The main businesses of Red Dog Plant, Inc. (henceforth “the Company”) are 1) development and operations of its interpreter reservation platform, 2) agency services for interpreters, and 3) translation services. As such, the Company is often required to take possession of personal identification information (henceforth “PII”) that relate to its customers, staff, and outsourcing entities (henceforth “Users”).
The Company takes seriously the social responsibilities associated with the handling of PII. To ensure proper protection of PII, the Company has implemented certain policies as per below. All of the Company’s interactions are conducted upon confirmation that all staff and related parties have been made thoroughly cognizant of the policies.
- The Company shall respect all laws, guidelines, and other standards as determined by the “Law Regarding Protection of Personal Information,” the Japan Industrial Standard’s “Personal Information Protection Management System Requirements (JISQ15001),” and others. Further, the Company shall implement and manage programs in an appropriate manner to ensure compliance with said policies.
- Use of PII made available to the Company shall be limited to stated purposes only and only to the degree made necessary by stated purposes.
- The Company shall not divulge to third-parties and/or otherwise make public PII unless prior approval from Users have been obtained or where the disclosure relates to the normal and regular execution of services by outsourced entities.
- The Company shall administer security measures and appropriate preventive/corrective measures to ensure PII is not misplaced, corrupted, and/or unintentionally exposed to the general public.
- The Company shall provide, via website or other, a means through which concerns, opinions, and/or questions regarding PII may be addressed. The Company shall ensure proper organizational structures to promote faithful execution.
- The Company shall make effort to improve PII related practices in a continuous manner so as to keep itself aligned with changes in the social environment.
- The PII policies above pertain also to discrete ID numbers and other discrete data.
Handling of PII
Ⅰ. Acquisition of PII and Means of Acquisition
The following relates to PII acquired by the Company.
① Information acquired directly from Users.
The Company may acquire necessary PII from Users via its on-line platform and/or through direct communication with those Users.
② Purpose of PII acquisition.
The Company may acquire PII for the following purposes.
・Administration of the on-line platform, agency, and/or the translation businesses.
・Staff hiring activities and/or human resource management.
・Facilitation of administrative functions between administration and hiring (above two).
・Execution of services outsourced to the Company.
・Other stated goals that have secured prior approval from Users..
Ⅱ. Administration of PII
The Company shall rigorously enforce the following PII related policies.
① Measures to Ensure the Accuracy of PII.
The Company shall make effort to ensure the accuracy of data and to keep such data updated at all times.
② Measures to Ensure PII Security.
The Company shall administer and implement rigorous protocols for systemic security management of PII.
③ Rigorous Supervision of PII Administered by Third-parties
The Company shall, based on established protocols, disclose information only to approved entities and make appropriate supervision.
④ Storage and Disposal of PII
The Company shall establish the period of time PII will be stored by the Company and shall abrogate such information when stated time period expires.
Ⅲ. Disclosure of PII to Third Parties
The Company shall not disclose PII to third-parties except under the following circumstances.
・Prior approval from the Owner has been obtained.
・PII disclosure is required by law.
・PII disclosure is done in cooperation with government and/or public entities.
Ⅳ. Outsourcing of PII Administration
Certain administrative functions related to law and tax may be outsourced to third-parties. In such cases, the Company will enforce appropriate administration and supervision of those third-parties.
Ⅴ. Disclosure, Correction, and Abrogation of PII
Upon request by Users for disclosure, correction, and or abrogation of personal information, the Company shall firstly make confirmation that the requestor is the Users and only then take appropriate action as determined by Company protocols.