Personal Information Protection Policy

Pasona Group Inc., as a holding company of Pasona Group companies (meaning consolidated subsidiaries and equity method affiliates) that provide comprehensive human resource services, including temporary staffing, job placement, outplacement, and outsourcing, deeply recognizes the importance of the handling of personal information and shall take appropriate measures to acquire, use, and provide personal information in an appropriate manner. In addition, in order to guarantee the rights of our customers, business partners, registered staff, shareholders, and employees with respect to their personal information, we have established this Personal Information Protection Policy and will implement the matters set forth below.

Establishment of the operating organization
In order to use and manage personal information appropriately, we will establish an operating organization that defines roles, responsibilities, and authorities.
Appropriate operation and management
We will educate and inform our employees about laws, guidelines, regulations, and manuals, etc., concerning the protection of personal information and will implement and manage such appropriately.
Prohibition of use for other purposes
We will establish, implement, and maintain procedures to take necessary measures to ensure that personal information is not used for any other purposes.
Compliance with laws, regulations, and standards
We will establish a plan to comply with laws, national guidelines, and other norms applicable to the protection of personal information and will prepare appropriate personal information protection documents.
Implementation of safety measures
To ensure the accuracy and safety of personal information under our control, we will take appropriate preventive and corrective measures against leakage, loss, or damage of personal information.
Response to complaints and consultations
We will establish a necessary system and procedures to receive complaints and consultations from individuals regarding the handling of their personal information and will respond to such appropriately and promptly, and we will comply with and maintain such system and procedures.
Continuous improvement
The Company's personal information protection system, which is established with this policy as its top priority, will be continuously reviewed and improved through internal audits, etc., while taking into consideration technological trends in the information industry, and the Company will maintain the standards of the system.

Date of Enactment December 10, 2007

Pasona Group Inc.
Group CEO
Yasuyuki Nambu

Handling of Personal Information

1. Name, address, and name of representative of the Company

Pasona Group Inc.
1-30, Minami-Aoyama 3-chome, Minato-ku, Tokyo
Group CEO and President Yasuyuki Nambu

2. Purpose of use of personal information

Pasona Group shall use the personal information that it collects and acquires for the following purposes. In cases where the purpose of use of personal information is separately specified to the individual at the time of collection, such personal information will be used for the purpose specified at the time of collection.

To receive, respond to, and manage inquiries, applications, and opinions, and to perform various procedures
To provide the services requested by the customer
To provide information, proposals, materials, and responses to inquiries regarding the products and services of the Company and Pasona Group companies (including Pasona Group's affiliates as defined in Article 8, Paragraph 8 of the "Regulations Concerning Terms, Forms and Preparation Methods of Financial Statements, etc."; hereinafter the same shall apply) (including the communication and transfer of inquiries to Pasona Group companies that provide the products and services) (including the transmission and transfer of inquiries to Pasona Group companies that provide the products and services)
To provide information on events and seminars held or sponsored by the Company and Pasona Group companies
To reply to requests for cooperation in marketing activities, distribution of content and advertising, and surveys related to the business activities of Pasona Group Inc. and Pasona Group companies
To develop new products and services offered by the Company and Pasona Group companies, analyze usage trends and needs with the aim of improving future services, and providing proposals for services based on the results of such analysis
To prepare statistical data relating to the business activities of the Company and Pasona Group companies
To distribute various communications and notices related to recruitment, selection, and decision-making
To carry out human resources management, labor management, health management, welfare operations, communication in the event of work-related or emergency situations, implementation and review of various human resource policies, applications for company housing placement or cancellation, and company housing-related operations

3. Provision of personal data to third parties

We will not provide personal data to third parties without the consent of the individual, except in the following cases:

When the Company has clearly indicated or notified the person in advance of the necessary matters and obtained his/her consent
When disclosure or provision is permitted by law
When disclosure is necessary for the protection of the life, body, or property of an individual and when it is difficult to obtain the consent of the person in question
When disclosure is particularly necessary for improving public health or promoting the sound growth of children and when it is difficult to obtain the consent of the person in question
Cases in which the provision of personal information is necessary for cooperating with a state organ, a local government, or an individual or entity entrusted by either a state organ or local government to execute affairs prescribed by law, and in which obtaining your consent is likely to impede the execution of such affairs
Cases in which the third party is an academic research institution, etc., and when it is necessary for the third party to handle the relevant personal data for academic research purposes (including cases in which part of the purpose of handling the relevant personal data is for academic research purposes, excluding cases in which there is a risk of unjustified infringement on the rights and interests of individuals).

4. Outsourcing of personal data

We may outsource part or all of the operations handling personal data to contractors that meet the standards of our personal information protection system, within the scope of the purposes of use. In the event that all or part of the handling of personal data is outsourced, the Company will enter into a contract with the outsourced party and exercise necessary and appropriate supervision to ensure the safe management of personal data by the outsourced party.

5. Joint use of personal data

In order to provide comprehensive services to the Company and Pasona Group companies, Pasona Group will jointly use personal data with respect to items (iii) through (vii) of "2. Purpose of use of personal information".

Information on executives and employees of business partners, etc. (including prospective customers)

Item	Content
Items of personal data to be shared	Name, name of organization, address, department, title, e-mail address, telephone number, fax number, transaction history
Scope of parties with which Pasona Group companies will share personal data with	Pasona Group companies; however, companies located outside of Japan are excluded. List of Pasona Group Companies
Purposes of use by parties with whom personal information is shared	Items (iii) through (vii) of "2. Purpose of use of personal information"
Method of acquisition	Information acquired through the exchange of business cards, business discussions, applications for business transactions, applications for events and seminars, inquiries regarding products and services through the website, etc., will be shared through a system in which Pasona Group companies will jointly use such information.
Party responsible for the management of personal data shared by	The Company and Pasona Group Companies

Contact for inquiries regarding shared use

Please contact the following for inquiries regarding the joint use of information on executives and employees of Pasona Group's business partners.
Pasona Group Inc.
E-MAIL ： info_biz@pasonagroup.co.jp

6. Use of statistically processed data

We may create statistical data based on personal data, which is processed in such a way that individuals cannot be identified. The Company may use statistical data that does not identify individuals without any restrictions.

7. Voluntary nature of personal information

The provision of personal information is voluntary and not mandatory. However, please understand that if you do not provide your personal information, you will not be able to use the services described in the Purposes of Use.

8. Acquisition of personal information by methods not easily recognizable by the individual

We may use information such as cookies and browsing history (hereinafter referred to as "Personal Information") to enhance the information and services provided on our website and to make it more convenient to use. When we obtain Personal Information from a data management platform operated by a third party and use it within the scope of the purpose of use after linking it with your Personal Information, we will obtain your consent in advance.

9. Disclosure, correction, and deletion of retained personal data

The procedures for requesting disclosure, etc. (notification of purpose of use; disclosure; correction, addition, or deletion of content; suspension of use; deletion; and suspension of provision to third parties) of retained personal data and records provided to third parties in accordance with Japan's Act on the Protection of Personal Information (the "Personal Information Protection Act") are as follows.

In principle, requests for disclosure, etc., must be made by the individual in question. In order to make a request, identification and details of the request are required, so please fill out the necessary documents specified by the Company and submit them to the contact listed in "11. Contact for inquiries."
The disclosure, etc., is not applicable in any of the following cases: when there is a risk of harm to the life, body, property, or other rights and interests of the person concerned or a third party; if there is a risk of causing significant hindrance to the proper conduct of our business; or when such disclosure would violate other laws or regulations.

10. Security control measures

We will take necessary and appropriate security control measures to prevent the leakage, loss, or damage (hereinafter referred to as "leakage, etc.") of personal data and to manage such data. The security control measures for personal data are as follows.

Formulation of basic policy
To ensure the proper handling of personal data, we have established the Personal Data Protection Policy.
Establishment of rules for handling personal data
For each stage of acquisition, use, storage, provision, deletion, and disposal, etc., the Company has established its "Basic Rules for Personal Data Protection" (hereinafter referred to as the "Basic Rules for Personal Data Protection"), which describe the acquisition method, person/persons responsible and in charge, and their duties, etc.
Organizational safety control measures
1. In addition to appointing a personal information protection administrator for the handling of personal data, the Company has established a system for clarifying the employees who handle personal data and the scope of personal data handled by such employees, and for reporting to the personal information protection administrator in the event that a violation of the Act on the Protection of Personal Information or the Basic Rules for Personal Data Protection is detected or if any indication of such a violation is detected.
2. Periodic audits are conducted to ensure that the handling of personal data is in compliance with laws and regulations, the Basic Rules for the Protection of Personal Information, and other standards.
Personnel safety control measures
1. Matters concerning the confidentiality of personal data are stipulated in the employment regulations.
2. Regular training is provided to employees on matters to be considered in the handling of personal data.
Physical security control measures
1. In areas where personal data is handled, access control for employees and restrictions on equipment and other items that they may bring into the office are in place, and measures are taken to prevent unauthorized persons from viewing personal data.
2. Measures are taken to prevent theft or loss of equipment, electronic media, and documents that handle personal data, as well as to prevent personal data from being easily discovered when such equipment, electronic media, etc., are carried out, including during transportation within the business site.
Technical security control measures
1. Access control is implemented to limit the scope of persons in charge and the personal information database, etc., handled.
2. A system is in place to protect the information system handling personal data from unauthorized external access or unauthorized software.
Understanding of the external environment
1. In the event that personal data is handled in a foreign country, the Company shall take measures for the secure management of personal data after obtaining information on the personal data protection system of the country concerned.
2. If personal data is handled in a foreign country and you would like to know the name of the foreign country and the outline of its system for the protection of personal information, please contact us at by referring to "11. Contact for inquiries" below

11. Contact for inquiries

For inquiries regarding the disclosure, etc., of retained personal data (personal data for which we have the authority to disclose, correct, add, or delete content, suspend use, erase, or suspend provision to third parties, other than data specified by the Order for Enforcement of the Act on the Protection of Personal Information as data for which disclosure would harm the public interest or other benefits), or for inquiries regarding the handling of personal data, please contact the following.

Please note that this address is the contact point for Pasona Group Inc. Inquiries from users of human resources services should be directed to the respective company's inquiry desk.

Pasona Group Inc.
3-1-30 Minami-Aoyama, Minato-ku, Tokyo (〒107-8351)
E-MAIL ： pd_protection@pasonagroup.co.jp

Last revised on April 1, 2022

Basic Policy on the Proper Handling of Specified Personal Information, etc. ("Basic Policy")

We have established this Basic Policy to ensure the proper handling of specified personal information and personal numbers ("Specified Personal Information, etc.") in accordance with Japan's Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures (the "My Number Act") as an organization.

Compliance with relevant laws, regulations, guidelines, etc.
We will properly handle specified personal information, etc., in compliance with the My Number Act, the Act on the Protection of Personal Information, the "Guidelines for the Proper Handling of Specified Personal Information (Business Operators' Edition)," and other guidelines.
Purpose of use
We will use the Specified Personal Information, etc., provided to us for the purposes set forth in the "Rules for Handling Specified Personal Information" separately stipulated by us.
Matters concerning safety control measures
We will take necessary and appropriate security control measures for the management of Specified Personal Information, etc., including the prevention of leakage, loss, or damage. In addition, the Company shall exercise necessary and appropriate supervision over its employees, and contractors (including subcontractors, etc.) who handle Specified Personal Information, etc. (including subcontractors, etc.) will be supervised as necessary and appropriate. The security control measures for Specified Personal Information, etc., are specifically stipulated in the "Regulations for Handling Specified Personal Information, etc."
Response to complaints and consultations
Inquiries regarding specified personal information handled by the Company should be directed to the relevant department that acquired the specified personal information from the person in question or to the following contact point.
(1) Inquiries concerning specified personal information handled in relation to Pasona Group's business
Finance and Accounting Department, Pasona Group Inc.
1-30, Minami-Aoyama 3-chome, Minato-ku, Tokyo 107-8351, Japan
(2) Contact for inquiries regarding specified personal information, etc., handled based on an employment relationship with the Company
Human Resources Department, Pasona Group Inc.
1-30, Minami-Aoyama 3-chome, Minato-ku, Tokyo 107-8351, Japan

Pasona Group Inc.
Group CEO
Yasuyuki Nambu