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CDS Privacy Policy
CDSI K.K.
Recruiting License 13-(yu)-070352
Article 1.Purpose
CDSi K.K. (hereinafter CDS) is committed to protecting personal information of the candidates. This policy outlines our personal information handling practices. The purpose of this Policy is to protect candidates’ rights and to realize our public-spiritedness as a recruiting agency.
Article 2. Types of personal information CDS collects
Personal information stated in this rule will be information from 1-4 of the candidates, the client employee and dispatch employee.
1. Resume, career history
2. Application for registry
3. Record of interview with candidates
4. Any other document that could specify individuals
Article 3. People who have permission to handle personal information
Personal information responsible official or the staff who has been assigned by the official can handle the personal information.
Article 4. Personal information protection responsible official
We will choose one responsible official who will be responsible for below.
1. Create, revise, modify and store privacy policy.
2. To familiarize those below with Privacy Policy;
a. Those who handle personal information.
b. Those who will be handling the information.
3. Managing all complaints and consultation regarding handling the privacy policy.
4. Provide this privacy policy freely available for candidates.
5. Respond to the instruction of administrative authority regarding personal information protection and familiarize the staff with the instruction.
6. Control and manage the application software for personal information protection.
7. Manage the password, periodic modification and cancellation of the password for accessing the personal information stored on computers.
8. Taking measure in protecting the information stored on computer from illegal access.
9. Other duties that will be written in this policy.
Article 5. Perpetuating the ethics
At CDS, any employee, regardless of his/her title, shall familiarize with the content of Privacy Policy and strictly observe it. In addition, he/she shall recognize the responsibility associated with handling personal information and perform his/her job with high ethical standards.
Article 6.Definition of confidential information
In this rule, confidential information by definition is facts about a candidate he/she
earns benefits from not having them disclosed. e.g.)permanent address (except the name of the prefecture), place of birth, a political party he/she supports/is part of, history of political movements, amount of debts, the fact that he/she is a guarantor of a loan
Article 7. Prevention of confidential information leakage
CDS shall strictly observe the following in order to prevent leakage of confidential information of a candidate without good reason
1. CDS employees shall not leak the information during his/her employment at CDS and after he/she resign from CDS.
2. CDS employees shall not take out of office any document that contains confidential information.
Article 8. Legitimate cause that is not considered as confidential information leakage
Following causes are not considered as confidential information leakage as stated. However, we shall try to keep the information provided minimum.
1. If we are under legal obligation to provide the document from public institutions.
2. Testimony at the court.
3. Reference based on criminal procedure law, requested by an investigative organization.
4. If there are any threats on violating the person or the third party’s life, body, asset, other rights and profit.
Article 9. Personal information of clients
In regards to the personal information of clients, CDS shall strictly observe the following rules.
1. CDS shall not leak the information without justifiable causes.
2. CDS shall not use the information for any other purposes than for recruiting.
3. CDS shall request candidates not to leak the information without justifiable causes.
Article 10. Collection of personal information
CDS will collect the personal information only for the use of introducing candidates to clients. We will therefore collect only the information that is required in the hiring process.
Article 11. Methods used in collecting personal information
The method shall be one of the followings and in cases where another method will be used, the approval from the holder of the information must be acquired after the information had been collected.
1. Collecting from candidates.
2. Collecting from other people upon the consent of candidates.
Article 12. Information which should not be collected:
The following information should not be collected unless there is a clear acceptance from the candidate, rules in ordinance, or from the necessity due to legal procedures.
1. Ethnic group, race, social status, family origin, address, registered address,
place of birth or other details that may cause social discrimination.
2. Ideas and beliefs.
3. Involvements with labor union.
Article 13. Prohibition of identity confirmation
CDS shall not make comments that encourage clients to confirm the identity of a candidate.
Article 14.Maintenance of personal information
Personal information shall be maintained in a way that no one else but those who have
permission to handle it can browse freely.
Article 15 Usage of the personal information
The collected personal information must be used only to provide candidate information to the client companies or to provide dispatch employee information to dispatch hiring companies. However, CDS may ask for feedback, request, and information to improve our services.
Article 16. Maintenance of the original copy
When taking personal information out of the office, copies must be made and the original must be kept in the prescribed place.
Article 17. Record of the clients to whom personal information is provided
When providing a copy of personal information to a client or a business partner, the record of transaction must be maintained.
Article 18. Consent of a candidate
When CDS needs to provide a candidate or dispatch employee’s personal information to a client, CDS shall disclose the name of the client to the candidate and obtain his/her consent.
Article 19. Outsourcing
In cases where the information needs to be outsourced for information processing, CDS shall decide on the outsourcing vendor under the condition that they would have standards that meet the personal information protection and will sign a NDA before outsourcing.
Article 20. Disclosure of personal information
When a candidate requests disclosure of his/her personal information, CDS shall respond to the request immediately.
Article 21. Correction and deletion of personal information
When a candidate requests CDS to correct, delete part of, or add to his/ her personal information, CDS shall respond to it immediately. If the original information is already provided to a client, CDS shall provide the changed information to the client upon the consent of the candidate.
Article 22. Receiving the acceptance from the candidates and dispatch employee
The acceptance on Articles 11, 12, 18 and 21 can be accepted either by document or orally.
Article 23. Right to refuse the use/ provision of personal information
If a candidate refuses the use of or provision of his/her personal information to a client, CDS shall respond to it.
Article 24. Destruction of document that contains personal information
Such document shall be destructed in case of the following immediately from the computers. However, in cases we have legal obligation or the destruction will interfere with our business operations, we will not destruct certain records.
1. A candidate requests destruction of such document
2. If a year has past without any job introduced to a candidate; but only if
no job is currently introduced to the candidate.
Article 25. Methods of Destruction
Destruction of document that contains personal information shall be performed in the following methods:
1. Shred by a shredding machine
2. Have an industrial waste disposer destruct it
Article 26. Prohibition of unfair treatment
In the case a candidate requests disclosure or correction of his/her personal information, or he/she refuses the use or provision of his/her personal information, CDS shall not treat the candidate unfairly for that reason.
Article 27. Exceptions on handling personal information
Regardless of Articles 20, 21, 23 and 24, there will be cases where we will not be accepting disclosure, amendment and deletion that may be an obstacle to our operation or records on our operations.
Article 28. Training
The person in charge of Privacy Policy shall provide employees with training regarding Privacy Policy at the beginning of their employment and annually.
Article 29. The method of training
The training shall be performed in the following ways;
1. The training shall be provided to all employees, regardless of their titles and types of employment
2. The training shall include the following items:
3. Recognize the importance of personal information protection.
4. Recognize the danger of inappropriate management of personal information
5. familiarize with Privacy Policy
Article 30. Response to the requests of candidates
The person in charge of Privacy Policy shall respond with sincerity to inquires, consultations, or requests from a candidate.
Article 31. Handling of complaints
In a case a candidate files a complaint in ways of handling the personal information, the person in charge of Privacy Policy will take measures.
Article 32. Penalties
Should an employee collect personal information against Privacy Policy, he/she shall be
subject to punishment according to CDS company rules.
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