Handling of Pseudonymized Personal Information at Deloitte Tohmatsu Consulting LLC

1. Definition of Pseudonymized Personal Information

Pseudonymized personal information means information relating to an individual that can be prepared in a way that makes it not possible to identify a specific individual unless collated with other information by taking any of the measures prescribed in the Act on the Protection of Personal Information.

2. Preparation and Handling of Pseudonymized Personal Information

When preparing pseudonymized personal information, Deloitte Tohmatsu Consulting LLC (hereinafter referred to as "our company") will take the following measures:

(1) Proper processing in accordance with standards prescribed by applicable laws and regulations. 

(2) Implementing security measures for information that has been deleted and information about the processing method, in accordance with standards prescribed by applicable laws and regulations.

(3) Not collating the pseudonymized personal information with other information in order to identify a person identifiable by personal information that was used to prepare the pseudonymized personal information. 

(4) Complying with other matters required by laws and regulations.

3. Purpose of Using Pseudonymized Personal Information

Planning, research, development, survey, analysis, and sales promotion of services, without identifying a specific individual.

4. Joint Use of Pseudonymized Personal Information

Our company may jointly use pseudonymized personal information among those entity or entities as specified in "(2) Scope of Joint Users".

(1) Items of pseudonymized personal information to be jointly used:

Information obtained in the process of providing our services, such as the following information prepared so that a specific individual cannot be identified.

• Company attributes: Industry, employee size
• Individual attributes: Gender, age, occupation, position, employment form, income level, place of residence (up to the prefecture) 
• Service history (assessment results, course attendance status, questionnaire results, test answers, inquiries)

(2) Scope of Joint Users:

Entities of Deloitte Tohmatsu Group

(3) Purpose of Joint Use:

May jointly use within the scope of "3. Purpose of Using Pseudonymized Personal Information".

(4) Manager of Joint Use:

Deloitte Tohmatsu Consulting LLC (details here)

5. Complaints and Inquiries

If you have any complaints, opinions, or questions regarding the preparing/handling of pseudonymized personal information by each entity of Deloitte Tohmatsu Group, please contact here.