S&K Brussels Consulting Co., Ltd.

Privacy Policy

S&K Brussels Consulting Co., Ltd ("S&K Brussels Consulting"), and S&K Brussels Consulting USA Corporation (collectively, "S&K Brussels Consulting Group," "we," "our") has established the following privacy policy ("Privacy Policy") for the handling of personal information within S&K Brussels Consulting Group. S&K Brussels Consulting Group shall comply with this policy as well as the Act on the Protection of Personal Information (Act No. 57 of 2003) ("APPI") and all other applicable laws and regulations.

1. Acquisition of Personal Information

S&K Brussels Consulting Group shall specify the purposes of use of Personal Information and acquire Personal Information in the necessary scope and appropriate manner. S&K Brussels Consulting Group shall, except in those cases based on the APPI and or other applicable laws and regulations, not acquire special care-required personal information ("Sensitive Personal Information") without the prior consent of the individual concerned.

2. Purposes of Use of Personal Information

S&K Brussels Consulting Group shall use Personal Information only within the scope of the purposes stated below unless separately notified or except otherwise approved by laws and regulations.

Purposes of Use of Personal Information Categories of Personal Information
1.
  • Provision of consulting services;
  • Responding to various types of inquiries, or the like; or
  • Other purposes incidental to those mentioned above.
Information obtained in connection with the provision of consulting services by S&K Brussels Consulting Group, including the following:
  • Identification information (name, address, date of birth, etc.) and contact details (company/school, job title, e-mail address, phone number, etc.);
  • Client information (client information made available to S&K Brussels Consulting Group in the course of providing consulting services to our clients); and Business and professional information (job title, function or position, organization, work experience, and academic experience, information relating to business activities such as attendance at business workshops, lectures, seminars, meetings, and other professional events, and any other personal data related to business and professional activities, etc.).
2.
  • Provision of information regarding activities of S&K Brussels Consulting Group (including sending or transmitting letters of greeting, season’s greetings, etc.);
  • Provision of information regarding workshops, lectures, seminars, and other events, and accepting applications to attend or participate in such events;
  • Sending or transmission of, or receipt of applications for, newsletters;
  • Provision of other information, or receipt of requests for, or inquiries regarding, the provision of such information; or
  • Other purposes incidental to those mentioned above.
Information obtained in connection with the provision of consulting related information or details concerning the possibility of providing consulting related information by S&K Brussels Consulting Group, including the following:
  • Identification information (name, address, date of birth, etc.) and contact details (company/school, job title, e-mail address, phone number, etc.); and
  • Business and professional information (job title, function or position, organization, work experience, and academic experience, information relating to business activities such as attendance at business workshops, lectures, seminars, meetings, and other professional events, and any other personal data related to business and professional activities, etc.).
3.
  • Provision of information, or receipt of applications for, or inquiries regarding recruitment;
  • Employment selection (for job applicants);
  • Ongoing communications and provision of information regarding S&K Brussels Consulting Group to applicants for recruitment or those who have received an informal employment commitment;
  • Personnel management and training for those who have received formal employment offers; or
  • Other purposes incidental to those mentioned above.
Information obtained in connection with the recruitment of consultants, other professionals, staff, or interns of S&K Brussels Consulting Group, including the following:
  • Information to be submitted at the time of employment (curriculum vitae, work experience, results of aptitude tests, grades and degree certificates issued by higher education institutions such as universities and professional education institutions, grades and certificates issued by accredited qualification test institutes, etc.)
4.
  • Personnel management and training; or
  • Other purposes incidental to those mentioned above.
Information obtained in connection with the recruitment of consultants, other professionals, staff, or interns of S&K Brussels Consulting Group, and in connection with personnel management and training for those who have received formal employment offers, including the following:
  • Information submitted at the time of employment (curriculum vitae, work experience, results of aptitude tests, grades and degree certificates issued by higher education institutions such as universities and professional education institutions, grades and certificates issued by accredited qualification test institutes, etc.); and
  • Personnel Performance Evaluation Information
5.
  • Assessing the health of consultants, other professionals, staff, or interns of S&K Brussels Consulting Group
Information obtained in connection with the management of the health condition of consultants, other professionals, staff, or interns of S&K Brussels Consulting Group, including the following:
  • Sensitive Personal Information (health data such as health checkup results, etc.)
6.
  • Withholding tax collection and social insurance-related affairs, etc.
Information obtained in connection with withholding tax collection and social insurance-related affairs of consultants, other professionals, staff, or interns of S&K Brussels Consulting, including the following:
  • Specific Personal Information (including information on family dependents); and
  • Salary and compensation-related documents
7.
  • Provision of payroll and social insurance services
Information obtained in connection with the provision of payroll and social insurance services of consultants, other professionals, staff, or interns of S&K Brussels Consulting, including the following:
  • Salary related documents (including bank account information)
8.
  • Provision of payroll and social insurance services
  • Emergency communications involving consultants, other professionals, staff, or interns of S&K Brussels Consulting
Information obtained in connection with the provision of payroll and social insurance services and emergency preparation for consultants, other professionals, staff, or interns of S&K Brussels Consulting, including the following:
  • Identification information (name, address, date of birth, etc.) and contact details (company/school, job title, e-mail address, phone number, etc.) of the above attorneys, other professionals, staff, or interns’ respective family members.
9.
  • Provision of payroll and social insurance services, related communications, etc.
Information submitted by retirees of S&K Brussels Consulting Group at the time of resignation, including the following:
  • Information submitted at the time of resignation, address, and contact details after resignation.
10.
  • Provision of compensation and expense reimbursement-related services
Bank account information
11.
  • Registration of S&K Brussels Consulting Group’s system
Biometric information, passwords
12.
  • Publication on the S&K Brussels Consulting Group’s website and in various media for publicity, advertising, recruitment activities, etc.
Photography and interview information (interview information such as name, organization, photo, and business description)

3. Provision of Personal Data to Third Parties and Extraterritorial Transfers

S&K Brussels Consulting shall comply with the APPI and all other relevant laws and regulations regarding the provision of personal data to third parties and extraterritorial transfers, including, where necessary, obtaining the consent of the relevant individual. In relation to some of the personal information handled by S&K Brussels Consulting, the consent of the individual concerned under the APPI shall not be obtained, as the provision and extraterritorial transfer of said personal information to third parties is conducted in a manner that can ensure the continued implementation of measures equivalent to those required to be taken by personal information handling business operators under the APPI below.

  • Provision to third parties and extraterritorial transfer among S&K Brussels Consulting Group companies in accordance with this Privacy Policy, which is commonly applied throughout S&K Brussels Consulting Group companies.
  • Provision to third parties and extraterritorial transfer, such as S&K Brussels LPC, S&K Brussels BV and Sugimoto & Kawashima PLLC, with whom S&K Brussels Consulting Group has entered into an outsourcing agreement that includes non-disclosure obligations regarding the handling of personal information.
  • Provision to third parties and extraterritorial transfer, such as other companies with whom S&K Brussels Consulting Group has entered into an outsourcing agreement that includes non-disclosure obligations regarding the handling of personal information.

The foreign countries to which the extraterritorial transfer of personal data may be provided are Belgium, where S&K Brussels BV is located, and the United States, where Sugimoto & Kawashima PLLC and S&K Brussels Consulting USA Corporation are located. For information on the personal information protection systems of these countries, please refer to the following:

4. Joint Use of Personal Data

S&K Brussels Consulting may jointly use personal data acquired by S&K Brussels Consulting Group in accordance with the description in "1: Joint Use within S&K Brussels Consulting Group"

[1: Joint Use within S&K Brussels Consulting Group]

a) Scope of joint use

S&K Brussels Consulting Group (S&K Brussels Consulting Co., Ltd. and S&K Brussels Consulting USA Corporation)

b) Person(s) responsible for the management of said personal data

S&K Brussels Consulting

c) Purpose of use and categories of personal information to be jointly used by the persons using the data

Purposes of Joint Use of Personal Categories of Personal Data to be Jointly Used
1.
  • Provision of consulting services;
  • Responding to various types of inquiries, or the like; or
  • Other purposes incidental to those mentioned above.
Information obtained in connection with the provision of consulting services by S&K Brussels Consulting Group, including the following:
  • Identification information (name, address, date of birth, etc.) and contact details (company/school, job title, e-mail address, phone number, etc.);
  • Client information (client information made available to S&K Brussels Consulting Group in the course of providing consulting services to our clients); and
  • Business and professional information (job title, function or position, organization, work experience, and academic experience, information relating to business activities such as attendance at business workshops, lectures, seminars, meetings, and other professional events, and any other personal data related to business and professional activities, etc.). S&K Brussels Consulting Group
2.
  • Provision of information regarding activities of S&K Brussels Consulting Group (including sending or transmitting letters of greeting, season’s greetings, etc.);
  • Provision of information regarding workshops, lectures, seminars, and other events, and accepting applications to attend or participate in such events;
  • Sending or transmission of, or receipt of applications for, newsletters;
  • Provision of other information, or receipt of requests for, or inquiries regarding, the provision of such information; or
  • Other purposes incidental to those mentioned above.
Information obtained in connection with the provision of consulting related information or details concerning the possibility of providing consulting related information by S&K Brussels Consulting Group, including the following:
  • Identification information (name, address, date of birth, etc.) and contact details (company/school, job title, e-mail address, phone number, etc.); and
  • Business and professional information (job title, function or position, organization, work experience, and academic experience, information relating to business activities such as attendance at business workshops, lectures, seminars, meetings, and other professional events, and any other personal data related to business and professional activities, etc.).
3.
  • Provision of information, or receipt of applications for, or inquiries regarding recruitment;
  • Employment selection (for job applicants);
  • Ongoing communications and provision of information regarding S&K Brussels Consulting Group to applicants for recruitment or those who have received an informal employment commitment;
  • Personnel management and training for those who have received formal employment offers; or
  • Other purposes incidental to those mentioned above.
Information obtained in connection with the recruitment of consultants, other professionals, staff, or interns of S&K Brussels Consulting Group, including the following:
  • Information to be submitted at the time of employment (curriculum vitae, work experience, results of aptitude tests, grades and degree certificates issued by higher education institutions such as universities and professional education institutions, grades and certificates issued by accredited qualification test institutes, etc.)
4.
  • Personnel management and training; or
  • Other purposes incidental to those mentioned above.
Information obtained in connection with the recruitment of consultants, other professionals, staff, or interns of S&K Brussels Consulting Group and in connection with personnel management and training for those who have received formal employment offers, including the following:
  • Information submitted at the time of employment (curriculum vitae, work experience, results of aptitude tests, grades and degree certificates issued by higher education institutions such as universities and professional education institutions, grades and certificates issued by accredited qualification test institutes, etc.); and
  • Personnel Performance Information
5.
  • Assessing the health of consultants, other professionals, staff, or interns of S&K Brussels Consulting Group
Information obtained in connection with the management of the health condition of consultants, other professionals, staff, or interns of S&K Brussels Consulting Group, including the following:
  • Sensitive Personal Information (health data such as health checkup results, etc.)
6.
  • Provision of payroll and social insurance services, related communications, etc.
Information submitted by retirees of S&K Brussels Consulting Group at the time of resignation, including the following:
  • Information submitted at the time of resignation, address, and contact details after resignation.
7.
  • Registration of S&K Brussels Consulting Group’s system
Biometric information and passwords
8.
  • Publication on the S&K Brussels Consulting Group’s website and in various media for publicity, advertising, recruitment activities, etc.
Photography and interview information (interview information such as name, organization, photo, and business description)

5. Security Management of Personal Data

S&K Brussels Consulting takes the following appropriate measures to prevent disclosure, loss, impairment, and or any other mishandling of personal data:

a) Formulation of a basic policy

This Privacy Policy has been established as a basic policy to ensure the appropriate handling of personal information and to provide a point of contact for questions and complaints.

b) Establishment of rules for the handling of personal data

Basic handling procedures have been established for the collection, use, and storage of personal data.

c) Organizational security management measures

(i) The responsible person confirms that personal information is handled in accordance with the established handling procedures.

(ii) A reporting and communication system from employees to the responsible person has been established.

d) Human security management measures

(i) Regular training is provided to employees, etc., on points to keep in mind regarding the handling of personal data.

(ii) Matters relating to the confidentiality of personal information are included in employment contracts and outsourcing agreements.

e) Physical security management measures

(i) Measures are taken to ensure that personal data cannot be easily accessed by anyone other than employees, etc., who are authorized to handle personal data and the relevant individual.

(ii) Measures are taken to prevent theft or loss of equipment, electronic media, and documents that handle personal information.

(iii) Measures are taken to ensure that personal information is not easily revealed when equipment, electronic media, etc., that handle personal information are transported, including transfers between offices of S&K Brussels Consulting Group.

f) Technical security management measures

(i) Equipment capable of handling personal data and employees, etc., who handle such equipment are clearly identified to prevent unwanted access to personal data.

(ii) Mechanisms are in place to protect information systems that handle personal information from unauthorized external access or unauthorized software.

g) Understanding the external environment

  • S&K Brussels Consulting stores personal information on servers located in Japan, which are provided by a cloud service provider located in Japan.
  • S&K Brussels Consulting USA Corporation stores personal information on servers located in Japan, which are provided by a cloud service provider located in Japan, but may handle personal information in the United States. S&K Brussels Consulting USA Corporation understands the personal information protection system in the United States and implements the security control measures specified in items a) to f) above.

6. Requests for Notification of Purposes of Use, Disclosure, Correction, Discontinuation of Use, or other Handling of Personal Information

Upon receiving a request to disclose the retained personal data or its purpose(s) of use; to disclose, correct, supplement or delete the personal information; to temporarily suspend or permanently discontinue the use of the personal data; to discontinue the provision of personal data to a third party; etc., S&K Brussels Consulting Group shall, after confirming the identity and relevance of the person making the request, respond promptly and in good faith, in accordance with the provisions of the APPI. Please note that we may not be able to respond to a request if it does not satisfy the requirements prescribed by the APPI, or if there is cause to decline the request in accordance with applicable laws and regulations.

7. Contact for Inquiries

Requests for disclosure, comments, questions, complaints, and other inquiries with respect to our handling of personal information should be referred to our Data Protection Manager Office at the contact details below:
Data Protection Manager Office
S&K Brussels Consulting Co., Ltd
Sanno Bridge B1F
2-5-6 Sanno
Ota-City, Tokyo 143-0023
JAPAN
E-mail: dpm@sandkbc.com

8. Amendment to this Privacy Policy

In an effort to improve our policies and procedures for the handling of personal information, S&K Brussels Consulting shall periodically review and amend this Privacy Policy.

Last updated on April 28, 2022