cases involving information provision to other business operators, etc.
- To entrust services related to health screening, health guidance and consultation to health screening institutions contracted with the Society
- To entrust services related to the conduct of health management seminars to professional organizations
- To entrust employers with services related to the distribution of health screening tickets to be submitted to contracted medical care institutions
- To entrust employers with services related to the delivery of materials to and scheduling with insured persons when health screening is scheduled
- To provide employers with insured persons’ health screening results
- To entrust contractors with services related to the confirmation of the eligibility and the enrollment of insured persons, etc. in relation to their participation in physical activity encouragement programs
- To implement joint undertakings promoted by the National Federation of Health Insurance Societies (including the Tokyo Federation and the Johoku Area Regional Federation)
- To entrust contractors with services related to the confirmation of eligibility of insured persons, send information to insured persons, and the enrollment of insured persons in relation to welfare service activities for insured persons
- To entrust employers with activities related to health guidance and consultation
- To entrust contractors with activities related to health guidance and consultation
Purposes of use necessary for reviews and payments of medical fees
(1) Cases associated with internal use by the Health Insurance Society, etc.
- To check and review medical cost details (Rezept) and other documents
(2) Cases involving information provision to other business operators, etc.
- To entrust the checking and reviewing of Rezept data
- To entrust data entry and electronic capturing of images to computerize Rezept data
Purposes of use necessary to secure the stable operation of the Health Insurance Society
(1) Cases associated with internal use by the Health Insurance Society, etc.
- To conduct medical expense analyses/disease analyses
(2) Cases involving information provision to other business operators, etc.
- To outsource data processing and other services associated with medical expense analyses
Other
(1) Cases associated with internal use by the Health Insurance Society, etc.
- To use information as basic materials for maintaining and improving services as part of the Health Insurance Society’s management and operation-related business
- To use information as records related to the Health Insurance Society’s management and operation-related business
- To execute proper accounting operations
(2) Cases involving information provision to other business operators, etc.
- To view information and respond to inquiries for the proper processing of operations (exchanges of information between insurers)
- To consult with or make notification to insurance companies, medical care institutions, the National Federation of Health Insurance Societies, etc., in handling third-party compensation claims
Specific personal information
Purposes of use for information sharing with other medical insurers or administrative organs (“Other Organizations”) as prescribed in Article 19, item (vii) of the Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures
(1) To receive information from Other Organizations to perform clerical duties of the Society
- Information about payments of benefits related to the review process of injury and sickness allowance, high-cost medical expenses, and other insurance benefits
- Information about taxable/non-taxable status required for judging copayment categories of elderly recipients, etc.
- Information about the eligibility of insured persons held by Other Organizations related to affairs required for insured persons’ acquisition of insurance status
- Information about taxable/non-taxable status, residence certificates, and other information required for affairs related to dependent certification
(2) Cases where the Society provides information to Other Organizations for their execution of administrative duties
- Insurance provided by the Society related to benefit payment-related affairs of Other Organizations, such as high-cost medical expenses, childbirth, and funeral expenses-related benefits
- Information about insured persons’ acquisition of insurance status and the eligibility of dependents held by the Society required for affairs about confirmation of the eligibility at Other Organizations, such as insured persons’ acquisition of insurance status and dependent certification

Items that require consent

It is stipulated by laws and guidelines that, when providing information to third parties, “to the extent that the purposes of use of personal information that are normally required to provide insurance benefits to insured persons, etc. are in the interest of insured persons, etc. or impose a significant burden on health insurance societies and employers, and obtaining express consent from insured persons, etc. is not necessarily reasonable for the insured persons, etc. themselves (e.g., when sending medical care cost information to each insured person), if the scope of use of such information has been made clear by posting on a website, distributing brochures, making public notice, or by other means, and insured persons, etc. have not specifically indicated their explicit objection or reservation,” it may be considered that implicit and comprehensive consent has been obtained from insured persons, etc.
The Society has determined that the following items are in line with the purport of the above stipulation and therefore established the process, and asks for understanding and cooperation from insured persons, etc.
If you do not consent to this process, please notify the Society in writing of the code and number on your health insurance certificate, your name, and the reason you cannot give your consent. If you do not indicate anything, the Society will deem that you have given your “implicit and comprehensive consent.”

Method of notification
While the Society should basically notify each of the insured persons, etc. of the purposes of use of their personal information, doing so would impose a significant burden on the Society and not be reasonable for the insured persons, etc., either. Therefore, the Society discloses such information by posting on a website, distributing brochures, making public notice, or by other means, so that each of the insured persons, etc., may readily access such information.
Method of obtaining consent
The Society employs “implicit and comprehensive consent” as a method to obtain consent from insured persons, etc., as it is deemed a method that does not impose a significant burden on the Society and at the same time is reasonable for the insured persons, etc.
Items covered by the means of “implicit and comprehensive consent”
- (1) Medical care cost information
  Unless prior consent has been obtained from each of the insured persons, etc., medical care cost information should be sent to them separately. However, this way would impose a significant burden on the Society in performing its clerical duties and would not be considered a reasonable way for the insured persons, etc., either.
  Therefore, as in the same way as the current process, the Society will notify “medical care cost information” covering insured persons, etc. all of a lump even after the enactment of the relevant law.
- (2) Payments, collection, and notification of insurance benefits and health activity subsidies made via employers
  Unless prior consent has been obtained from each of the insured persons, etc., payments, collection, and notification of insurance benefits and health activity subsidies should be made to/from each of them. However, this way would cause the Society a significant amount of work related to payments, collection, and notification, and remittance fees, and would not be considered a reasonable way for the insured persons, etc., either.
  Therefore, as in the same way as the current process, the Society will pay, collect, and notify to/from insured persons “insurance benefits” and “health activity subsidies” covering insured persons, etc. all of a lump through employers even after the enactment of the relevant law.

Items covered under joint undertakings

It is stipulated by laws and guidelines that “if the personal data is provided to specific persons who have joint use of that data, and the business notifies the person identifiable by that data of this in advance as well as the details of that data, the extent of the joint users, the users' purpose of use, and the name and address of the person responsible for managing the personal data, or the business makes the foregoing information readily accessible to the person identifiable by that data in advance, the business may provide that personal data to a third party.”
Therefore, the Society publishes the information about each joint undertaking it has been conducting.

Undertakings for health screening (“HS”) of insured persons
- (1) Joint undertaking collaborators
  Employers and mobile HS contractors
- (2) Purport of the use of personal data for the joint undertaking
  To provide HS, health guidance and consultation to insured persons to maintain and enhance their health
- (3) Items of personal data to be jointly used
  The affiliation, health insurance certificate codes/numbers, names, genders, dates of birth, ages, and data about HS results of insured persons
- (4) The scope of persons who handle personal data
  [Joint undertaking collaborators]
  HS personnel, occupational physicians, public health nurses, nurses, and registered dietitians of employers, and personnel, doctors, public health nurses, nurses, dietitians, and technicians of mobile HS contractors
  [The Society]
  HS personnel and the Managing Director of the Society
- (5) The purposes of use for persons who handle personal data
  To process affairs related to HS, provide health guidance and consultation, and analyze HS results
- (6) The name of the person responsible for the management of data
  [Joint undertaking collaborators]
  The heads of departments in charge of HS of employers, the heads of the departments in charge of HS of contracted HS institutions
  [The Society]
  The Managing Director of the Society
Grant programs related to benefits for high-cost medical care
- (1) Joint undertaking collaborators
  The National Federation of Health Insurance Societies (the “NFHIS”)
- (2) Purport of the use of personal data for the joint undertaking
  This is a program under “the business referred to in Article 2 of the Supplementary Provisions to the Health Insurance Act,” through which the NFHIS grants part of the expenses when the Society incurs high medical expenses. To apply for the program, the Society will submit to the NFHIS copies of Rezept, documents (grant application general statements) containing names and genders of the Rezept patients, whether they are insured persons or their family members, inpatient or outpatient, year and month of treatment, and the amount of the Rezept billing.
- (3) Items of personal data to be jointly used
  In addition to the matters stated in the grant application general statements referred to in the preceding paragraph, each copy of Rezept in which the final number of points is stated (if Rezept for Diagnosis Procedure Combination (DPC Rezept) contains the final number of points in a later page, the first page and such later page)
- (4) The scope of persons who handle personal data
  [Joint undertaking collaborators]
  Personnel of the NFHIS, and contractors of the NFHIS
  [The Society]
  Personnel of the Society in charge of high-cost grants, the Managing Director
- (5) The purposes of use for persons who handle personal data
  The Society will use personal information to apply for and receive grants through the undertaking as specified in (2) above. The NFHIS will use personal information to check the accuracy of the application submitted by the Society and to ensure the proper grants. The NFHIS retains copies of Rezept for one year, and Rezept converted into image data for four years, as such copies and data are necessary to support the information in the application.
- (6) The name of the person responsible for the management of data
  [Joint undertaking collaborators]
  The person responsible for the data management and the heads of the responsible departments of the NFHIS
  [The Society]
  The Managing Director of the Society

Supplementary Provisions

(Effective date)

Revised on April 1, 2022
Revised on July 1, 2018
Revised on April 1, 2016
Revised on April 1, 2012
Revised on Sepetember 1, 2010
Established on March, 2005