Japan: Closed consultation on draft to partially amend the Personal Information Protection Act Guidelines (for Checking and Recording on Transfers to Third Parties)

On 13 October 2023, the Japanese Personal Information Protection Committee (PIPC) closed its consultation on the draft to revise the Personal Information Protection Act Guidelines (for Checking and Recording on Transfers to Third Parties). The draft focuses on the checking and recording obligations of data handlers associated with sharing personal information with third parties. It also provides explanations regarding the criteria for applying these obligations. The obligations hinge on whether the shared information qualifies as "personal data" as defined by the Act. If the information does not meet this definition at the time of sharing, the checking and recording obligations are not enforced. Nevertheless, even if the shared information initially does not meet the criteria for personal data, if the third party subsequently incorporates it into their database or treats it as personal data, the obligations become applicable from that point onwards.