Protection of Personal Information

The Western Digital Technologies Health Insurance Association (hereinafter “WDTJ”) conducts various healthcare businesses for the purpose of providing insurance benefits and maintaining as well as promoting better health of insured persons and dependents (hereinafter “enrollees”). WDTJ strives to properly collect, use, and protect the personal information by defining this Privacy Policy to earn the trust of every enrollee in the course of executing these healthcare businesses.

Western Digital Technologies Health Insurance Association Policy on the Protection of Personal Information (Privacy Policy)

The Western Digital Technologies Health Insurance Association promotes the following initiatives from a stance of properly protecting the personal information of each enrollee (hereinafter “personal information”).

WDTJ has put in place the proper measures to protect the personal information collected from enrollees in an effort to prevent any leak, loss, damage, or unauthorized access to the personal information of enrollees.
WDTJ only uses personal information provided by enrollees for the purposes believed to benefit every enrollee, such as maintaining and promoting better health. WDTJ also only uses individual numbers for the designated purposes and range stipulated by the Act on the Use of Numbers to Identify a Specific Individual in the Administrative Procedures.
WDTJ never discloses personal information about an enrollee to a third party without prior consent. Moreover, the WDTJ never discloses personal information which includes individual numbers (hereinafter “personally identifiable information”) regardless of whether an enrollee gives consent, except when said disclosure is stipulated in the Act on the Use of Numbers to Identify a Specific Individual in the Administrative Procedures.
However, personal information which is not personally identifiable information may be shared with a third party without the prior consent of an enrollee if said disclosure is Article 27, Paragraph 1 of the Act on the Protection of Personal Information (Law No. 57, May 30, 2003).
WDTJ provides education and raises awareness about the protection of personal information in all of its employees and appoints an officer responsible for handling personal information in an effort to properly handle any and all personal information.
WDTJ reviews and enhances any outsourcing operations to ensure an even higher level of personal information protection. When entering into any outsourcing agreement, WDTJ carefully evaluates the qualifications of each outsourcer and makes certain even the terms and conditions of contracts provide the utmost protection of personal information.
WDTJ strives to ensure the personal information of enrollees is as up-to-date, accurate, and protected as possible. Enrollees may make inquiries, corrections or any other such requests regarding their personal information by contacting WDTJ customer service. WDTJ will promptly respond to said requests within a reasonable range.
WDTJ complies with all laws, regulations and other standards related to the handling of the personal information of enrollees and consistently revises and improves the terms and conditions of this privacy policy.

Customer Service

Western Digital Technologies Health Insurance Association

TEL: 03-6380-1635　
Email: info@wdtj-kenpo.jp

Business hours: Weekdays 9:30 A.M. to 12:00 P.M.; 1:00 P.M. to 6:00 P.M.

Disclosure of Personal Information Collected by WDTJ and Its Purpose of Use

The Western Digital Technologies Health Insurance Association (hereinafter “WDTJ”) creates a personal information database and uses personal information to render health insurance services collected from (1) personal information included on various notifications and application forms submitted by insured persons and family dependents (hereinafter “enrollees”), (2) personal information included on statements of medical expenses (hereinafter “health insurance claims”) billed by healthcare providers and other medical institutions for medical care provided to enrollees, and (3) personal information included in the health checkup results data from medical examinations undergone by enrollees.

WDTJ uses personal information for the purpose of either providing insurance benefits to enrollees for illnesses, injuries, or deaths not caused by occupational accidents as well as childbirth, or executing operations necessary for maintaining and promoting better enrollee health as provided for in the Health Insurance Act.

WDTJ services require a tremendous amount of trust from enrollees as a health insurance association handling a large volume of medical data from health insurance claims to medical examination results as well as other personal information. Therefore, the Ministry of Health, Labour and Welfare published more detailed guidelines advising clearly defined purposes to limit the use of personal information.

WDTJ shall handle the personal information collected in Attachment 1 in accordance with the usage purposes outlined in Attachment 2 as a general rule. The purpose and method for using personal information is disclosed below.
Furthermore, WDTJ never uses personal information in its possession for any other purpose than running its healthcare businesses.

Applicable Notification and Application Forms
1. WDTJ has configured a master database (hereinafter “master data”) including an enrollee ledger and stores data on computers for operational processes to use throughout the entire health insurance association for input and processing of health insurance card numbers, names, dates of birth, genders, addresses, monthly remuneration and other items included in applications for eligibility as an insured person or dependent change notifications when individuals enroll in the health insurance association.
2. WDTJ issues health insurance cards after verifying applications for eligibility as an insured person and dependent change notifications.
3. WDTJ executes certification processes according to certificates of taxation and exemption of local taxes, copies of student identification cards, income statements and various other discretionary materials when an insured person submits a dependent change notification.
4. WDTJ requires insured persons to return health insurance cards when submitting a notification of forfeiture of eligibility, which are verified and stored for a fixed period of time before disposal.
5. WDTJ updates the data registered as master data according to applicable change (correction) notifications to update or add information to the master data.
6. WDTJ correlates data on benefits, health insurance claims, health examination and other relevant data using the master data to verify benefit payments and other processes, to identify persons related to notifications on medical care costs and various other health insurance businesses, and to contact enrollees.
7. WDTJ may contact individuals using the address, name or any other contact information included on notifications or in the master data as necessary even after said individual loses eligibility as an insured person of the health insurance association.
8. WDTJ answers inquiries about qualification or forfeiture of eligibility and other such health insurance-related healthcare questions from healthcare providers, other insurers, including municipalities and pension offices, using personal information such as health insurance card numbers, names, dates of birth, genders, dates of qualification, or dates of loss of qualification, after verifying the identity of the person making the inquiry.
9. WDTJ may ask other insured persons or third parties about health insurance card numbers, names, dates of birth, genders, dates of certification or loss of qualification or other information in the master data to make adjustments of duplicate benefits of other insured persons or healthcare providers if any discrepancies arise, such as examinations after an individual loses eligibility as an insured person.
10. WDTJ incorporates data from notifications on the calculation basis and monthly changes into the master data to charge insurance premiums, including adjusted insurance premiums and long-term care insurance premiums. In addition, WDTJ requests employers submit salary and bonus ledgers and other documentation for review when submitting a notification.
11. WDTJ provides health insurance card numbers, names, dates of birth, genders, and addresses included in the master data about individuals applying for a physical examination to contract healthcare providers to use when sending results from the examination.
12. WDTJ provides health insurance card numbers, names, genders, and addresses included in the master data about individuals using health service options to contractors "Valur HR Co.,Ltd" to use for Health Checkup Reservation and various purchasing applications.
Cash Payments and Other Benefit Application Materials
1. WDTJ enters data on computers for business processing and reviews application details to make proper payment decisions.
2. WDTJ enters data to store payment records for use when reviewing applications thereafter.
3. WDTJ may ask a third-party insured person about health insurance card numbers, names, dates of birth and other information in the master data about individuals requesting childbirth and childcare lump-sum allowances or dependents’ childbirth and childcare lump-sum allowances when necessary for adjusting duplicate benefits of other insured person to make payment decisions.
4. WDTJ responds to inquiries about whether a request was made for childbirth and childcare lump-sum allowances or dependents’ childbirth and childcare lump-sum allowances from other insured persons by providing information about applications and benefits after verifying the identity of the person making the inquiry.
5. WDTJ reviews health insurance claim data of individuals requesting injury or illness allowance and asks the physician in charge for verification or evaluation, the status of medical treatments, and any other applicable information as necessary to make payment decisions.
Certificate of Medical Remuneration (Health Insurance Claims)
1. WDTJ stores images and data of health insurance claim requests by the Health Insurance Claims Review & Reimbursement Services on its computers for business processing to use in healthcare businesses.
2. The inspection of the contents of receipt data is outsourced to a contractor "Taisho Audit Co" and requests a secondary evaluation by the Health Insurance Claims Review & Reimbursement Services for any questions arising about a claim.
3. As part of this request for a secondary evaluation, WDTJ shares the name of the health insurance association, the health insurance card number, name, date of birth, date of loss of qualification, the date on which medical care was provided and other relevant information with the healthcare provider for confirmation if a question arises about an exam after the individual loses their qualification as an insured person.
4. As part of a review of whether there are public expenditures of patients expected to pay high-cost medical expenses or medical cost subsidies from a municipality, WDTJ shares the name of the health insurance association, the health insurance card number, name, date of birth, and other relevant information with the healthcare provider for confirmation.
5. WDTJ uses health insurance claim data to analyze medical costs and ensure no billing errors of the health insurance association as well as to provide post-health guidance after physical examinations, and to identify candidates for education to prevent lifestyle diseases.
6. WDTJ uses health insurance claim data to identify and provide guidance to enrollees who have undergone examinations at several healthcare providers in the same month.
7. WDTJ uses health insurance claim data to make decisions on payments of high-cost medical expenses and benefits, such as co-payment reductions, additional aggregated high-cost medical expenses, and additional family medical expenses.
8. WDTJ refers to health insurance claim data to make payment decisions about injury and illness allowances.
9. WDTJ refers to health insurance claim data to make payment decisions about therapies and other medical treatments performed by judotherapists as well as medical costs for family dependents.
10. WDTJ refers to health insurance claim data to make payment decisions about funeral expenses of an insured person or family.
11. WDTJ responds to requests for disclosure of health insurance claims by providing relevant data for said health insurance claims.
  Moreover, WDTJ only discloses information to approved parties in accordance with disclosure rules pertaining to disclosure requests.
12. Based on the receipt data, we entrust the contractors "Value HR Co.,Ltd.and Hoken Co.The company notifies subscribers of "medical expense notices," "benefit payments", and "generic drug difference information.
13. With regard to the billing of medical treatment expenses for Judo therapists, we entrust the inspection organization"Taisho Audit Co."
14. WDTJ submits copies of health insurance claims of relevant patients for any medical care provided due to traffic accidents or actions of a third party to non-life insurance companies.
15. WDTJ sends a copy of health insurance claims and applications including some of the details in the course of applications to joint projects to pay high-cost medical expenses run by the National Federation of Health Insurance Societies (Kenporen) to receive subsidy grants.
Health Checkups
1. WDTJ outsources health checkups to medical contractors"Valu HR Co.,Ltd."
2. WDTJ receives the numerical result data from the medical contractor and notifies the patient of said results. WDTJ also uses the results data to provide post-health guidance after the examination and identify candidates for education to prevent lifestyle diseases.
3. The Western Digital Technologies Health Insurance Association provides health checkups in cooperation with employers. Therefore, WDTJ contacts every employer about the numerical results of health checkups of insured persons (employees) as a general rule, and WDTJ and the employer both store a copy to help in the health management of insured persons.
4. WDTJ saves result data from health checkups as master data to compare with future data for reference in the provision of health management services and health guidance.
Execution of Other Healthcare Businesses

The health insurance association will use the symbol number, name,and address data on the insurance card to implement various health services.
- Publication of public relations magazine Social Insurance Publication Co.
- Publication of health checkup guide Sun Life Planning Co.
- Information magazine at the time of the birth of a subscriber Baby and Mama Co.
Human Resource Data on Officers and Employees, WDTJ Committee Member List, and a List of Health Insurance Representatives at Each Business Establishment
1. WDTJ carefully stores all materials about the appointment and hiring of WDTJ officers and employees after use.
2. WDTJ carefully stores all materials about the remuneration of WDTJ officers and employees to use for tax withholdings and other such processes.
3. WDTJ uses the WDTJ Committee Member List when contacting members and directors about Board of Directors meetings and other matters.
4. WDTJ uses the list of names of health insurance representatives at each business establishment, at the Health Management Promotion Committee, and in other business-related liaison work.
Personally Identifiable Information

“Personally identifiable information” refers to personal information, including individual numbers (My Numbers) or other numbers, codes and symbols used as an alternative to individual numbers, excluding certificate of residence codes.

The Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures defines the usage scope of personally identifiable information, such as the sharing of information between parties involved in administrative processes of government bodies. For example, local municipalities provide information on taxation and exemption of local taxes to health insurance societies for the certification of dependents. Personally identifiable information cannot be used for any purpose other than the specific purposes within the usage range stipulated by the Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures.

In addition, any use outside the usage scope stipulated in the Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures must mask, delete or take other measures to redact individual numbers from personally identifiable information.
Storage Management, Disposal and Deletion of Personal Information
1. WDTJ document management regulations define rules for warehouse storage of any personal information included in various notifications, applications, health insurance claims, and other paper documents for a prescribed number of years after data entry and restrict anyone from taking said documents out of storage unless necessary for verification or other such processes.
2. WDTJ also properly stores personal information in non-paper mediums according to operation management rules related to the storage on non-paper mediums.
3. WDTJ shreds paper documents containing personal data which has passed the prescribed storage period or is no longer necessary after processing into small illegible pieces and outsources disposal of a large quantity of personal data to contract processors which dissolve said documents into pulp.
4. WDTJ disposes or returns computers and other magnetic storage media by first rendering data unreadable using a data erasing software.

→Attachment 1: Example of personal information held by the Western Digital Technologies Health Insurance Association
→Attachment 2: Main usage purposes of personal information foreseen in standard Western Digital Technologies Health Insurance Association operations

Disclosure of Personal Information to Third Parties

A health insurance association is deemed to have been granted full implied consent for the use of personal information when no explicit objection or reservation is raised by the insured person or other concerned parties in its position under Notification No. 0414-(18), “Guidance on Proper Handling of Personal Information at Health Insurance Societies,” issued on April 14, 2017 by the Director of the Health Insurance Bureau of the Ministry of Health, Labour and Welfare Health Insurance Bureau for purposes beneficial to insured persons and other concerned parties or in cases where changes to current methods of notification on medical care costs or other such information impose an unreasonable burden on the health insurance association while obtaining explicit consent would also not necessarily be reasonable from the point of view of the insured person, which applies to the provision below.

Disclosure of Personal Information to Third Parties (Scope of Full Consent)
[Usage Purposes]
1. To provide notifications on health care costs for a single household
2. To provide payments for high-cost medical expenses and additional benefits without relying on applications from individuals
3. To provide payments for childbirth and childcare lump-sum allowances and other various payments and additional cash benefits
4. To provide payments for influenza vaccine and other healthcare business subsidies to insured persons for family members

Items, Procedures and Methods for Disclosure of Personal Information (Personal Data) to Third Parties

Usage Purposes	Item of Personal Information for Disclosure to Third Parties	Procedure and Method of Disclosure
1	Names of patients, dates of treatments, payment period, treatment classifications or types of benefits, days, total medical care costs, amount of health insurance coverage, out-of-pocket costs, names of healthcare providers rendering treatments, amount of statutory benefits, amount of additional benefits, and payment dates	Disclosed as statements of medical care costs every month on the Western Digital Technologies Health Insurance Association website
2 and 3	Codes, numbers, names of individuals, names of the type of cash benefits, and amounts of payments	Disclosed to the person in charge at the employer
4	Codes, numbers, names of individuals, names by type, and amounts of payments	Disclosed to the person in charge at the employer

Handling of Anonymized Data

“Anonymized data” refers to information related to individuals collected by anonymizing data to remove any personally identified information and ensure the personally identifiable information cannot be recovered to identify an individual.

Health insurance societies continuously create anonymized data for healthcare businesses, epidemiological surveys, and other such operations in order to provide said data through electronic means of communication to contractors which analyze health insurance claims. The anonymized data created for provision includes genders, dates of birth, health insurance eligibility, such as enrollment periods, withdrawal periods, and the classifications of the insured persons and family, histories of treatments in certificates of medical remuneration, and the histories of general medical checkups as informational items. This anonymized data never includes any personally identifiable information.
Procedures to Cease Disclosures to Third Parties
1. Insured persons and other individuals may request the Western Digital Technologies Health Insurance Association obtain explicit consent in advance for any usage purposes which the individual does not feel comfortable granting implicit consent.
2. If the insured person or other individuals do not express the above intention to cease disclosure, WDTJ deems that it has received full consent for the usage purposes it has announced.
3. The insured person and other individuals may decide to grant full consent or indicated reservations about disclosing an item at any time.
Please contact WDTJ customer service using the contact information below if you would like to cease disclosure of any items.

Customer Service

Western Digital Technologies Health Insurance Association

TEL: 03-6380-1635　
Email: info@wdtj-kenpo.jp

Business hours: Weekdays 9:30 A.M. to 12:00 P.M.; 1:00 P.M. to 6:00 P.M.

Joint Use of Personal Information: (1) Subsidy Projects Related to Payment of High-cost Medical Expenses

The Western Digital Technologies Health Insurance Association uses personal information (personal data) it has collected in the joint projects outlined below.

In addition, Article 27.5.3 of the Act on the Protection of Personal Information stipulates an entity or business operator receiving such personal information (personal data) shall not be deemed a third party and may disclose such personal information (personal data) without the prior consent of the individual in cases in which (1) personal data used jointly, (2) the items of the personal data used jointly, (3) the scope of the joint users, (4) the purpose for which the personal data is used by them, and (5) the name of the individual or business operator responsible for the management of the personal data is, in advance, notified to the person or put in a readily accessible condition for the person.

Items for Joint Use of Personal Information (Personal Data)

(1) Certificates of medical remuneration including certificates of pharmaceutical remuneration (hereinafter “health insurance claims), (2) data or written documents for summary statements of subsidy applications recording items such as patient names, genders, insured persons or family dependents, in-patient or out-patient care, dates of treatments, and the amounts of said health insurance claims, in addition to all other items of data included in health insurance claims
Persons or Entities Jointly Using Personal Information
- Kenporen, subsidy project groups, employees in charge of high-cost medical expenses
- Contractors of Kenporen (ICT and healthcare promotion divisions and partner companies of the Japan Productivity Center)
Joint Usage Purposes

Subsidy projects related to payment of high-cost medical expenses
Officer Responsible for Personal Information Management
- Western Digital Technologies Health Insurance Association
  (Address) 2F Yoyogi East, 5-23-5 Sendagaya, Shibuya-ku, Tokyo
  (Board chairperson) Reiji Suzuki
  (Manager) Managing director
- National Federation of Health Insurance Societies
  (Address)　1-24-4,Minami-aoyama,Minato-ku,Tokyo
  (Chairman)　Shunichi Miyanaga
  (Manager) 　Support Dev　General manager
Inquiries

Customer Service

Western Digital Technologies Health Insurance Association

TEL: 03-6380-1635　
Email: info@wdtj-kenpo.jp

Business hours: Weekdays 9:30 A.M. to 12:00 P.M.; 1:00 P.M. to 6:00 P.M.

Joint Use of Personal Information (2) Personal Information Used Jointly with Employers

The Western Digital Technologies Health Insurance Association uses personal information (personal data) it has collected in the joint projects outlined below.

Items for Joint Use of Personal Information (Personal Data)
1. Personal information about individuals including necessary information about dependents such as names, genders, dates of birth, employee numbers, affiliations, positions, addresses, telephone numbers, standard monthly remuneration, standard amount of bonuses, business email addresses, and certifications as a dependents
2. Information about regular health check-ups, physical examinations, and other general health examinations provided by the WDTJ healthcare business including codes, numbers, names, dates of birth, genders, age, addresses, telephone numbers, and email addresses of patients as well as the names of employers, employee codes, dates of heath examinations, dates of reservations for health examinations, names of healthcare providers, items included in the health examinations, numerical results of healthcare examinations, diagnoses, questions asked by physicians, and details of any health guidance
Persons or Entities Jointly Using Personal Information
- WDTJ employees
- HR managers of employer
- Medical examiners of employer
- Industrial physicians
- Contractors
Joint Usage Purposes
1. Smooth and precise execution of the WDTJ operations, such as certifying or revoking eligibility, benefits payments, and healthcare businesses stipulated for health insurance societies by the Health Insurance Act
2. WDTJ and employer activities for health promotion and prevention of onset and progression of illnesses through aftercare, health guidance, consultations and other measures based on health examination results of insured persons as well as
  evaluations and analyses after taking measures to enhance the effectiveness of projects conducted with employers
Officer Responsible for Personal Information Management
- Western Digital Technologies Health Insurance Association
  (Address) 2F Yoyogi East, 5-23-5 Sendagaya, Shibuya-ku, Tokyo
  (Board chairperson) Reiji Suzuki
  (Manager) Managing director
- Employers and General HR managers
Inquiries and Feedback

Customer Service

Western Digital Technologies Health Insurance Association

TEL: 03-6380-1635　
Email: info@wdtj-kenpo.jp

Business hours: Weekdays 9:30 A.M. to 12:00 P.M.; 1:00 P.M. to 6:00 P.M.

Procedures for Disclosure or Correction of Personal Data or Termination of Use

Anyone who would like to request disclosure or correction or stop use of personal data collected by WDTJ may acquire, fill out, and submit the designated WDTJ application form according to the handling requirements related to the disclosure or correction of personal data or termination of use.

Specific Procedures

Acquire a Request for Disclosure of Personal Information Collected by WDTJ to file a request for disclosure of personal information or acquire a Notification of Correction/Termination of Use of Personal Information Collected by WDTJ to file a request to correct or terminate the use of personal information.
Fill in the necessary items.
Prepare the necessary documents to attach. Please ask WDTJ about the necessary document attachments.
Submit the application form and other materials to WDTJ.

WDTJ considers the convenience of everyone filing requests or notifications to make application processes as simple as possible for individuals. The WDTJ responds to any requests or notifications in writing. As a general rule, WDTJ will respond to a request for disclosure by disclosing the information regardless of the reason. However, WDTJ may refuse to disclose information in part or in whole if the disclosure may harm the assets or other interest of a third party, if it may significantly inhibit the proper execution of WDTJ operations, or if the WDTJ does not have the personal data requested for disclosure. In this case, WDTJ will immediately notify the individual of the reason in writing.

Requests for Disclosure of Certificates of Medical Remuneration (Health Insurance Claims)

WDTJ discloses certificates of medical remuneration (health insurance claims) in accordance with rules on disclosure of certificates of medical remuneration and other documents as well as administrative requirements for handling disclosures of certificates of medical remuneration and other documents. In the course of disclosing certificates of medical remuneration (health insurance claims), WDTJ asks the in-network healthcare provider or other medical institution which issued the health insurance claim whether disclosure is appropriate because it is difficult for WDTJ to determine whether the disclosure of the health insurance claim would hinder the medical care of an individual.

WDTJ does not charge disclosure fees as a general rule but will charge the actual costs of sending documents if a reply or other response is requested by postal mail.
Please do not hesitate to contact WDTJ with any other inquiries you may have.

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